Corporate Governance
Ethics and integrity
Setting high standardsOur 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.
Business conduct and ethicsOur 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.
Artha FCL 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.” is our first motto.
Artha FCL’s Guidelines for Anti-bribery and Corruption Compliance
Artha FCL employees commit to conduct its business activities in the highest ethical and professional manner. Artha FCL’s reputation for integrity is one of its most important assets, and compliance with anti-bribery and corruption laws is fundamental to business conduct. Artha FCL 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 Artha FCL 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. Artha FCL 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, Artha FCL 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
Artha FCL 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 Artha FCL’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 Artha FCL’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 Artha FCL Business Integrity Hotline or the Artha FCL 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.
Health and safety
Our commitment
Artha FCL is committed to providing a safe and healthy working environment for all employees. To do this, all global programs are designed with the most stringent regulations in mind to meet or exceed all local requirements. We also focus on the design and operations of our facilities to deliver a safe and comfortable space for our employees and visitors. We integrate environmental and occupational health and safety compliance throughout the firm to ensure we are operating at the highest standard.
Our approachArtha FCL utilizes a Safety Management System, in line with OHSAS 18001, to manage health and safety risks throughout the firm. Through this, we have established an Environmental and Occupational Health and Safety Policy that extends beyond our employees to protect clients, contractors and visitors to our offices and events. This design enables us to proactively manage all processes with Health and Safety implications, while centrally managing core programs to deliver state of the art health and safety programs. Artha FCL provides all employees with Health & Safety workplace training programs to cover both general and function specific Health and Safety knowledge.
Our programsOur health and safety programs are developed and managed by our Global Health & Safety Team and delivered in partnership with Human Resources, Enterprise Security, Enterprise Resilience and Corporate Real Estate Teams. We employ a multi-faceted strategy to manage and reduce risk through in depth regulatory oversight and global programs that include:
- AED (Automated External Defibrillator) Program
- Emergency Preparedness Program
- Emerging Health Concerns and Pandemic Program
- Ergonomics Program
- Workplace Injury and Illness Prevention Program
- Event Safety Program
- Travel Safety Program