1. Purpose
1.1 This Code establishes the ethical, professional and behavioural standards required throughout TrustCome. It provides a common framework for judgement where law, contract, policy, custom or instruction may not provide a complete answer.
1.2 The Code protects institutional trust by defining expected conduct, prohibited conduct, duties of disclosure, routes for advice and reporting, safeguards against retaliation and the principles governing investigation and response.
3. Institutional Standard
3.1 Compliance with law is mandatory but may not be sufficient. TrustCome may require a higher standard where conduct could lawfully occur yet remain inconsistent with institutional integrity, independence, discretion, fairness or reputation.
3.2 No commercial target, relationship, deadline, instruction, seniority, ownership interest, political consideration or perceived strategic importance authorises a departure from this Code.
4. Personal Responsibility
4.1 Every person is responsible for understanding the provisions relevant to their role, seeking guidance before acting when uncertainty is material and reporting suspected misconduct in good faith.
4.2 A person shall not avoid accountability by relying blindly upon custom, silence, informal approval, ambiguous instruction, technological output or the fact that others engaged in similar conduct.
10. Duty to Clients and Private Principals
10.1 Clients and private principals shall be treated with competence, discretion, candour, fairness and respect. Information, influence, access or vulnerability entrusted through a relationship shall never be exploited.
10.2 TrustCome shall not create false expectations, conceal material limitations, misstate authority or accept work that cannot be performed competently and responsibly.
13. Candour and Truthfulness
13.1 Communications, representations, applications, reports, records, invoices, credentials, biographies, marketing material and statements made on behalf of TrustCome shall be accurate and not materially misleading by content, omission, emphasis or context.
13.2 A person shall correct a material error promptly and shall not allow a known misunderstanding to continue where others may reasonably rely upon it.
14. Competence, Care and Diligence
14.1 Persons shall undertake only work they are competent and authorised to perform or shall secure appropriate supervision, expertise or support.
14.2 Diligence includes preparation, verification, documentation, timely communication, appropriate challenge and recognition of the limits of one’s knowledge.
15. Fairness and Consistency
15.1 Comparable circumstances should be treated consistently unless a documented and legitimate distinction justifies a different outcome.
15.2 Favouritism, prejudice, retaliation, personal loyalty, animosity, status or wealth shall not replace objective criteria in appointment, procurement, access, opportunity, remuneration, review or discipline.
17. Authority and Delegation
17.1 No person shall commit TrustCome, approve expenditure, make representations, access restricted information or direct another person beyond documented authority.
17.2 Delegation transfers decision authority within defined limits but does not eliminate oversight, accountability or the duty to escalate exceptional risk under TC-PLC-001.
18. Conflicts of Interest
18.1 Actual, potential and perceived conflicts shall be disclosed and managed under TC-PLC-002. A person shall not determine their own conflict outcome or participate contrary to a recusal or safeguard.
18.2 Disclosure is an act of stewardship and does not by itself imply misconduct. Concealment, incomplete disclosure or participation despite restriction may constitute serious misconduct.
19. Bribery, Corruption and Improper Influence
19.1 TrustCome prohibits offering, promising, giving, requesting, agreeing to receive or accepting any financial or other advantage intended to induce, reward or conceal improper performance.
19.2 Facilitation payments, kickbacks, secret commissions, sham consulting arrangements, concealed referral fees and benefits routed through relatives, charities, agents or third parties are prohibited unless a narrow lawful emergency exception is confirmed by TrustCome Legal & Governance.
27. Information as an Entrusted Asset
27.1 Information created, received or accessed through TrustCome is an institutional asset and shall be handled according to its classification, purpose, sensitivity and lawful restrictions.
27.2 Access does not imply permission to use, copy, disclose, analyse, retain or transfer information for unrelated purposes.
28. Confidentiality and Need-to-Know
28.1 Confidential information shall be disclosed only to authorised persons with a legitimate need to know and through approved channels.
28.2 Curiosity, convenience, personal relationship, seniority or technical ability does not create a legitimate need to know.
37. Dignity and Respect
37.1 TrustCome shall maintain a professional environment in which persons are treated with dignity, fairness and respect regardless of role, status, background, identity, belief, age, disability, nationality or other protected characteristic.
37.2 Courtesy is not weakness and directness is not disrespect. High standards may be enforced firmly without humiliation, intimidation or abuse.
43. Due Diligence and Knowing the Counterparty
43.1 TrustCome shall understand the identity, ownership, authority, reputation, purpose and relevant risk of clients, partners, suppliers, advisers, agents and intermediaries before establishing material relationships.
43.2 Secrecy, unexplained ownership, unusual payment routes, unsupported urgency, adverse information or reluctance to provide basic diligence shall be treated as warning indicators.
49. Engagement Refusal and Withdrawal
49.1 TrustCome may refuse, pause or withdraw from an engagement where purpose, conduct, ownership, influence, information demands, legal exposure or ethical risk cannot be understood or controlled consistently with this Code.
49.2 Withdrawal shall be planned to protect lawful duties, confidentiality, people, records and stakeholder interests and shall not be used to conceal wrongdoing or abandon mandatory reporting.
50. Duty to Seek Guidance
50.1 Persons shall seek timely guidance where facts are uncertain, competing duties arise, a proposed action feels improper, pressure is applied or a reasonable observer could question the conduct.
50.2 Seeking advice early is expected and shall not be treated as weakness, disloyalty or inability.
53. Good-Faith Reporting
53.1 A report is made in good faith where the person honestly believes the information may indicate misconduct or risk, even if later review does not substantiate the concern.
53.2 A reporter is not required to prove misconduct before raising a concern. Knowingly false, fabricated or malicious allegations are not protected.
55. Non-Retaliation
55.1 Retaliation against a reporter, witness, adviser, investigator or person refusing improper conduct is prohibited whether direct, indirect, formal or informal.
55.2 Protection may include alternative reporting lines, access controls, confidentiality measures, monitoring of employment or engagement decisions, temporary separation and direct oversight by an independent authority.
62. Seniority and Accountability
62.1 Seniority, ownership, revenue contribution, political access, relationship value or exceptional performance shall not shield a person from review or consequence.
62.2 Greater authority may justify greater accountability because leaders shape culture, control resources and influence whether others feel able to speak.