Governance is the part of the work that is not negotiable.
Where our work sits, the standard has to be visible before it is tested.
Advisory work adjacent to government carries a specific risk. What a firm like ours offers can be misread — by a client, by an intermediary, occasionally by a counterparty who hopes it is true — as access rather than assessment. That misreading is how advisory firms in emerging markets fail, and it is a failure of governance some time before it becomes a failure of ethics.
The firm’s answer is to make its constraints explicit, enforceable and public: a documented acceptance test before any mandate is taken, verification of every counterparty, a conflicts position that leads to declining rather than managing, an absolute prohibition on facilitation payments, and a route by which anyone can raise a concern without going through the person they are concerned about.
The policies below are the firm’s own, applied to the firm’s own work. They are written to United Kingdom standards — including the Bribery Act 2010, the Criminal Finances Act 2017 and the UK GDPR — and applied in full to work carried out in Bangladesh, irrespective of local practice or commercial consequence.
Six gates before any substantive work begins.
- 01
Written enquiry
Engagements begin in writing. We establish what is being sought, on whose behalf, over what period and against what expected outcome. Approaches that remain verbal are not progressed, and no substantive work is undertaken before the acceptance test below has been completed.
- 02
Counterparty due diligence
Every client, sponsor and material intermediary is identified and verified before engagement: legal existence, ownership traced through to natural persons, source of funds, adverse media, litigation and regulatory history, and identification of any politically exposed person among the beneficial owners. Where ownership cannot be traced to identified natural persons, we do not proceed.
- 03
Sanctions and financial crime screening
Counterparties, their directors and their beneficial owners are screened against United Nations, United Kingdom, European Union and United States designation lists, and against applicable export control restrictions where a project involves controlled goods or technology. Screening is repeated at each material stage rather than performed once at onboarding.
- 04
Conflicts assessment
The proposed mandate is tested against current and recent engagements and against any personal interest held by anyone who would work on it. The assessment and its outcome are recorded whether or not a conflict is found, so that the register shows what was considered as well as what was found.
- 05
Partner approval and engagement terms
Acceptance requires the agreement of the partnership, not the decision of the individual who brought the mandate. Scope, fee basis, exclusions, the composition of the team and the grounds on which we would resign are recorded in an engagement letter before work begins. Fee structures that would make our advice contingent on a particular governmental or regulatory decision are not used.
- 06
Ongoing review
Acceptance is not permanent. Due diligence is refreshed, conflicts are re-tested at each material change, and a mandate can be resigned mid-engagement where the standards set out here can no longer be met. Resignation is treated as an available outcome rather than a failure, and clients are told at the outset that it is.
Refusal criteria, written down in advance.
Facilitation payments are prohibited without exception.
The prohibition covers cash, gifts, hospitality, employment, contracts, charitable and political contributions, and any other advantage offered, promised, given, requested or accepted in order to secure or expedite an act by a public official or a private counterparty. It binds the firm, everyone working on its behalf, and every third party engaged in connection with a mandate.
It applies without regard to local expectation, to the size of the payment, to whether the act being expedited is one the payer is already entitled to, or to the commercial consequence of refusing. A delay caused by refusing a payment is an acceptable cost of doing business in this market. There is no de minimis exception and no authority anywhere in the firm to grant one.
In practice this means hospitality declared within written limits and recorded in a register; no political contribution made on behalf of a client or in connection with a mandate; anti-bribery representations, audit rights and termination rights in every engagement letter and subcontract; and diligence on third-party intermediaries to the same standard we apply to clients.
The single circumstance in which a payment demanded under duress may be made is where there is an immediate threat to personal safety. Any such payment is recorded at the time, reported to the partnership, disclosed to the client without delay, and assessed for reporting obligations.
Where a conflict is material, we decline rather than manage it.
Conflicts are identified before acceptance and re-tested whenever a mandate changes shape. A register records every identified conflict, the assessment applied to it, the decision taken and by whom.
A partnership of this size cannot honestly claim to rely on internal information barriers, and we do not pretend otherwise. Where a conflict is material — advising two parties competing for the same concession, or advising on a matter in which the firm or an individual holds an interest — the answer is to decline or to resign. Where a conflict is not material, it is disclosed in writing to every affected party and the engagement continues only with their consent.
We do not act on both sides of a negotiation. No individual may hold an undisclosed interest in a client, counterparty or supplier connected to a mandate, and declarations are refreshed annually and on every new engagement.
Screened at onboarding, and again at every material stage.
Sanctions exposure in cross-border infrastructure work rarely arrives through the client. It arrives through a shareholder two levels up, an equipment supplier, a vessel, or a payment routed through a jurisdiction nobody examined. Screening is therefore applied to the ownership chain and to the transaction, not only to the party signing the engagement letter.
Anti-money laundering controls follow the same logic. Source of funds is established and evidenced rather than asserted, unusual payment structures are questioned before they are accommodated, and the firm will decline or resign where a satisfactory explanation is not forthcoming.
Sanctions & Export Controls Policy and the Anti-Money Laundering & Counter-Terrorist Financing Policy set out the controls in full.
Information held for one mandate is not an asset for another.
Client and project information is held on a need-to-know basis, under written confidentiality terms, and is not used to advantage another client. Material learned on one engagement is not carried into another, including where it would be commercially useful to do so.
The firm does not publish client names, transaction values or project references, and does not use a mandate as a credential without written consent. That is why this website carries no client list and no case studies with parties identified. The absence is deliberate rather than an omission.
Retention periods, the treatment of personal data and the safeguards applied to transfers outside the United Kingdom are set out in the data policies in the legal register.
A concern should never have to travel through the person it is about.
Anyone may raise a concern about the conduct of the firm or about conduct encountered in connection with one of its mandates: a member of the team, a consultant, a client, a counterparty, a supplier, or a member of a community affected by a project.
Concerns can be raised with the engagement partner or, where that is not appropriate, directed to the partnership through the enquiry route on this site, marked for the attention of the partnership. Concerns may be raised anonymously. Anonymity limits what can be investigated, but it does not affect whether a concern is taken seriously.
Reports are acknowledged, assessed by someone independent of the matter, and investigated on a documented basis. Retaliation against a person who raises a concern in good faith is treated as misconduct in its own right, irrespective of whether the concern is ultimately upheld.
Anti-Bribery & Anti-Corruption Policy
Prohibitions, controls and procedures governing bribery, facilitation payments, hospitality, political contributions and third-party intermediaries.
Conflicts of Interest Policy
Identification, recording, management and disclosure of actual and potential conflicts arising in advisory and facilitation work.
Sanctions & Export Controls Policy
The firm’s approach to financial sanctions, trade restrictions and export control obligations across the jurisdictions in which it operates.
Anti-Money Laundering & Counter-Terrorist Financing Policy
The firm’s risk-based approach to money laundering and terrorist financing risk, including customer due diligence, monitoring and reporting obligations.
Whistleblowing & Speak-Up Policy
Protected channels for raising concerns about wrongdoing, the handling process, and the protections available to those who report.
Raise it with the partnership
Enquiries, requests for our policy documents in full, and concerns about the conduct of the firm or of a mandate are all reviewed by the partnership and answered directly. Concerns may be raised anonymously.
Contact the partnership