| Ethics Policy |

Malachite was founded with a clear intention to increase both the profit and social value of the businesses we advise. In all our work, we aim to blend strong profits with good social impact, and to shape high value businesses that are good for our clients and good for the communities they impact.

An Ethical Understanding of Business

A number of values define our understanding of what business is and how it should be carried out responsibly.

1. MALACHITE BELIEVES THAT BUSINESS IS AN ACTIVITY WITH MORAL RESPONSIBILITIES.

A good business is one that aims for both profit and public good. At Malachite, we believe that a business does not just have the singular responsibility to make a profit. It also has wider responsibilities to the society in which it thrives. Malachite has responsibilities to our shareholders, our clients, our employees and to people affected by our advice.

We believe responsible capitalism means respect for all of these actors and always considering the different stakeholder interests and impacts.

2. MALACHITE BELIEVES IN THE PRINCIPLES OF RULE OF LAW, GOVERNMENT REGULATION AND TAXATION.

Business is best governed by national and international laws that are common to all companies and that create a fair and transparent environment for commercial competition.

Regulation is vital in the interests of companies, employees, customers, consumers and society at large to protect them from danger, ill health, exploitation, excessive environmental damage and fraud. It is also essential as protection from monopolies, oligopolies and unfair prices.

Taxation is essential to convert business gains into public goods. A good tax system can deliver a fair and objective redistribution of wealth that companies cannot ensure and oversee on their own.

3. MALACHITE ACTIVELY WORKS TO RESPECT THE HUMAN RIGHTS OF EVERY INDIVIDUAL ACROSS THE WORLD.

Every person has individual rights and responsibilities. These are vital to consider in the way we work and in the advice we give. In particular, all of our work aims to respect the Universal Declaration of Human Rights, the International Bill of Human Rights, the International Labour Organisation’s Eight Core Conventions on Fundamental Human Rights, and the UN Convention on Corruption. We further endorse the UN Guiding Principles on Business and Human Rights and encourage our clients and partners to adopt the highest standards of respect for human rights.

Malachite is committed to steering a fair and ethical course when the human rights of different groups collide. Many commercial ventures face practical difficulties with trade-offs between the rights of different groups, and between the rights of people alive today and the rights of people in future generations not yet born. We take seriously these various ‘rights clashes’ when they arise. We seek always to minimise them and to mitigate the worst effects of any business we advise.

4. MALACHITE BELIEVES IN BEING OPEN TO ANY LEGAL BUSINESS OPPORTUNITY AND DOES NOT PROSCRIBE PARTICULAR CLIENTS OR SECTORS.

We will not rule out working for any particular sector or client but will judge each business opportunity on its commercial and ethical merits.  If we can achieve good business and, at the same time, abide by our principles with an ethically controversial client, or within an ethically contested sector, we will seek to do so.

Making Ethical Choices

Malachite encourages a conscious approach to the way it makes ethical choices and encourages an ethical culture within its team. This culture is complemented by internal and external accountability mechanisms, both formal and informal.

1. MALACHITE WORKS TO FIND THE MORAL BALANCE IN A PROJECT SO THAT WE DELIVER BOTH COMMERCIAL AND SOCIAL VALUE.

Most difficult decisions in business ethics are situation-specific. Finding the right moral balance in an investment strategy will always have to be struggled with and worked out around particular deals and within specific limits. Malachite believes that a good choice is one that finds the “golden mean” in an investment strategy that is not too commercially focused and anti-social, nor too socially focused and anti-commercial.

2. ETHICAL DELIBERATION IS A KEY ELEMENT IN SHAPING COMPANY CHARACTER AND DECISION-MAKING.

Malachite believes that ethical business is a matter of character and judgement. Practical experience and due deliberation of ethical problems is the best way to shape ethical character in a company and cultivate a morally alert company.

Malachite staff and associates are encouraged to raise ethical questions at any time and to have their concerns duly deliberated. This process of deliberation involves listening to a range of views across the company and among the different stakeholders in a given project. Regular deliberation is an essential way of forming a common “company conscience” which can then be acted on by different members of the company at different times and in different places. In particularly difficult cases, ethical deliberation will be referred to the Board for a final decision.

3. MALACHITE IS A MEMBER OF THE GLOBAL COMPACT AND SUPPORTER OF THE UN GUIDING PRINCIPLES ON BUSINESS AND HUMAN RIGHTS.

Malachite follows closely the thinking and policy of the UN Secretary General’s Special Representative on Business and Human Rights (the ‘Ruggie Principles’). We also recognise the importance of external ethical monitoring to encourage the highest standards of self-discipline and public accountability. We are, therefore, members of the United Nations’ Global Compact, reporting annually and publically against their ten principles of human rights, labour rights, non-corruption and environmental responsibility.

Our Ethical Operating Principles

Alongside a concern for ethical decision-making, Malachite also aims to act ethically in the day-to-day management of our business.

  1. We run our business honestly, transparently, and legally. We adhere strictly to the UK Anti-Bribery Act.
  2. We will continually try to improve our performance in the best interests of our shareholders, our clients, our employees and the people affected by the advice we give.
  3. We will operate to high standards of research which value veracity, accuracy and a duty of care towards people we interview and observe, and in our written reports.
  4. We will operate with discretion and confidentiality on behalf of our clients so that our actions do not compromise them with potential government partners or commercial competitors.
  5. We will operate with complete professional independence so that our advice is always objective and not influenced by excessive self-interest or by client bias.
  6. We will always work openly and transparently and never pretend to be another entity or hide our own identity.
  7. We will report suspected human rights violations to the best authorities at the time whenever we encounter them.
  8. We will operate as a good employer by providing fair rewards, good working conditions, a duty of care and giving employees a fair say in the running of the company.
  9. We will be a good contractor and customer by honouring our contracts and paying our bills on time.