Code of conduct

We comply with the law of every jurisdiction in which we work. Where this code is stricter than the law, the code applies; where the law is stricter, the law applies and we keep to the spirit of the code.

The managing director is responsible for this code and answers questions about it. The code is reviewed every twelve months, with input from our external accountant, and within three months of any change in law or regulation that affects it. Our people are briefed on this code, confidentiality and information security before their first engagement and confirm in writing, on joining and every twelve months thereafter, that they have read it and will follow it.

We give clients our honest judgment, including when it is unwelcome, and we decline work we cannot stand behind.

We do not mislead. We do not make, and do not help clients make, statements to investors, media, regulators or the public that we know or should know are false or misleading. When we approach journalists, analysts or other stakeholders on a client’s behalf, we say whom we act for. Writing in a client’s name with the client’s authority is legitimate; presenting a client’s interest as independent opinion, through invented voices or undisclosed paid endorsement, is not, and we do not do it.

We use AI tools under our confidentiality and information-security statement. We check what they produce before it carries our name and do not present machine output as verified analysis.

We respect intellectual property. Confidentiality and data protection are governed by our general terms and conditions and our confidentiality and information-security statement.

Before accepting an engagement we check whether we, or anyone working on it, have an interest in or a relationship with the client, its counterparties, its competitors or the matter that could influence, or appear to influence, our judgment. This includes prior or concurrent work for a counterparty and any financial interest in the client or its counterparties.

We disclose any such conflict to the client in writing before we start and act only with the client’s informed agreement. Where a conflict cannot be managed by disclosure and the client’s agreement, we decline. We record each check and its outcome.

Our people tell the managing director at once of any personal interest that could affect their work for a client. We tell a client promptly if we learn that one of its staff has an undisclosed interest in Special Projects.

We do not offer, give, ask for or accept anything of value to obtain or reward an improper advantage, directly or through anyone else. This includes facilitation payments, which we do not make even where local practice tolerates them. Anyone who is offered or asked for an improper advantage reports it to the managing director at once, and we inform the client concerned.

Gifts and hospitality are permitted only if they are modest, infrequent, openly given, connected to the business relationship and never in cash. Anything above CHF 150 per person and occasion requires the managing director’s prior written approval and is entered in our gift register. We give nothing of value to public officials, or to a client’s staff in connection with an engagement, without the client’s prior written consent, and nothing to anyone deciding on a tender or a contract award.

We make no political contributions in the firm’s name or on a client’s behalf, and no charitable contributions as a means to obtain business.

We prevent fraud and keep accurate books. Payments and expenses are documented; our accounts are kept and reviewed by an external accountant and retained for ten years as Swiss law requires. We pay our taxes, do not facilitate tax evasion by anyone and invoice only the contracting entity.

We compete fairly. We do not exchange prices, pitches or client information with competitors and take no part in bid-rigging or market-sharing.

We know who our clients are. We accept no cash, no payments from or to undisclosed third parties and no payment structures we cannot explain. We are not a financial intermediary and do not structure or execute financial transactions; an engagement that would require this is declined, and the client is pointed to a licensed provider.

Before we start, and when an engagement is renewed or materially extended, we check the client and any business partner on it against the sanctions lists of Switzerland, the EU, the United Kingdom and the United States, and record the check. We do not work for or with listed persons or entities, and we do not provide advisory, communications or research services to persons or entities in Russia or in any other jurisdiction where Swiss or EU sanctions prohibit it.

Our people who receive inside information about a listed company do not trade in its securities, recommend or encourage trades, or pass the information on beyond what the engagement requires, until it has been made public. We keep the records a client or the law requires.

We respect internationally recognised human rights, including the International Bill of Human Rights and the ILO fundamental conventions, and act in line with the UN Guiding Principles on Business and Human Rights in a way proportionate to our size. This section is our human rights and modern slavery statement.

Everyone who works for us, employed or freelance, does so under a written contract at fair market terms. Employees’ hours, leave, pay and insurance follow Swiss law; freelancers are independent contractors who set their own hours and carry their own insurance. Everyone is free to join an association and to bargain collectively. We use no forced, bonded or child labour, employ no one under 15, retain no identity documents and charge no recruitment fees, and we do not knowingly work with anyone who does.

We treat people equally. We do not tolerate discrimination, harassment or bullying on any ground, including gender, ethnicity, religion, age, nationality, sexual orientation, disability, union membership or political opinion, in our firm or in our work with clients and stakeholders.

We provide a safe and healthy working environment, including for remote and travelling work, and respect our people’s time outside work.

Our direct exposure to human rights and labour risk is limited to our own people; our indirect exposure runs through software providers and client-side work. We keep a list of our suppliers, review it every twelve months and favour providers that publish their own standards.

Our material environmental impact is business travel and office energy. We travel only where it serves the engagement, take the train for journeys of up to six hours and prefer providers that run on renewable electricity.

Our target is that every intra-European journey of up to six hours by rail is made by rail. We estimate our travel emissions each year, provide the figure on request and reduce waste and resource use. We review these risks and targets together with this code.

We claim no environmental result we cannot evidence.

This code forms part of our contracts with freelancers and business partners, who confirm it before they work with us. We expect them to apply equivalent standards in their own supply chains.

We select providers for quality, security and conduct, and check them against sanctions lists and public sources before we engage them.

Anyone, inside or outside the firm, can raise a concern about a breach of this code or of the law with the managing director by any means, or anonymously by post to our registered address. A concern about the managing director may be raised with our external accountant or with the competent authority. We keep the reporter’s identity confidential as far as the law allows.

We acknowledge a report within seven days and, where we can reach the reporter, tell them the outcome in writing within thirty days of the acknowledgement or explain why more time is needed.

We do not tolerate retaliation against anyone who raises a concern in good faith or takes part in an inquiry. Our employment and freelance contracts include this protection. Breaches of this code lead to consequences up to termination of employment, contract or engagement.

We answer clients’ due-diligence questionnaires, provide this code and the evidence behind it, and allow review of relevant records on ten business days’ notice.

We tell an affected client in writing, within five business days of becoming aware of it, of any material breach of this code on its engagement, and we correct it.

We sign clients’ supplier codes and note any deviation to the client in writing before signing. Signatory: Simon Strand, managing director.