Governance · Ethics & Compliance
Integrity Must Guide Every Engagement.
Synarula Limited expects business to be conducted lawfully, honestly and responsibly. Ethical conduct is not limited to formal compliance. It requires sound judgement, transparent relationships, accurate representations and the willingness to raise concerns when conduct does not meet the standards expected.
Code of conduct
- Act honestly
- Comply with applicable law
- Avoid misleading statements
- Maintain accurate records
- Protect confidential information
- Treat stakeholders fairly
- Declare conflicts
- Reject bribery and corruption
- Respect human rights
- Protect personal information
- Escalate concerns
- Cooperate with legitimate investigations
Anti-bribery and anti-corruption
- Bribes must not be offered, requested, paid or accepted
- Facilitation payments are prohibited unless required to protect immediate personal safety and then formally reported
- Gifts and hospitality must be reasonable, transparent and recorded
- Political contributions must not be made on behalf of Synarula Limited without formal authorisation
- Charitable donations must not be used to disguise improper payments
- Agents and intermediaries must be risk assessed
- Government-facing engagements require appropriate oversight
- Suspicious conduct must be escalated
Conflicts of interest
- Actual conflicts
- Potential conflicts
- Perceived conflicts
- Disclosure obligations
- Recusal
- Independent review
- Conflict mitigation
- Conflict register
- Periodic declarations
A confidential conflict disclosure form is available. Submissions are not displayed publicly.
Submit a conflict disclosureThird-party due diligence
Due diligence scope depends on the risk and engagement type.
- Identity verification
- Company verification
- Ownership verification
- Authority verification
- Sanctions checks
- Adverse media review
- Government connection review
- Licence and permit checks
- Conflict checks
- Reputation assessment
- Risk classification
- Approval
- Periodic review
Sanctions and restricted parties
Synarula Limited must not knowingly engage in prohibited activity or with prohibited parties. Screening records are maintained for the following parties and are not exposed publicly.
- Organisations
- Individuals
- Beneficial owners
- Directors
- Representatives
- Payment beneficiaries
- Suppliers
- Buyers
- Investors
- Project owners
Anti-money laundering awareness
Synarula Limited is not described as a regulated financial institution unless legally confirmed.
- Identity checks
- Source-of-funds awareness
- Source-of-wealth awareness where appropriate
- Unusual payment patterns
- Third-party payments
- High-risk jurisdictions
- Complex ownership structures
- Cash-related risks
- Escalation
- Record keeping
Data protection and confidentiality
- Lawful data processing
- Purpose limitation
- Data minimisation
- Access controls
- Retention
- Secure storage
- Confidentiality agreements
- Data subject rights
- Breach escalation
- Supplier controls
Speak-up and reporting
A confidential reporting route is available for the following concerns:
- Bribery concerns
- Fraud
- Conflicts
- Harassment
- Discrimination
- Data misuse
- Financial misconduct
- Safety concerns
- Human-rights concerns
- Environmental concerns
- Retaliation
- Other serious misconduct
Reports will be handled as confidentially as reasonably possible, subject to legal, regulatory and investigative requirements. Complete anonymity cannot be guaranteed where it cannot technically or legally be assured.
Go to the speak-up formNon-retaliation
Good-faith concerns must not result in retaliation. Outcomes are not guaranteed before investigation, and concerns are assessed on their merits.
Raise a Compliance Concern
If you have a concern about conduct, bribery, conflicts or any matter covered here, please use the confidential speak-up route. Alternatively, contact compliance directly.