The company will not tolerate corruption, bribery and unfair, anticompetitive activity, and insists on integrity in all aspects of its business and from all those it does business with.

Acclaro Advisory recognises the threat that bribery and corruption pose to economic progress and development in the countries in which it operates, and is committed to complying with the requirements of the relevant laws of those countries, as well as relevant cross-boundary legislation.

As individuals, collectively and as a company we will:

  • Apply the principles set out in the Ethics and Business Integrity Policy in everything we do.
  • Comply with applicable laws, rules and regulations as a minimum. Where the standards of behaviour expected by Acclaro Advisory are higher we will apply these higher standards.
  • Seek guidance where we are unsure of the appropriate course of action.
Clients and Business Partners

Acclaro Advisory will work for clients and with business partners that comply with internationally acceptable ethical standards, and where its commissions are consistent with generally accepted ethical standards. Acclaro Advisory will not undertake or support any form of commission known to be breaching, as a policy or strategy, the generally accepted ethical standards of its home country or the country in which it is operating.


Acclaro Advisory will conduct relationships with clients and business partners in the spirit of transparency, openness and trust, albeit with due regard to considerations of commercial or personal confidentiality. Acclaro Advisory does not permit the establishment or maintenance of any undisclosed or unrecorded account, fund or asset, and insists that proper and full records must be made of all transactions on behalf of the company.


Acclaro Advisory employees shall act in an ethical, honest and professional way in all of their business dealings, and may not offer, give or receive any gift or payment which is, or may be construed as, a bribe. Any demand for, or offer of, a bribe or inducement to act in any way contrary to our principles must be rejected immediately.

Corporate Gifts and Hospitality

Whilst recognising that corporate hospitality is frequently given and received as part of the development of legitimate and mutually beneficial relationships, Acclaro Advisory will not condone the giving or receiving of gifts, hospitality or favours that could be interpreted as an attempt at bribery. Acclaro Advisory employees shall avoid accepting gifts, hospitality or favours which might appear to place them under any obligation.

Conflict of Interest

Acclaro Advisory employees are required to avoid any contact that might lead to, or suggest, a conflict of interest between their personal activities and the business of Acclaro Advisory or its clients. All employees are required to disclose family links or other close relationships with a relevant decision-maker in a client, supplier or competitor organisation; financial interests in a client, supplier or competitor organisation; and activities on behalf of a client or another in such a way that the trust vested in Acclaro Advisory by a third party (client or other business partner) may be abused.


Acclaro Advisory requires all employees to report promptly to the company any violations of law or company policies that come to their attention and to co-operate fully in any audit, enquiry, review or investigation by the company. Acclaro Advisory will maintain secure reporting systems to enable such reports to be made in confidence.

Employee Awareness

Acclaro Advisory will ensure that its employees are aware of the company’s business principles and this business integrity policy. Employees will receive guidance and supervision on ethical behaviour and legal compliance relevant to their role, and their knowledge and understanding will be regularly assessed. Ultimately, if employees fail to comply with this policy, they are liable to disciplinary action, up to, and including, dismissal.

This Ethics and Business Integrity Policy seeks to provide the primary guidance you should follow. This should help you consider if your course of action is appropriate or if you need to seek further advice and guidance.

Sunil Shah
Managing Director, Acclaro Advisory
May 2020