Code of Professional Conduct

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Code of Professional Conduct

The Code of Professional Conduct highlights our personal responsibility for professional conduct. We expect all colleagues to comply with this Code of Professional Conduct and we expect others working on our behalf, such as contractors, advisors and other suppliers, to act in a manner that is consistent with our Code.

The Code of Professional Conduct are segmented in the following areas:
• Client Service
• Risk Management
• Work Environment
• Social Responsibility

1. Client Service

We uphold our clients trust by ensuring integrity; prioritising their needs; by providing objective and independent advice; and by protecting confidential and sensitive information. We commit that all our colleagues act in ways that justify and reinforce this trust.

Outcome

We are committed to delivering impact to the best of our abilities to all our clients and we hold our leaders accountable for that impact. Our leaders oversee our work, ensure that the conditions for impact are in place, and bring our best capabilities to every situation. All colleagues have the obligation to speak up if they feel that there is compromise.

Confidential Information

In the course of our work we are entrusted with confidential information and we take exceptional care to keep this trust. Client confidential information is all non-public information (written or oral), including business plans and trade secrets, client names, the nature of our client services, our recommendations or advice, client data, and information we purchase at our clients’ expense. All colleagues are expected to ensure that our clients’ data and the firm’s data environment is protected from unauthorized external access, as much as their own commitment to keep the confidentiality.

Firm members are also prohibited from using client confidential information for any reason other than the service of that client. Such information cannot be used for personal or political ends, or in service of a different client.

Conflict of Interest

Firm members are restricted from undertaking employed work outside the firm, and may not operate or actively manage a business, run for political office, or accept an official role in a political campaign or engage in any outside activities that could interfere with our responsibilities to our clients and the firm. All firm members are required to disclose any potential conflicts of interest, whether real or perceived, and to consult with relevant firm leaders on how best to handle the situation.

Client resources and assets

We expect colleagues to treat client assets, including facilities and equipment, with respect, and to spend only what is necessary to perform our work to the highest standard.

2. Risk Management

The trust, and our reputation for integrity and independence, is precious for our presence and operations. All colleagues therefore, are expected to act at all times to proactively manage risks to the firm and to build and protect the firm’s reputation.

Corruption

We will not participate in any form of corruption and we have an obligation to inform our clients if we encounter actual or perceived corruption in their organizations or on behalf of their organisation. Firm members, and anyone acting on our behalf, must not offer or receive gifts or favors to gain any form of advantage for ourselves, our colleagues, or any third party.

Higher Risk Situations

The firm has identified a number of client service situations that require colleagues to follow specific additional requirements to manage risks to clients, our firm, and our people. Working on areas like analytics, M&A, Public, Social or State-linked Sectors, specific industries, restructuring and bankruptcy, compensation, work requiring interaction with regulators, and work conducted in partnership with third parties are areas of high risk of exposure to sensitive and confidential data. Colleagues undertaking this work are required to be familiar with the specific policies and be trained as required before engaging in such assignments.

Public Relations

All colleagues are expected to present themselves professionally on social media. Even in the use of private social media accounts, we expect colleagues to be mindful of the perceptions that can be created. We expect colleagues to maintain both client and firm confidentiality, and to protect the firm’s reputation for political neutrality. All external publication and communication with the press requires approval by firm.

Resources and Security

All colleagues are required to protect the firm’s data and its data environment from unauthorized access. We expect colleagues to be thoughtful in how they use firm resources and protect the firm’s information and assets. Colleagues may not use company resources for personal or political purposes.

Working with third parties

We partner with other firms and engage individuals, including Senior Advisors, from outside the firm to bring the best to our clients and the firm. As much as the expertise is critical, security and confidentiality are critical too. We ensure that all third parties involved in any assignment, sign a code of conduct and Non-disclosure Agreement in addition to a clear set of terms of contract.

3. Work Environment

We attract, develop, and seek to excite and retain, truly exceptional people. We do this through the opportunities for impact, growth, and development we provide; by providing a work environment in which our people feel respected, and can thrive, grow, and be their best; and by maintaining a caring meritocracy.

Diversity and Inclusion

We value an inclusive culture and celebrate diversity of all types. Diversity in our teams improves the creativity of our thinking, the quality of our work, and the development experience for our people. We do not tolerate discrimination, harassment, or bullying in any form.

Fair and Equal Opportunity

Our individual evaluation processes and hiring process are transparent and fair, and based on our believe in fairness and equal opportunity purely based on meritocracy. Any form of favoritism, bias or personal relationship is prohibited to ensure this fair and equitable environment.

Personal Data

We handle our colleagues’ personal data fairly and with respect and will only collect personal data for specific, explicit, and legitimate purposes, and limit the data collected to only what is necessary for the purpose for which it was collected. We also ensure confidentiality of such data.

Handling Ambiguity

Not every situation can be neatly captured in a policy or code of conduct, and colleagues should always seek advice when faced with a difficult situation, or whenever they are unsure of the correct course of action. If a colleague observes something they believe may be inconsistent with our values, our policies, or this Code, could put the firm or an individual colleague at risk, or may be against the law, they have an obligation to speak up.
Colleagues in any kind of senior position, have an additional obligation to report anything that could be a violation of our Ensuring an Environment Free from Harassment or Discrimination Policy. Our aspiration is that all colleagues feel comfortable seeking advice or raising concerns directly with a firm colleague.

4. Social Responsibility

As a firm, we are committed to positive social impact. We help address societal challenges in the way we conduct ourselves in the course of our business; through our engagement in our communities; and in the investments we make to support significant and lasting impact on pressing social issues.

Societal Activities

In the course of client service, colleagues are expected to think broadly about the impact of our work on our clients’ multiple stakeholders, to help our clients be mindful of their social impact, and to always act in a manner that is consistent with relevant laws and regulations. We encourage colleagues who wish to give back to their communities other than in political activities.

Human Rights

We are committed to human rights and comply with all human rights laws. We do not tolerate physical violence, threats, bullying, or verbal abuse of any kind in the workplace, forced labor, child labor and human trafficking, whether in our own or our clients’ locations, or any other form of human rights violation.

Environment

We commit to minimizing any negative impact our firm has on the environment We are making efforts to manage, and reduce our carbon footprint. This includes reducing emissions from travel, where possible, minimizing waste, and increasing recycling.

Competition and Trade

We are committed to promoting free, fair and competitive markets, and compete on the quality and impact of our work. We abide by international trade regulations that prohibit or restrict trade with certain countries, organizations, or individuals. Further, all colleagues must comply with all relevant laws, regulations, and internal policies relating to anti-trust, fair competition, anti-money laundering, funding terrorist organizations, and trade controls.

Conclusion

Our Code of Professional Conduct highlights an obligation to maintain the highest professional standards. We are each responsible for applying the standards outlined in this code, and of taking the responsibility to speak up and voice any questions or concerns related to possible violations of this code, of our values, our policies, or the law.

This Code of Professional Conduct is intended to be a living document. The Risk, Audit and Governance Committee of the Shareholders Council is responsible for periodically refining and updating the content of this Code.