Third-Party Code of Conduct

1. Introduction

Parker Russell (“the Firm”) is committed to conducting business ethically, responsibly, and in compliance with all applicable legal and regulatory requirements.

The Firm expects all suppliers, contractors, consultants, agents, intermediaries, introducers, professional advisers, outsourced service providers, and other third parties (“Third Parties”) acting on its behalf or providing services to adhere to the standards set out in this Code.

This Code forms part of the Firm’s wider governance, compliance, environmental, social and governance (ESG), and risk management framework and should be read alongside applicable contractual obligations.

The Firm reserves the right to review, monitor, and assess compliance with this Code throughout the duration of any business relationship.

2. Purpose

The purpose of this Code is to:

• Promote ethical business conduct.
• Protect the Firm’s reputation and integrity.
• Support compliance with applicable laws and regulations.
• Promote responsible business practices throughout the supply chain.
• Reduce legal, financial, operational, and reputational risks.
• Support the Firm’s ESG objectives and sustainability commitments.

3. Scope

This Code applies to:

• Suppliers and vendors.
• Contractors and subcontractors.
• Consultants and advisers.
• Agents and intermediaries.
• Recruitment agencies.
• Outsourced service providers.
• Technology providers.
• Joint venture partners and strategic partners where appropriate.

Third Parties are expected to communicate these standards to their employees, subcontractors, and supply chains where relevant.

4. Legal and Regulatory Compliance

Third Parties must:

• Comply with all applicable laws and regulations.
• Maintain all required licences, permits, authorisations, and registrations.
• Operate in a lawful and ethical manner.
• Cooperate with lawful regulatory enquiries and compliance reviews.
• Notify the Firm of any material regulatory investigations, sanctions, or legal proceedings that may affect the business relationship.

Compliance must include applicable UK legislation and any local laws relevant to the services provided.

5. Business Ethics and Integrity

Third Parties shall conduct business honestly, fairly, and transparently.

Third Parties must not:

• Engage in fraudulent activities.
• Misrepresent information.
• Falsify records.
• Conceal material facts.
• Participate in unethical business practices.

All business transactions must be accurately recorded and supported by appropriate documentation.

6. Anti-Bribery and Corruption

Third Parties must comply with all applicable anti-bribery and anti-corruption legislation, including the UK Bribery Act 2010.

Third Parties shall:

• Maintain effective anti-bribery controls.
• Prohibit offering, giving, requesting, or accepting bribes.
• Prohibit facilitation payments.
• Maintain accurate books and records.
• Conduct business with integrity.

Third Parties must not make payments, gifts, hospitality, or other benefits intended to improperly influence decisions on behalf of the Firm.

The Firm may require evidence of anti-bribery policies and procedures.

7. Modern Slavery and Human Rights

Third Parties must comply with the Modern Slavery Act 2015 and respect internationally recognised human rights.

Third Parties shall:

• Prohibit forced labour.
• Prohibit bonded labour.
• Prohibit child labour.
• Prevent human trafficking.
• Ensure employment is freely chosen.
• Pay workers fairly and lawfully.
• Respect freedom of association where legally permitted.

Third Parties shall implement procedures designed to identify and mitigate modern slavery risks within their operations and supply chains.

8. Equality, Diversity and Inclusion

Third Parties shall promote equality, diversity, and inclusion and maintain workplaces free from discrimination, harassment, victimisation, and bullying.

Third Parties shall not discriminate on grounds including:

• Age.
• Disability.
• Race.
• Ethnic origin.
• Nationality.
• Religion or belief.
• Sex.
• Sexual orientation.
• Gender reassignment.
• Marital or civil partnership status.
• Pregnancy or maternity.

Third Parties are encouraged to foster inclusive workplaces and equal opportunities.

9. Employment Standards

Third Parties shall:

• Comply with employment legislation.
• Provide fair terms and conditions.
• Maintain lawful working hours.
• Pay at least applicable minimum wage requirements.
• Provide safe and respectful working environments.
• Maintain appropriate grievance procedures.

10. Health and Safety

Third Parties must provide a safe and healthy working environment and comply with all applicable health and safety legislation.

Third Parties shall:

• Identify and manage workplace risks.
• Provide appropriate training.
• Maintain accident reporting procedures.
• Promote employee wellbeing.
• Take reasonable steps to prevent workplace injuries and illness.

11. Data Protection and Confidentiality

Third Parties shall comply with:

• UK GDPR.
• Data Protection Act 2018.
• Applicable privacy legislation.

Third Parties must:

• Protect personal data.
• Maintain confidentiality.
• Implement appropriate technical and organisational security measures.
• Report data breaches promptly.
• Restrict access to confidential information on a need-to-know basis.

Information obtained through the business relationship must not be disclosed without proper authorisation.

12. Information Security

Third Parties shall maintain appropriate information security controls designed to protect confidential information, client data, and Firm information assets.

Security controls should include:

• Access controls.
• Password management.
• Data encryption where appropriate.
• Cybersecurity measures.
• Incident response procedures.
• Business continuity arrangements.

The Firm may request evidence of information security controls.

13. Sanctions and Financial Crime Compliance

Third Parties shall comply with applicable sanctions, anti-money laundering, and financial crime legislation.

Third Parties must:

• Maintain appropriate compliance procedures.
• Conduct customer and supplier due diligence where appropriate.
• Avoid transactions involving sanctioned persons or entities.
• Report any concerns that may affect the Firm.

14. Environmental Responsibility

The Firm is committed to environmental sustainability and encourages Third Parties to support responsible environmental practices.

Third Parties are encouraged to:

• Reduce greenhouse gas emissions.
• Improve energy efficiency.
• Minimise waste generation.
• Promote recycling.
• Reduce resource consumption.
• Support sustainable procurement practices.

Where appropriate, suppliers may be requested to provide environmental information or carbon reduction commitments.

15. Conflicts of Interest

Third Parties must avoid actual, potential, or perceived conflicts of interest.

Any conflict that could affect the business relationship must be disclosed promptly.

Third Parties shall not improperly influence Firm personnel or decision-making processes.

16. Gifts and Hospitality

Any gifts or hospitality offered to Firm personnel must:

• Be reasonable and proportionate.
• Be lawful.
• Be transparent.
• Not create actual or perceived conflicts of interest.

Cash gifts or equivalent benefits are strictly prohibited.

17. Monitoring and Audit

The Firm reserves the right to:

• Conduct supplier reviews.
• Request information regarding compliance.
• Undertake due diligence assessments.
• Review relevant policies and procedures.
• Conduct audits where contractually permitted.

Third Parties are expected to cooperate with reasonable requests relating to compliance verification.

18. Reporting Concerns

Third Parties are encouraged to report suspected misconduct, unethical behaviour, legal violations, or breaches of this Code.

Concerns may include:

• Bribery and corruption.
• Modern slavery.
• Fraud.
• Data breaches.
• Human rights abuses.
• Environmental misconduct.

Reports will be treated appropriately and, where possible, confidentially.

19. Breach of this Code

Failure to comply with this Code may result in:

• Corrective action requirements.
• Enhanced monitoring.
• Suspension of engagements.
• Contract termination.
• Reporting to relevant authorities where appropriate.

The Firm reserves all contractual and legal rights in respect of non-compliance.

20. Review

This Code shall be reviewed periodically to ensure continued alignment with legal, regulatory, ethical, and ESG requirements.

Approval

Approved by: Managing Partner

Policy Owner: Compliance Officer

Version: 1.0

Review Frequency: Annual