Code of Conduct
The standards we hold ourselves to, including anti-bribery, conflicts of interest and speaking up.
版本 1.0 · 最後更新於 2026年8月16日
Why this exists
Clients engage HainanInc because getting something wrong in a regulated environment is expensive. That makes our own conduct part of what we are selling: a compliance adviser whose standards are negotiable is not worth engaging.
This code applies to everyone who works for or on behalf of HainanInc Advisory Group, including employees, contractors and subcontractors. It is not a statement of aspiration. Departing from it is a disciplinary matter and, for a subcontractor, grounds for terminating the relationship.
Acting with integrity
We do what we say we will do, we say what we can and cannot do, and we do not overstate our position.
- We describe our capabilities accurately, including where a matter falls outside them
- We do not claim a licence, registration or authorisation we do not hold
- We give clients our honest assessment, including when it is not what they want to hear
- We tell a client promptly when something has gone wrong, including when the fault is ours
- We do not promise an outcome that depends on a decision we do not control
Anti-bribery and anti-corruption
We prohibit bribery and corruption without exception. No one acting for us may offer, give, request or accept anything of value to improperly influence a decision, secure an advantage, or reward either.
This applies whether the counterparty is a public official or in the private sector, whether the benefit flows to the individual or to someone connected to them, and whether it is given directly or through an intermediary. Engaging a third party to do what we may not do ourselves is a breach by us.
Facilitation payments
We do not make facilitation payments — small unofficial payments to speed up a routine action someone is already obliged to perform. This holds even where such payments are locally customary and even where refusing means a process takes longer. If a payment of this kind is solicited, the answer is no and the request is escalated.
Where a personal safety risk makes refusal unsafe, safety comes first; the payment is reported immediately afterwards and recorded accurately.
Gifts and hospitality
Modest, occasional hospitality in the ordinary course of business is acceptable. Anything that could reasonably be seen as intended to influence a decision is not.
- Never offer or accept cash or a cash equivalent
- Never offer or accept anything while a decision affecting the giver is pending
- Anything beyond modest value requires approval before it is offered or accepted
- Everything offered or accepted is recorded
Why this matters for our clients
Many of our clients are subject to anti-bribery law that reaches beyond the country they operate in, and that can make them answerable for the conduct of a service provider acting on their behalf. Our standard here is therefore not only ours — it is part of what protects them.
Conflicts of interest
A conflict is not itself misconduct; concealing one is. Anyone who becomes aware of an actual or potential conflict must disclose it before continuing with the work.
We check for conflicts before accepting an engagement. Where one exists between clients, we will decline the work, or proceed only with the informed written consent of both and with appropriate separation of the teams involved. Where a personal interest could reasonably be seen to affect someone's judgement, they step back from that decision.
We do not accept a commission or referral fee from a third party in connection with a client engagement without disclosing it to the client.
Anti-money-laundering and sanctions
We carry out client due diligence before accepting an engagement and keep it current, as set out in our AML and KYC Policy.
We screen clients and connected parties against applicable sanctions lists, and we do not act where doing so would breach a sanctions or export control regime that applies to us or to the engagement. Where a concern arises mid-engagement, work stops while it is resolved.
Confidentiality and handling information
Client information is confidential, including the fact that a party is a client at all. We do not discuss client matters outside the team delivering them, and we do not use client information for any purpose other than the engagement.
We do not trade, or enable anyone else to trade, on information obtained through our work that is not public.
Our people
We recruit and promote on merit. We do not tolerate discrimination, harassment or bullying, and we expect the same standard from clients and counterparties in their dealings with our people.
We comply with the employment law of the jurisdictions we operate in, and we hold the same standard for working conditions across our own operations that we advise clients to meet in theirs.
Speaking up
Anyone who suspects a breach of this code should raise it. Raising a concern honestly is protected: we do not retaliate against someone who reports in good faith, and we treat retaliation as a separate breach in its own right. This protection applies even where the concern turns out to be mistaken.
Concerns may be raised with your usual contact, or in confidence to enquiries@hainaninc.com marked for the attention of the partners. Where a concern involves the person you would normally report to, use the second route.
Clients and third parties who wish to raise a concern about our conduct may use the same address, or the process in our Client Service and Complaints policy.
