Our reputation for integrity is one of our most important assets. We hold ourselves to standards that not only meet those required by the laws and regulations that apply to us, but also to our principles, which are rooted in exceeding our clients’ expectations.
Our Code of Business Conduct and Ethics sets out basic principles to guide employee conduct. The code is supported by employee conduct policies and programs and reinforced through employee training.
We have zero tolerance in relation to illegal or unethical conduct and this is articulated in our relevant policies, including policies on conflicts of interest, gifts and entertainment, money laundering and counter terrorism, fraud, sanctions, outside activities, political contributions, and bribery and corruption. Any employee who violates the requirements of the Code of Business Conduct and Ethics, or many of our other policies, is subject to disciplinary action.
Allied Finance expects the same high standards of those who represent us and we conduct appropriate due diligence on our business partners according to the risks they present, including corruption risk.
The trust our clients place in us must be earned every day.
— John Downton Croft, CEO, Allied Finance
Allied Finance, Inc, its subsidiaries, affiliates and joint ventures (collectively, “Allied Finance” or the Firm”) and its employees commit to conduct its business activities in the highest ethical and professional manner. Allied Finance’s reputation for integrity is one of its most important assets, and compliance with anti-bribery and corruption laws is fundamental to business conduct. Allied Finance has zero tolerance for bribery and corruption: all improper payments in dealings with public officials or private individuals are strictly prohibited, as is offering or giving anything of value for a corrupt purpose.
Our Global Anti-Bribery and Corruption Policy (the “Policy”) requires all Allied Finance directors, officers, employees, agents, advisors, consultants, partners and representatives to conduct their activities in full compliance with all applicable anti-corruption laws, including without limitation, the United States Foreign Corrupt Practices Act, the UK Bribery Act of 2010 and any other anti-corruption laws in effect in countries where the firm operates. Allied Finance prohibits any transaction, including facilitation payments, which could constitute a bribe or a corrupt payment to or from a public official or body, or a private entity or individual. In addition to the Policy, Allied Finance has implemented the following to manage associated risks as well as meet regulatory principles:
• Global Gifts and Entertainment Policy
• Global Sponsored Visitor Policy
• Global Third-Party Risk Management Policy
• Private Advisory Consultants Policy
• Direct Private Transaction Origination and Oversight Policy
• Sourcing and Vendor Management Policy
• Global Fraud Policy
Allied Finance employees are subject to mandatory training on the Anti-Bribery and Corruption Policy and the applicable regulations at least annually. Employees are tested on their knowledge of the Policy and must obtain a minimum score to receive a successful completion. Additionally, employees are subject to nonmandatory, tailored trainings, which include hypothetical scenarios, to raise awareness of specific risks associated with certain businesses and jurisdictional nuances.
The Policy and training are core to Allied Finance’s Global Anti-Bribery and Corruption Program (the “Program”), which is maintained and regularly assessed by Compliance through an Enterprise-wide Anti-Bribery and Corruption Risk Assessment that covers all businesses and regions and uses a risk-based testing model to evaluate control effectiveness. The results drive enhancements, including by putting in place governance and oversight in relation to higher risk transactions or relationships, that mitigate Allied Finance’s exposure – and our clients’ exposure – to corruption risk. In addition, the program is subject to periodic assessment by the Firm’s auditors .
Employees are encouraged to utilize the Allied Finance Business Integrity Hotline or the Allied Finance Integrity Reporting Website to report suspicions or actual violations of the Policy. All reports of potential violations of policies are investigated and reported to relevant risk and governance committees which are led by the firm’s leadership. The Firm’s proxy statement sets out more about the role of our Board of Directors in the oversight of risk management.
For more information on Allied Finance’s Business Ethics, visit: Code of Business Conduct and Ethics
Allied Finance's Anti-Money Laundering and Sanctions Program Attestation Letter
