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Business Ethics: operating to the highest ethical standards

We expect the same high ethical standards across all our portfolio companies which we apply to ourselves and we actively work with our management teams to achieve this. At all times we expect honest and transparent trading. We expect portfolio companies to:

  • Maintain high standards of business integrity at all times;
  • Have a clear anti-corruption and anti-bribery policy, supported by appropriate levels of compliance monitoring; and
  • Understand the key risks associated with suppliers’ labour practices (i.e. the use of child labour, working conditions, wages and discrimination) and environmental impacts throughout the supply chain.

The vast majority of our current portfolio is in professional business services and financial services companies, all UK headquartered.  However, Dunedin promotes strong ESG procedures across all portfolio companies, irrespective of sector or geography, extending to supply chains.  This is something that must be looked at ahead of any new investment and then monitored actively throughout the life of our investment.

Ethical procedures and policies are 100% across our portfolio:

100% Anti-money laundering
100% Anti-bribery & corruption
100% Anti-forced labour

Source: Dunedin ESG audits, 2019

Hawksford – taking a clear ethical stance

Hawksford works with an international list of clients, providing corporate, private client and funds services in areas such as regulatory affairs, financial and tax compliance, and corporate governance. It believes that with an ever-changing environment it is imperative that they have a clear ethical stance which can be followed by all staff. Not only does Hawksford hold to high ethical standards as ‘it is the right thing to do’, but it also realises that ethics is a key driver for clients looking for a service provider and is therefore important to be considered in all aspects of the financial services they provide, whether it be demonstrated through their professionalism, loyalty, integrity, reliability or responsibility.

Hawksford is aware that just because an action is legal does not mean that the action should ethically be taken. They therefore consider the implications of taking action (or not as the case may be) based on ethical considerations.

Hawksford takes its ethical responsibilities very seriously and has various policies and procedures within its systems and controls environment to safeguard against any wrongdoing, including but not limited to, breaches of sanctions, tax evasion, bribery, corruption, conflicts of interest, money laundering or terrorist financing, fraud and connections to any form of criminality to name but a few. A clear designated whitelist of services to be conducted by Hawksford has been established and is regularly reviewed in order to meet with current practice and industry changes. Part of this list is a clear, automatic, rejection criteria for connections to various unethical behaviours to which they do not want to be associated. These ethical criteria are further included through their Client Risk Scorecard which is applied when considering onboarding and providing ongoing services to each client structure. Hawksford encourages its staff to report any wrongdoing whether through its Suspicious Activity Reporting Procedure, its Whistleblowing Policy and Procedure and its Complaints and Breaches Policy and Procedure. Additionally, transparency of services conducted and fees charged is imperative in providing a long lasting effective and trustworthy relationship with their clients.

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