1. Purpose
1.1 This Policy establishes a coherent institutional system for identifying, disclosing, assessing, managing, recording, reviewing and, where necessary, prohibiting conflicts of interest and threats to independent judgement.
1.2 Its purpose is to protect the integrity of decisions, engagements, appointments, transactions, investigations, publications, relationships and information entrusted to TrustCome.
4. Institutional Principles
4.1 TrustCome shall act with integrity, impartiality, independence, confidentiality, accountability and respect for lawful obligations.
4.2 A person shall place the legitimate interests of TrustCome and those it serves above undisclosed personal, financial, family, professional, political or external interests when exercising institutional responsibility.
6. Conflict Does Not Always Mean Misconduct
6.1 The existence of a conflict does not by itself establish dishonesty or misconduct. Conflicts are a normal governance risk that must be disclosed and controlled.
6.2 Failure to disclose, concealment, misleading information, participation after recusal, retaliation or personal use of confidential information may constitute a serious breach regardless of whether loss ultimately occurs.
7. Reasonable Perception
7.1 TrustCome shall consider how a reasonable and informed observer could view the circumstances, not only whether the individual believes they can remain objective.
7.2 Perception shall be assessed in context, including the sensitivity of the matter, the person’s authority, the closeness of the interest and the expectations of clients, governments, institutions and other stakeholders.
8. Non-Retaliation and Good-Faith Disclosure
8.1 No person shall suffer retaliation for making a good-faith disclosure, requesting guidance, declining participation pending review or reporting a suspected breach.
8.2 Knowingly false or malicious allegations are not protected and may be addressed under applicable conduct procedures.
24. Individual Duty
24.1 Every person within scope has a personal duty to recognise and disclose relevant interests, cooperate with assessment, comply with safeguards and avoid participation beyond the permission granted.
24.2 A manager’s knowledge of an interest does not replace the individual’s duty to disclose through the controlled process.
27. Duty to Disclose
27.1 A person shall disclose an interest as soon as they know, or reasonably should know, that it may relate to a TrustCome role, decision, engagement, transaction or information set.
27.2 Disclosure shall occur before substantive participation wherever practicable. Where the conflict arises during a matter, participation shall pause pending direction unless immediate protective action is required.
35. No Self-Clearance
35.1 No person may determine that their own conflict is immaterial or adequately managed where the matter falls within this Policy.
35.2 Routine administrative declarations may be screened by an authorised process, but the final determination shall remain independent of the affected person.
39. Recusal and Withdrawal
39.1 Recusal means withdrawal from access, discussion, recommendation, influence, approval, execution and review to the extent stated in the determination.
39.2 The affected person shall not receive informal updates, influence others through private communication or resume participation until formally authorised.
41. Prohibited Conflicts
41.1 A conflict shall be prohibited where lawful or professional duties forbid it, informed consent cannot cure it, confidential information cannot be protected, independence is fundamental to the role, safeguards are impracticable or institutional confidence would remain materially impaired.
41.2 Disclosure alone does not authorise a prohibited conflict.
45. Client, Counterparty and Mandate Conflicts
45.1 TrustCome shall assess whether duties to one client, institution, government, counterparty or mandate conflict with duties to another or with TrustCome’s own interests.
45.2 The response may include informed consent where lawful and appropriate, scope limitation, separate teams, information barriers, independent oversight or refusal or cessation of the mandate.
47. General Principle
47.1 Gifts, hospitality, travel, entertainment, discounts, favours, charitable support and other benefits shall not be offered, requested, accepted or retained where they could improperly influence, reward or appear to influence institutional judgement.
47.2 The assessment shall consider timing, value, frequency, source, recipient, cultural context, decision proximity, public-office involvement and reasonable perception.
71. Speaking Up and Seeking Guidance
71.1 A person who is uncertain shall seek guidance before acting. Questions may be raised through management, TrustCome Legal & Governance or another designated confidential channel.
71.2 Concerns shall be treated seriously and directed to an authority independent of the alleged conflict.
75. Consequences and Remedial Action
75.1 Outcomes may include guidance, training, revised safeguards, recusal, reassignment, removal of authority, recovery, contract action, disciplinary process, termination, reporting or referral to external authorities.
75.2 Consequences shall reflect intent, seniority, concealment, recurrence, cooperation, harm, benefit obtained and institutional impact.
76. Retaliation
76.1 Retaliation, victimisation, disadvantage or threat against a person who makes a good-faith disclosure or participates in an investigation is prohibited.
76.2 Retaliation shall be treated as a separate breach even where the original concern is not substantiated.