This Code of Business Conduct and Ethics (“Code”) sets out the guiding principles and ethical standards that all employees, officers, directors, and representatives of Bale Capital (“the Company”) are expected to uphold. It reflects our commitment to operating with integrity, accountability, and transparency in all aspects of our business.
This Code is supported by detailed policies which expand on the expectations and requirements summarised herein. All employees must comply with the Code and the supporting policies.
This Code applies to:
All directors, officers, and employees of Bale Capital;
Contractors, agents, consultants, and business partners acting on Bale Capital’s behalf.
Compliance with this Code and related policies is a condition of continued employment or engagement with the Company.
Our business is founded on the following core principles:
Integrity: Conducting all activities honestly, ethically, and lawfully.
Transparency: Ensuring open, complete, and accurate communication and recordkeeping.
Accountability: Taking responsibility for actions and decisions.
Respect: Treating all individuals with dignity and fairness, and upholding their rights.
Sustainability: Minimising environmental impact and promoting long-term value creation.
These principles are further elaborated in Bale Capital’s Environmental and Social Responsibility Policy and Human Rights Policy.
Employees and representatives must comply with all applicable laws, regulations, and industry standards in the jurisdictions in which we operate.
For specific obligations and compliance protocols, refer to:
Sanctions and Trade Compliance Policy
Anti-Money Laundering and Counter-Terrorism Financing Policy
Anti-Bribery and Corruption Policy
Conflicts between personal interests and company interests must be avoided. Employees must not use their position or Company resources for personal gain or for the benefit of related parties without prior disclosure.
Refer to the Conflict of Interest Policy for procedures on declaring and managing potential conflicts.
Bale Capital prohibits all forms of bribery, facilitation payments, or corrupt practices. Employees must not offer, promise, give, solicit, or receive anything of value to obtain or retain business or influence a decision.
For details on thresholds, due diligence, and reporting obligations, refer to the Anti-Bribery and Corruption Policy.
Modest gifts and hospitality may be offered or accepted only where they are lawful, reasonable, and not intended to secure undue influence. Cash or cash equivalents must never be given or accepted.
Guidance is provided in the Gifts and Business Entertainment Policy.
Employees must act fairly, honestly, and in good faith in all commercial dealings. Anti-competitive behaviour such as price-fixing, bid-rigging, and misuse of confidential information is strictly prohibited.
See the Competition and Fair Dealing Guidelines for further detail.
Company assets, whether physical, digital, or intellectual, must be protected from loss, damage, theft, and unauthorised use. All assets must be used for legitimate business purposes only.
The IT and Asset Management Policy and Information Security Policy provide detailed guidance.
Employees must maintain the confidentiality of non-public information and protect personal and business data in accordance with applicable privacy laws and internal protocols.
For obligations relating to data handling and breach reporting, consult the Data Protection and Privacy Policy.
We foster a professional and inclusive workplace free of discrimination, harassment, and bullying. Diversity and equal opportunity are fundamental to our culture.
Refer to the Equal Opportunity and Anti-Harassment Policy and Workplace Behaviour Policy for conduct expectations.
All employees are responsible for maintaining a safe working environment and complying with health and environmental regulations.
Detailed responsibilities are set out in the Health, Safety, and Environment (HSE) Policy.
The Compliance Officer oversees the implementation, interpretation, and enforcement of this Code. Violations may result in disciplinary action, including termination of employment or contract.
All personnel are required to familiarise themselves with this Code and the supporting policies listed herein. Training will be provided as appropriate, and periodic reviews will be undertaken to ensure continued relevance and effectiveness.