Introduction
Ethics are the foundation of Finnerve’s reputation and of the trust placed in us by clients, colleagues, partners and authorities. This Code of Ethics and Conduct is not a statement of intent: it is a practical guide to how we work and how we make decisions when the right answer is not obvious.
Finnerve Ltd is a company incorporated in England & Wales that operates directly or through its subsidiaries in the UK, Spain, Peru, Chile, Mexico, Colombia and Panama. We work to a single standard of conduct: in every situation we apply the strictest of the UK, EU and local frameworks. We do not allow the level of rigour to depend on the country in which we operate.
Our values
- Integrity first. We do the right thing even when no one is watching, and even when it means walking away from an opportunity.
- The client at the centre. We serve the client’s real interest, not only the letter of the contract.
- Excellence without compromise. The quality of our work protects the reputation of those who rely on us.
- Innovation with purpose. We adopt technology to solve real problems, not to follow trends.
- Collaboration and respect. We build diverse and inclusive teams in which every person is treated with dignity.
- Long-term vision. We prefer a lasting relationship to an immediate gain.
- Reputation as an essential asset. Every decision is made in the knowledge that reputation takes years to build and moments to lose.
Guiding principles
Everyone connected to Finnerve commits to:
- Strict compliance with applicable law, including the UK Bribery Act 2010, the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023), the Competition Act 1998 and articles 101 and 102 TFEU, the UK GDPR, the Data Protection Act 2018 and Regulation (EU) 2016/679, the Money Laundering Regulations 2017 (MLR 2017) and the Proceeds of Crime Act 2002 (POCA 2002).
- Maintaining zero tolerance for corruption, in any form, in both the private and the public sector.
- Preserving the absolute confidentiality of information belonging to clients, colleagues and third parties.
- Competing fairly and honestly, without agreements or practices that restrict competition.
- Managing conflicts of interest responsibly, always placing the interest of the company and its clients first.
- Respecting human and labour rights, in line with the Modern Slavery Act 2015 and the UN Guiding Principles on Business and Human Rights.
Scope
This Code binds all directors, partners, employees, consultants and contractors of Finnerve, as well as any third party acting in the name or on behalf of the company. Its principles also extend to our suppliers and partners, from whom we require consistency with these standards as a condition of the relationship.
Our relationships
With our clients
Trust is the basis of everything we do. When we provide services to regulated entities, we become part of their compliance perimeter: any failure on our part can directly affect their regulatory standing. We therefore act with the same diligence we would demand of our own business and protect their information as if it were our own.
With suppliers and partners
We select our suppliers and partners using objective criteria of quality, soundness and conduct, never on the basis of favours or improper relationships. We firmly reject any link to forced or child labour, in accordance with the Modern Slavery Act 2015, and we expect the same commitment throughout our supply chain.
With our teams
We guarantee a working environment free from discrimination and harassment, in accordance with the Equality Act 2010. No decision affecting people is based on gender, age, origin, orientation, religion, disability or any other protected characteristic. We protect the health and safety of our teams under the Health and Safety at Work etc. Act 1974 and prevent harassment —including harassment by third parties— in accordance with the Worker Protection Act 2023.
With the authorities
We maintain a documented and transparent relationship with public bodies and regulators, including Companies House, HMRC, the FCA and the ICO. We provide the information legitimately requested of us and never offer payments, gifts or advantages to influence a decision or expedite a procedure.
Use of assets and technology
Corporate assets —equipment, systems, software, information and brand— are for professional and responsible use. We protect information and systems with cybersecurity measures aligned with ISO/IEC 27001:2022 and with NCSC guidance. The specific rules on use, access and protection are set out in the Information Security Policy.
Confidentiality and data protection
We process personal data in accordance with the principles of the GDPR: lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; integrity and confidentiality; and accountability. We apply the UK GDPR and the Data Protection Act 2018 and, where relevant, Regulation (EU) 2016/679. Any data protection query can be directed to dpo@finnerve.com.
Gifts, hospitality and entertainment
Accepting or offering gifts or hospitality can compromise our objectivity. Accordingly:
- Only gifts and hospitality of symbolic value, offered transparently and within reasonable business practice, are permitted.
- It is absolutely prohibited to offer or accept gifts, payments or advantages in connection with public officials.
- Any gift or hospitality that could be perceived as an attempt at undue influence must be refused and reported.
The specific thresholds, required authorisations and corresponding register are governed by the Anti-Bribery Manual.
Financial information and transparency
We keep faithful, complete and verifiable accounting records, in accordance with the Companies Act 2006. No transaction is recorded inaccurately, and no parallel accounts or funds are maintained. Accounting transparency is a non-negotiable condition of our activity.
Conflicts of interest
A conflict of interest arises when a personal, family or financial interest may influence —or appear to influence— a professional decision. Common examples include: taking part in engaging a company connected to a relative, holding interests in a competitor or client, or accepting an outside activity that competes with Finnerve.
Directors are additionally subject to the duties under sections 175 to 177 of the Companies Act 2006 (the duty to avoid conflicts of interest, not to accept benefits from third parties, and to declare any interest in transactions). Any conflict, actual or potential, must be declared in writing and recorded in the conflicts register, so that the company can take appropriate measures.
Press and communications
Only authorised spokespeople may speak on behalf of Finnerve to the media, on social networks or in public forums. Any external request for information must be channelled through the designated teams.
Whistleblowing
We operate a confidential channel for reporting, in good faith, any conduct contrary to this Code, to the law or to our policies: speakup@finnerve.com. Reports may be made anonymously and are protected against any retaliation under the Public Interest Disclosure Act 1998 (PIDA) and Directive (EU) 2019/1937.
We will acknowledge receipt of a report within 7 days and report the outcome within a maximum of 3 months. Nothing in this Code limits any person’s right to make a protected disclosure to a competent authority (a prescribed person) where the law so provides.
Breaches and sanctions
Breach of this Code may lead to disciplinary measures, up to and including termination of the employment or contractual relationship, without prejudice to any legal action —civil or criminal— that may be appropriate.
Final commitment
Everyone connected to Finnerve has a duty to know and apply this Code. We expect all to act with integrity, to consult when in doubt before deciding, and to report in good faith any situation that could compromise our values. The consistency between what we say and what we do is what sustains trust in Finnerve.