Code of ethics and professional conduct
Our values define who we are as a firm and who we aspire to be. They are the guiding principles that guide our actions and are essential to fulfilling our two-part mission: to help our clients achieve significant, lasting and substantial improvements in their performance and to build a great firm that attracts, develops, inspires and retains exceptional people. We expect all our colleagues to live our values every day. And when we are faced with a difficult situation, we expect everyone to challenge themselves and consult with colleagues to determine what course of action is most consistent with our values. While our values guide our behaviour and help us make the right choices, we also have firm policies. These policies set out our obligations as members of the firm and set out the rules for behaviour in a number of very specific, often complex situations. They apply to all members of the firm worldwide and we expect all colleagues to comply fully with these rules. We are held to the highest standards of integrity and conduct and therefore our rules often go far beyond what is required by law. Failure to comply with our policies may lead to disciplinary action, including dismissal from employment. Finally, we have a Code of Professional Conduct which sets out a set of expectations for the conduct of all members of the firm. The Code of Professional Conduct does not replace our policies. Rather, it serves as a guide to help colleagues understand the key elements of our policies and how those policies are enshrined in our values. The Code of Professional Conduct emphasises our personal responsibility for professional conduct. We expect all colleagues to comply with this Code of Professional Conduct and expect others working on our behalf, such as contractors, consultants and other suppliers, to act in accordance with our Code.
Our code of professional conduct
Our Code of Professional Conduct serves as a guide to our values and policies in action and defines the expectations we have of all firm members in the following areas:
1. to serve our clients with the highest professional standards
2. Creating a working environment that inspires and motivates our people
3. Fulfilling our responsibility to the community
4. Managing risks for the company
5. Seeking advice and raising concerns The Marrbery Code of Professional Conduct is supported by a full set of company policies.
1. serving our customers with the highest professional standards
We are honored to enjoy the trust of clients who We have earned this trust by always acting with the highest integrity; providing objective and independent advice; putting our clients’ interests ahead of our own; and protecting confidential and sensitive information. We expect everyone from all colleagues to always act in a way that justifies and justifies and reinforces the trust that we enjoy.
Impact on the client
As a firm, we set our sights high in terms of the positive impact we have through our service to clients. We will take on work when we can be confident that the objectives of the work will have a significant, positive and lasting impact; that the impact of our work has the potential to far exceed our professional fees; that we will not be pressured to compromise our values; and that we will stick to our commitment to do work that attracts, develops, inspires and retains exceptional people. We are committed to maximum impact for all our clients and we hold our leaders accountable for that impact. We expect our leaders to oversee our work, make sure the conditions for making an impact are right, and bring our best capabilities to every situation. All colleagues have a responsibility to speak up if they feel that our ability to realise these impact aspirations is being compromised.
Confidential customer informatio
In the course of our work we are entrusted with client and third party confidential information and we treat it with the utmost care with the information that has been entrusted to us. Confidential client information is all non-public information (written or verbal), including business plans and trade secrets, client names, the nature of our services, our references, the nature of our client services, our recommendations or advice, client data, and information that we acquire at our clients’ expense. We only share client confidential information with colleagues who have a legitimate need to know, or with those we know have a right to access this information. When using social media, we expect colleagues to protect confidential customer information, including anything that might reveal a customer’s identity or our presence there. Colleagues must also ensure that our client data and the firm’s information environment are protected from unauthorised external access by complying with the cybersecurity standards described in the firm’s cyber policy.
We must avoid engaging in outside activities that may interfere with our responsibilities to our clients and the firm. Each of us has a responsibility to ensure that So that there can never be any doubt as to whether we are acting in our capacity as an employee of the firm, or in any other role. Members of the firm are therefore not permitted to hold outside employment, nor are they permitted to conduct or actively manage a business, run for political office or take an official part in a political campaign. In addition, members of the firm may not serve on the board of directors of any for-profit company, whether private, public or state-owned, and must obtain permission before serving on the boards of non-profit organizations to ensure that no conflicts with our clients arise. Temporary client roles are only permitted in very limited circumstances and only after approval by the firm’s Client Risk Committee. All firm employees all members of the firm have a duty to disclose any potential conflicts of interest, real or perceived, and to consult with their respective firm managers and governing bodies on how best to deal with the situation.
Misuse of customer information
To ensure that there is no risk of insider trading, members of the firm and their family members are prohibited from buying or selling publicly traded securities (including securities issued by state, local, or municipal authorities in Ukraine and the European Union) of any client of the firm. Clients and must confirm the purchase and purchase and sale of any publicly traded securities in advance. In addition, firm members are prohibited from holding investments in a non-public company which they serve or making investments which create a conflict of interest for the firm or themselves. Members of the firm are also prohibited from using confidential client information for any purpose other than to serve that client. Such information may not be used for personal or political purposes or to serve another client.
Client resources and assets
We expect our colleagues to treat client property, including premises and equipment, with respect, and to spend only what is necessary to perform our work to the highest standard.
2. Creating a working environment that inspires and motivates our employees
We attract, develop, seek to engage and retain, truly exceptional people. We do this through the opportunities for influence, growth and development we provide; providing a work environment where our people feel respected and can thrive, grow and be and maintain a caring meritocracy.
Inclusiveness, diversity and a safe and respectful working environment
We value an inclusive culture and celebrate diversity of all types. Diversity in our teams enhances. The creativity of our thinking, the quality of our work, and the development experience of our employees. We expect every employee and each other to provide a work environment that celebrates the benefits of diversity and where everyone is treated with respect and dignity, feels welcome and safe and can grow, develop and do their best work. We do not tolerate discrimination, harassment or bullying in any form. Our expectations of behavior extend to all interactions in and out of the office including team, training and office activities and through electronic communications.
We demand that all colleagues support both the reality and perception of our meritocracy and do so in a caring, respectful, dignified and compassionate manner. Our website individual evaluation processes – which are crucial to our meritocracy – are holistic and confidential, and all colleagues should contribute to them with sincerity. Attempts to undermine our appraisal processes are contrary to our values. Any hiring, including for temporary positions or external services, should be in line with company processes and based solely on merit. Favoritism, or the perception of favoritism, poses a risk to our meritocracy and therefore we prohibit personal romantic, physical or family relationships between firm employees who are in any kind of leadership relationship or actively work together. We also prohibit the employment of children of partners of the firm. Colleagues must declare personal relationships that could interfere with our meritocracy or create any other conflict of interest.
Personal information from our colleagues
We treat our colleagues’ personal data fairly and only collect personal data for specific, explicit and legitimate purposes, and limit the scope of data collected to what is necessary for the purpose for which it was collected.
3. Fulfilling our responsibility to society
As a company, we are committed to making a positive social impact. We help solve societal problems in the way we do business; through our involvement in society; and in the investments we make to support a significant and lasting impact on pressing social issues.
The impact of our activities on society
When working with clients, colleagues are expected to think broadly about the impact of our work on our many stakeholders of our clients, help our clients be aware of their social impact, actively discuss the impact of our recommendations on the interests of shareholders, shareholders, clients and society, and always act in accordance with relevant laws and regulations. We encourage colleagues who wish to contribute to society – for example, by volunteering, serving on the boards of non-profit organizations, and philanthropy. However, members of the firm are not permitted to run for political office or to take an official, or formal, role in a political campaign.
We are committed to human rights and comply with all human rights laws. Our commitment to human rights determines who we serve and on what topics, and we will not do work that supports or makes possible human rights abuses. We do not tolerate physical violence, threats, bullying or verbal abuse of any kind in the workplace, either in our own or our clients’ workplaces. We require suppliers to comply with the Marrbery Supplier Code of Conduct, the Supplier Code of Conduct, which prohibits all forms of forced labour, child labour and human trafficking, and requires compliance with all laws relating to discrimination, harassment and bullying.
Marrbery aims to minimize our impact Our firm has an impact on the environment and we are committed to continuously improving our environmental policies and practices. We work hard to manage and reduce our global greenhouse gas and greenhouse gas emissions and waste. We expect colleagues to take account of their environmental impact when making decisions about how they operate. This includes reducing emissions from travel where possible, minimizing waste and increasing recycling at Marrbery and at customer sites.
Competition and trade
We aim to promote free, fair and competitive markets, and compete on the quality and impact of our work. We comply with international trade rules 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 antitrust, fair competition, anti-money laundering, terrorist financing and trade controls.
4. Risk management for the firm
We enjoy the trust of not only the clients we serve, but also the communities in which we operate and the talent that joins our firm. That trust, and our reputation for integrity and independence, is precious – our ability to influence our clients, provide opportunities for our people and contribute to the economy and communities in which we live and work depends on it. All colleagues are therefore expected to act at all times to actively manage risks to the firm and to build and protect the firm’s reputation.
Corruption, bribes, gifts and entertainment
We will not engage in any form of corruption and we have a duty to inform our clients if we encounter actual or suspected corruption in their organisations. Members of the firm and anyone acting on our behalf must not offer gifts or favours in order to obtain advantages in any form for themselves, their colleagues or any third party. Nor may we accept gifts that are intended to influence us, and we do not give preferential treatment in hiring based on merit. We must avoid both the reality and perception of undue influence and must therefore also avoid entertainment that may be perceived as inappropriate or excessive.
High-risk customer service situations
The firm has identified a number of client service situations that require colleagues to comply with specific additional risk management requirements for clients, our firm and our employees. These include analytics, mergers and acquisitions, government, public or government-related sectors, pharmaceutical and medical device compliance, buyer-supplier interactions, restructuring and bankruptcy, compensation, software provision and support, work requiring interaction with regulators, and work conducted in partnership with third parties. Approval by the Customer Service Risk Committee The Customer Service Risk Committee (CSRC) is required before undertaking work in these areas, and colleagues carrying out work must be familiar with the specific policies covering these areas, undergo all necessary training, and comply with requirements to engage appropriate experienced professionals to oversee the work.
Social media and the press
All colleagues should present themselves professionally on social media. Even when using personal social media accounts, we expect colleagues to be mindful of the perception that may be created. Regardless of whether a colleague is speaking on behalf of the firm or simply using social media for personal purposes. We expect colleagues to respect both client and firm confidentiality and to protect the firm’s reputation. Colleagues must not express their personal political views in a way that could jeopardise the firm’s reputation for political neutrality. All external publications and communications with the press require approval from the firm’s external communications department, and colleagues must receive media training before any interview with journalists or bloggers.
Data security and protection
All colleagues are required to protect the firm’s data and information environment from unauthorised access. All digital implementations of the firm, including applications, platforms, technology and third-party products, must comply with approved standards to ensure that sensitive information is protected by robust controls. Any exceptions must be approved by the Cyber Risk Team and colleagues who are unsure about the security of the system or technology should seek assistance via email.
Resources and assets of MARRBERY
We expect colleagues to be thoughtful about how they use the firm’s resources and protect the firm’s information and assets. Marrbery assets, including proprietary information, software, frameworks, tools and methodologies, should only be used in accordance with firm policies and for firm-related activities. Colleagues may not use Marrbery resources, such as email lists, for political purposes, to solicit investments or for other personal interests. We expect all colleagues to be careful with the firm’s finances, to comply fully and consistently with our spending policies and to reflect on how their use of resources will be perceived by the outside world and colleagues.
We maintain accurate records for the required period of time so that we can comply with all relevant laws and regulations. Our policy categorically prohibits keeping firm or client records outside the firm’s system, or destroying, falsifying or altering records that must be kept (for example, in the context of an investigation). Colleagues are expected to file all necessary firm documents, such as expense reports and timesheets, accurately and in a timely manner.
Working with third parties
We collaborate with other firms and engage individuals, including senior advisors, from outside the firm to bring the best out of our clients and the firm. These relationships are increasingly important drivers of our impact and innovation. At the same time, working with other organizations and individuals creates potential financial, legal and reputational risks. Such situations therefore require additional syndication and expert advice. It is the responsibility of all colleagues to ensure that any third party collaborating with or providing services to the firm has been appropriately vetted and must comply with our policies on consulting intermediaries, external consulting intermediaries, external employees and partnership policies.
5. Seeking advice and expressing concern
Not every situation can be clearly reflected in a policy or code of conduct, and colleagues should always seek advice when faced with a difficult situation, or when they are unsure of the right thing to do. If a colleague notices something that they think might be contrary to our values, policies or this Code, might put the firm or an individual employee at risk or might be against the law, they have a duty to speak up. Colleagues in any senior position, such as partners or supervisors, have an additional obligation to report anything that may violate our policy to ensure an environment free of harassment or discrimination. The firm will not tolerate retaliation against a colleague who, in good faith, expresses concern about any aspect of professional conduct or who fulfils his or her obligation to participate honestly in an internal or external investigation. Retaliation in any form is a breach of policy and may lead to disciplinary action, including dismissal. The following resources are available to all colleagues to seek advice, ask questions or raise concerns.
Advice from colleagues
We strive to make colleagues feel comfortable to seek advice or raise concerns directly with a colleague at a colleague’s firm. Examples of colleagues who may be able to help solve your problem include:
– The ED or another leader of your account team
– Your DGL, office managing partner, cell manager, supervisor or department manager
– Your regional human resources manager, HR or HR
– Your firm’s Director of Risk, Director of Human Resources, General Counsel or Human Resources Manager
– Any member of the firm’s legal department
– In cases of concerns about partner or senior partner conduct: Chair of the Professional Standards Committee, Head of Human Resources or HR Director
– On concerns relating to client service: Any member of the Client Service Risk Committee (CSRC) or our Chief Risk Officer
We accept that there are times when colleagues may feel the need to be able to raise a question or ask a question without directly contacting a colleague. For such cases, we have created hot chat rooms as an alternative way that colleagues can use. You can raise a question or concern via an internal link, which is hosted by an external service provider to keep information confidential. The provider, the software, ensures the confidentiality of information to the extent permitted by law.
The firm’s Ombudsman is available to all firm members to provide informal, confidential advice and support. Our Ombudsmen will not tell you what to do, act on or (unless they believe there is an immediate security risk) pass on information about your situation to others within or outside the firm. Because of this, the Ombudsman cannot take action to resolve any issues or questions or concerns you may have. If you are aware of a potential breach of our values, professional standards, policies, or the law, please report it in one of the ways listed above so that the firm can consider it and take appropriate action.
Our Code of Professional Conduct emphases that each of us has a duty to maintain the highest professional standards in customer service; to create an environment in which our employees are respected, inspired and motivated; to consider the wider impact of our actions on society; and to maintain the reputation of the firm. Each of us is responsible for applying the standards set out in this code and for taking responsibility for speaking up and raising any concerns or questions about possible violations of this code, our values, our policies or the law. Adhering to this code will enable us to truly live up to our values, fulfill our dual mission of serving our customers and people, and continue to earn the trust of our customers and the communities in which we live and work. Our collective ambition to make a positive impact in the world depends on that trust, and therefore on our adherence to the standards of conduct set out in this Code of Professional Conduct. This Code of Professional Conduct is intended as a living document. The Risk, Audit & Governance, Audit & Governance Committee of the Shareholders’ Board is responsible for periodically clarifying and updating the content of this Code. To provide input or suggestions for improving this Code of Professional Conduct, please refer to the firm’s intranet.
Date of initial acceptance: 15 October 2019
Date of last revision/update: 1 December 2022
The requirements set out here are based on the values of MARRBERY and the following documents: