Falconer Inc. Code of Professional Conduct 

Our values define who we are as a firm and who we aspire to be. As such, our team members are expected to live our values every day, including in difficult situations that may require additional consultation with leadership or advisors.

While our values guide our behavior and help us to make the right choices, we also hold ourselves to the highest standards of integrity and behavior. Our Code of Professional Conduct defines a set of expectations for the behavior of all Falconer team members. 

The Code of Professional Conduct highlights our personal responsibility for professional conduct. We expect all team members to comply with this Code of Professional Conduct and we expect others working on our behalf, such as contractors, advisors, etc., to act in a manner that is consistent with our Code. 

Our Code of Professional Conduct serves as a guide to our values and policies in action and outlines the expectations we have for all Falconer team members in the areas of: 

• Client Service

• Working Environment

• Risk Management

• Seeking Advice and Raising Concerns 

CLIENT SERVICE

We are privileged to have the trust of the clients that we serve, and we earn that trust by always acting with the highest integrity; by providing objective and independent advice; by putting our clients’ interests ahead of our own; and by protecting our clients’ confidential and sensitive information. We expect all team members to act at all times in ways that justify and reinforce the trust in which we are held. 

Client impact 

As a firm, we set a high aspiration for the positive impact we have through our client service. We will only undertake work where we can be confident that the objectives of the work are to bring material, positive and lasting impact; that the impact of our work has the potential to far exceed our professional fees; that we will not be pressured to compromise our values; and that we will be keeping faith with our commitment to do work that attracts, develops, excites and retains exceptional people. We are committed to delivering impact to the best of our abilities to all our clients and we hold our leaders accountable for that impact. We expect our leaders to oversee our work, ensure that the conditions for impact are in place, and to bring our best capabilities to every situation. Team members are obliged to speak up if they feel that our ability to deliver on these aspirations for impact is compromised. 

Client confidential information 

We are entrusted with client and third-party confidential information and we take exceptional care with the information that has been entrusted to us. Client confidential information is all non-public information (written or oral), including business plans and trade secrets, client names, the nature of our client services, our recommendations or advice, client data, and information we purchase at our clients’ expense. We only share client confidential information with team members who have a legitimate need to know, or those we know are authorized to access the information. In their use of social media, we expect team members to safeguard client confidential information, including anything that could reveal a client’s identity or our working relationship.

Team members are also prohibited from using client confidential information for any reason other than the service of that client. Such information cannot be used for personal or political ends, or in service of a different client. 

Conflicts of interest

All firm members are required to disclose any potential conflicts of interest, whether real or perceived, and to consult with relevant firm leaders on how best to handle the situation. 

Client resources and assets 

We expect team members to treat client assets, including facilities and equipment (where relevant), with respect, and to spend only what is necessary to perform our work to the highest standard. 

WORKING ENVIRONMENT

Our people are central to our success and we strive to create a positive working environment where they feel respected, and can thrive, grow, and be their best. We value an inclusive culture and celebrate diversity in all aspects of work and life. We expect every team member to hold themselves and each other accountable to ensure a working environment that celebrates the benefits of diversity and one in which everyone is treated with respect and dignity, feels welcomed and safe, and can grow, develop, and perform their best work.

We do not tolerate discrimination, harassment, or bullying in any form. Our expectations of behavior extend to all interactions within and beyond the work environment.

RISK MANAGEMENT

Corruption, bribery, gifts, and entertainment 

We will not participate in any form of corruption and we have an obligation to inform our clients if we encounter actual or perceived corruption in their organizations. Firm members, and anyone acting on our behalf, must not offer gifts or favors to gain any form of advantage for ourselves, our team members, or any third party. We also cannot accept gifts that are intended to influence us. 

Data security and protection 

All team members are required to protect the firm’s data and its data environment from unauthorized access.

Accurate records 

We maintain accurate records for the appropriate length of time to enable us to comply with all relevant laws and regulations. Team members are expected to file any required firm records, such as expense reports and timesheets, accurately and in a timely way. 

SEEKING ADVICE AND RAISING CONCERNS

Not every situation can be captured in a policy or code of conduct, and team members should always seek advice when faced with a difficult situation, or whenever they are unsure of the correct course of action. 

If a team member observes something they believe may be inconsistent with our values, our policies, or this Code, could put the firm or an individual team member at risk, or may be against the law, they have an obligation to speak up.

We do not tolerate retaliation against a team member who in good faith raises a concern about any aspect of professional conduct, or who fulfills their obligation to participate honestly in a firm or external investigation. 

If you are aware of a potential breach of our Values, professional standards, policies, or the law, please raise it so the firm can review it and take appropriate action. 

CONCLUSION

Our Code of Professional Conduct highlights that each of us has an obligation to maintain the highest professional standards in our client service; create an environment in which our people are respected, inspired and motivated; consider the wider implications of our actions on society; and uphold the firm’s reputation. We are each responsible for applying the standards outlined in this code, and of taking the responsibility to speak up and voice any questions or concerns related to possible violations of this code, of our values, our policies, or the law. 

This Code of Professional Conduct is intended to be a living document. 

Adopted: Oct. 9, 2023