Code of conduct & ethics

Purpose & scope

This Code of Conduct & Ethics sets the standards governing how Consultinghouse GWB (“Consultinghouse”, “we”, “us”) delivers advisory services. It applies to all partners, employees, contractors, and representatives involved in client mandates, business development, and institutional relationships.

Our advisory work sits at the intersection of capital, policy, and strategic markets. Clients, development finance partners, and institutional investors rely on our judgment, discretion, and independence. This code ensures that trust is earned and maintained in every engagement.

Conflicts of interest

We identify, disclose, and manage actual and potential conflicts of interest before accepting or continuing a mandate. No advisory assignment may proceed where an unresolved conflict could compromise our objectivity or a client’s interests.

• Mandatory conflict screening at mandate intake and when material circumstances change
• Written disclosure to affected clients and, where appropriate, abstention from related work
• Separation of teams where simultaneous mandates involve competing stakeholders
• Prohibition on personal trading or investments that could influence advisory recommendations without prior approval

Client confidentiality

Information received in the course of a mandate is treated as confidential unless disclosure is required by law, agreed in writing with the client, or necessary to prevent serious harm.

Mandate materials, financial models, term sheets, and board-level communications are stored securely, shared only on a need-to-know basis, and retained in accordance with our Data Protection & Privacy policy.

Anti-corruption

Consultinghouse maintains zero tolerance for bribery, facilitation payments, and improper influence in any jurisdiction. We comply with applicable anti-corruption laws, including the German Criminal Code and, where relevant, the UK Bribery Act and U.S. Foreign Corrupt Practices Act in cross-border mandates.

• No offer, promise, or acceptance of undue advantage to obtain or retain business
• Enhanced due diligence on third parties, intermediaries, and politically exposed persons
• Immediate escalation of any suspected corruption to senior management
• Termination of relationships where integrity cannot be verified to our satisfaction

Gifts & hospitality

Modest hospitality that facilitates normal business relationships is permitted where it is proportionate, transparent, and cannot reasonably influence advisory judgment. Cash gifts, lavish entertainment, and benefits to public officials are prohibited unless expressly permitted by applicable law and pre-approved in writing.

All gifts or hospitality above internal thresholds must be recorded in our compliance register. Employees may not solicit gifts or preferential treatment from clients, counterparties, or suppliers.

Reporting & accountability

Concerns about conduct may be reported to management or via our confidential compliance channel. Retaliation against good-faith reporters is prohibited. Material breaches are investigated promptly and may result in disciplinary action, mandate withdrawal, or notification to regulators where required.

For full policy documents or compliance inquiries, contact [email protected].