Stratagem Code of Ethics, Anti-Corruption and Ethical Business Conduct Policy
(Applicable to Stratagem, Stratagem Hub Limited, affiliates, employees, consultants, contractors, and representatives)
Stratagem is committed to conducting business with integrity, professionalism, and respect for the law. This Policy sets out the minimum standards of ethical conduct applicable to all Stratagem activities, including public policy advisory, government relations, public affairs, strategic communications, and related services. Compliance with this Policy is a condition of engagement with Stratagem.
1. Compliance with Applicable Laws
Stratagem conducts its business in compliance with all applicable laws and regulations in the jurisdictions in which it operates, including those relating to anti-bribery and anti-corruption, lobbying and disclosure requirements (where applicable), competition, sanctions, data protection, and employment.
2. Anti-Bribery and Anti-Corruption
Stratagem maintains zero tolerance for bribery, corruption, kickbacks, facilitation payments, or any improper inducement. No person acting on behalf of Stratagem may directly or indirectly offer, promise, authorize, give, request, or accept anything of value to obtain or retain business, secure an improper advantage, or influence any decision improperly.
3. Gifts, Hospitality and Business Courtesies
Gifts, hospitality, travel, entertainment, and other business courtesies must be lawful, reasonable, infrequent, and proportionate to a legitimate business purpose. They must not create, or appear to create, improper influence. Cash gifts and cash equivalents are prohibited.
4. Conflicts of Interest
Stratagem seeks to identify, avoid, disclose, and appropriately manage actual, potential, or perceived conflicts of interest. Engagements that compromise independence, objectivity, confidentiality, or duty to a client will not be accepted or continued unless appropriately disclosed and managed in line with legal and professional obligations.
5. Truthful and Responsible Representation
Stratagem is committed to honest, accurate, and responsible communications. We do not knowingly make false, misleading, deceptive, or unsubstantiated statements to clients, public officials, regulators, media, counterparties, or the public.
6. Confidentiality and Information Protection
Stratagem protects confidential, proprietary, and non-public information received from clients and stakeholders and uses such information only for legitimate professional purposes. Appropriate administrative and operational safeguards shall be maintained to protect information and records.
7. Fair Dealing, Respect and Non-Discrimination
Stratagem is committed to a professional environment and business conduct grounded in fairness, dignity, and respect. Harassment, discrimination, intimidation, retaliation, and abusive conduct are not tolerated in any dealings involving Stratagem personnel or representatives.
8. Third-Party Conduct
Stratagem expects subcontractors, consultants, and partner firms engaged on its behalf to uphold standards consistent with this Policy. Stratagem reserves the right to decline, suspend, or terminate relationships that present material legal, ethical, compliance, or reputational risk.
9. Accurate Books, Records and Documentation
Stratagem maintains accurate and complete records of transactions, invoices, expenses, and supporting documentation. No false, misleading, incomplete, or artificial entries may be created for any purpose, including concealment of improper payments or activities.
10. Reporting, Escalation and Non-Retaliation
Personnel and representatives are expected to report suspected misconduct, legal violations, or breaches of this Policy to Stratagem leadership promptly. Reports made in good faith will be reviewed seriously and handled without retaliation.
11. Enforcement
Violations of this Policy may result in disciplinary action, suspension or termination of employment or engagement, contract termination, and referral to relevant authorities where required by law or appropriate under the circumstances.
Stratagem is committed to ethical, lawful, and responsible advisory practice in the interests of client trust, institutional integrity, and public confidence.