03Ethical Conduct

MODERN SLAVERY AND FORCED LABOUR

AVENIR GLOBAL is firmly committed to respecting the human rights of all our employees and those within our supply chain. We have zero tolerance for human rights violations and expect our suppliers to uphold the same high standards that we impose on our businesses.

In 2024, in alignment with the disclosure requirements of the United Kingdom’s Modern Slavery Act 2015 and Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act, AVENIR GLOBAL published its first Modern Slavery Statement. This document outlines the policies and actions we have taken to raise awareness and prevent modern slavery and forced labour in our operations and supply chains.

In addition, we introduced a new mandatory course designed to help employees understand modern slavery and forced labour, recognize warning signs, and minimize risk when working with third parties.

For 2025, we are committed to continue improving our procurement practices and developing a greater understanding of risks associated with our supply chains.

BRIBERY AND CORRUPTION

We put business integrity at the heart of our values and maintain a zero-tolerance policy toward bribery and corruption.

In 2024, we introduced a new mandatory ethics course entitled “Anti-bribery and corruption: Our responsibilities”, designed to help employees understand key concepts, how to avoid bribery, how to recognize acceptable gifts and hospitality, and know their obligations when acting as third parties for our clients.

We also introduced a new global policy on bribery and corruption to ensure employees are fully aware of their obligations and responsibilities in the fight against corruption.

CONFLICTS OF INTEREST

The ability to make objective and impartial decisions is key to being trusted partners to our clients. This is why we take active measures to ensure that employees’ personal activities do not interfere with their professional obligations.

Since 2023, all employees are required to complete a mandatory course on conflicts of interest upon joining the Firm and every two years thereafter. This course helps them identify various types of conflicts of interest, understand how to navigate delicate situations, and actively respond when conflicts arise.

In 2024, we also launched a new Firm-wide policy on conflicts of interest to ensure that all our brands have a consistent approach to preventing and addressing these issues.

WHISTLEBLOWING HOTLINE

Creating an environment that promotes transparency and accountability is vital for preventing and addressing unethical conduct. In 2024, we introduced a whistleblowing platform that enables employees to report any ethical concerns or incidents they may encounter as part of their work. This includes, but is not limited to, conflicts of interest, fraud, bribery, or any violation of our Code of Conduct. The platform is hosted by a third party and offers a secure and confidential way to report concerns, ensuring they reach AVENIR GLOBAL’s senior management team directly.

To support this initiative, we also published a new global policy titled “Guidelines on whistleblowing procedures” to help employees understand how to raise ethical concerns and reassure them that they can do so without fear of retaliation. We will continue to increase awareness of this tool to ensure employees feel empowered to speak up with full confidence.

INFORMATION SECURITY AND PRIVACY AWARENESS

As cyber threats become more frequent and complex, we must take all necessary measures to protect all information and data entrusted to us by our clients.

In 2024, we continued our ongoing training and awareness program on information security and privacy. All new employees of AVENIR GLOBAL are required to complete two mandatory courses—“Security Essentials” and “Privacy Essentials”—within their first month of employment. Every quarter, all employees must complete a mandatory course covering important topics such as password management, phishing and ransomware, data leakage, and remote work, among others. We also conduct periodic phishing simulations to gauge the effectiveness of our training program.

Additionally, as part of Cyber Security Awareness Month in October, employees were asked to complete a series of weekly “cyber challenges” on key security topics. Staff who completed all training activities were eligible to win a prize package.

CYBER ESSENTIALS PLUS CERTIFICATION

In 2024, AVENIR GLOBAL obtained the “Cyber Essentials Plus” certification. Cyber Essentials Plus is a scheme backed by the government of the United Kingdom that guides organizations in implementing appropriate security measures to protect themselves against many of the most common cyber-attacks. This certification supports our efforts to successfully meet and exceed the security requirements of our clients.