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Governance and 



Ethical Policy

1. Purpose

FIN1 THE CONSULTANCY OF CORPORATE GOVERNANCE AND COMPLIANCE (CCGC) LTD with Company number: 09869037 (“the Company” and/or “FIN1 (CCGC) LTD”) is committed to the practice of responsible corporate behaviour. Through its business practices, the Company seeks to protect and promote the human rights and basic freedoms of all its employees and agents.

Further, the Company is committed to protecting the rights of all those whose work contributes to the success of the Company, including those employees and agents of suppliers to the Company.

The Company is also committed to eliminating bribery and corruption. It is essential that all employees and persons associated with the Company adhere to this policy and abstain from giving or receiving bribes of any form.

This policy is non-exhaustive, and all aspects of the Company’s business should be considered in the spirit of this policy.

3. Workers’ Rights

The Company is committed to complying with all relevant employment legislation and regulations. The Company regards such regulations and legislation as the minimum rather than the recommended standard.

No worker should be discriminated against based on age, gender, race, sexual orientation, religion or beliefs, gender reassignment, marital status, or pregnancy. All workers should be treated equally. Workers with the same experience and qualifications should receive equal pay for equal work.

No worker should be prevented from joining or forming a staff association or trade union, nor should any worker suffer any detriment because of joining, or failing to join, any such organisation.

Workers should be aware of the terms and conditions of their employment or engagement from the outset. Workers must be made aware of the wage that they receive, when and how it is to be paid, the hours that they must work, and any legal limit which exists for their protection and any overtime provisions.

Workers should also be allowed such annual leave, sick leave, maternity/paternity leave, and such other leave as is granted by legislation as a minimum.

The Company does not accept any corporal punishment, harassment in any form, or bullying in any form.

5. Conflicts of Interest

The Company holds as fundamental to its success the trust and confidence of those with whom it deals, including clients, suppliers, and employees. Conflicts of interest potentially undermine the relationship of the Company with its partners.

To help preserve and strengthen these relationships, the Company has developed a Corporate Hospitality and Gifts Policy, which provides rules and guidelines concerning the conduct of its officers and employees aimed at minimising the possibility of conflicts of interest and at avoiding risks associated with bribery and corruption.

All officers, employees, and representatives of the Company are expected to act honestly and within the law and its spirit. 

10. Service Provision and Business Conduct

10.1 We conduct our business by bringing into effective action the highest levels of integrity, due diligence, and professionalism.

10.2 We are fully committed to the protection of the financial system and continuously strive to contribute towards the implementation of a sound financial crime prevention policy in accordance with UK, EU, and International Standards.

10.3 We have a strict policy in place for not offering our opinion, services, and professional training to entities and individuals involved or suspected of being involved in arrangements to handle criminal and/or terrorist financing proceeds.

10.4 We dedicate a substantial part of our time to follow and stay aligned with national and international regulatory compliance developments.

10.5 We are committed to the invaluable principles of client confidentiality and data protection. In the interests of discharging our statutory duties and obligations, we cooperate with national and international regulatory authorities with a view to promote and enhance public policy, institutional safety, and soundness and foster a culture of good compliance.

10.6 We are committed 100% to fiscal transparency and promoting and enhancing tax justice throughout conducting our business.

10.7 We have a zero-tolerance policy towards all forms of financial crime, money laundering, terrorism and financing, bribery and corruption, tax evasion, cybercrime, trade misinvoicing, non-conformity with HM Treasury and the Department for Business, Innovation, and Skills, and fraud of any form and type whatsoever.

10.8 We conduct our business by implementing preventive and ongoing KYB/KYC/CDD/Third-Party Risk Management controls.

10.9 Whilst doing business, we are fully committed to rejecting and reporting any form of anti-social behaviour or any suspicious behaviour that may potentially compromise the application of financial regulation, public safety, and the rule of law.

10.10 The Directors of FIN1 adhere fully to the set of duties laid down in the Department for Business Innovation and Skills | Directors’ duties, BIS Director (10/15) Version 1.0 

2. Human Rights

The Company is vehemently opposed to the use of slavery in all forms; cruel, inhuman, or degrading punishments; and any attempt to control or reduce freedom of thought, conscience, and religion.

The Company will ensure that all its employees, agents, and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998.

The Company will not enter in any business arrangement with any person, company, or organisations failing to uphold the human rights of its workers or who breach the human rights of those affected by the organisation’s activities.

4. Environmental Issues

The Company is committed to keeping the environmental impact of its activities to a minimum and has established an Environmental Policy to help achieve this aim.

As an absolute minimum, the Company will ensure that it meets all applicable environmental laws in whichever jurisdiction it may be operating.

6. Information and Confidentiality

Information received by employees, contractors or agents of the Company will not be used for any personal gain, nor will it be used for any purpose beyond that for which it was given.

The Company will always ensure that it complies with all applicable requirements of data protection legislation (including, but not limited to, the Data Protection Act 1998) in force from time to time.

7. Shareholders and Investors

The Company, its officers, employees and representatives, and its subsidiaries are committed to ensuring that no act or omission which is within their power and which would have the effect of deliberately, negligently, or recklessly misleading the shareholders, creditors, or other investors in the Company occurs.

8. Suppliers and Partners

8.1 The Company expects all suppliers and partners to work towards and uphold similar ethical and moral standards.

8.2 The Company will investigate the ethical record of potential new suppliers before entering into any agreement. Further, the Company reserves the right to request information from suppliers regarding the production and sources of goods supplied.

8.3 The Company reserves the right to withdraw from any agreement or other arrangement with any supplier or partner who is found to have acted in contravention of the spirit or principles of this Ethical Policy.

9. Bribery and Corruption

9.1 The Company is fundamentally opposed to any acts of bribery and to the making of facilitation payments as defined by the Bribery Act 2010.

9.2 Employees and any other persons associated with the Company such as agents, subsidiaries, and business partners are not permitted to either offer or receive any type of bribe and/or facilitation payment.

9.3 All employees are encouraged to report any suspicion of corruption or bribery within the Company in accordance with the Whistleblowing Policy.

9.4 Should any employee or associated person be in doubt when receiving or issuing gifts and hospitality, he/she must refer to the Gift and Hospitality Policy.

9.5 The Company uses its reasonable endeavors to implement the guidance principles on bribery management that are published, from time to time, by Secretary of State in accordance with Section 9 of the Bribery Act 2010.

9.6 If an employee or associated person is found guilty of giving or receiving a bribe, he/she will be personally criminally liable and may be subject to disciplinary action.

9.7 Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or expenses.


Customer Treatment Policy

At FIN1 we believe that our customers are our most Valuable Asset. We strive to work closely with our clients and encourage them to refer or recommend us to their sister companies, trusted business partners and established contacts.

One of our main strategic goals is to see progressive development and repetition of the range of services we offer.

We are also highly specialised in carrying out private research and executive training, and when circumstances necessitate, we will work at anti-social hours to successfully deliver our projects.

Yet we are not more expensive than other competitors simply because we know:

  • The rates of our most expensive competitors.
  • We clearly demonstrate from the outset to our clients the savings and benefits of hiring us.
  • We have done identical work before.
  • We have special skills in place.
  • We work with precision, concision, confidentiality, and operational discipline.
  • We have an impeccable track record.
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