Effective Date: [November 14 , 2019]
Last Updated: [February 3 , 2026]
PURPOSE
Colangelo & Partners (“C&P”) is committed to conducting business with the highest standards of integrity, professionalism, and ethical responsibility.
This Code of Ethics establishes the principles and expectations that guide the behavior of all employees, partners, contractors, and representatives of the firm.
Our goal is to ensure that all activities are carried out in a manner that is:
- Ethical
- Transparent
- Compliant with applicable laws and regulations
- Respectful of clients, partners, and the public
SCOPE
This Code applies to:
- All employees (full-time and part-time)
- Senior leadership and partners
- Contractors, consultants, and freelancers
- Any third party acting on behalf of Colangelo & Partners
All individuals are expected to understand and comply with this Code.
CORE PRINCIPLES
- Integrity
- We act honestly and ethically in all professional interactions and business decisions.
- Accountability
- We take responsibility for our actions and their outcomes, both internally and externally.
- Respect
- We treat colleagues, clients, partners, and stakeholders with fairness and respect.
ANTI-CORRUPTION POLICY
Colangelo & Partners maintains a strict zero-tolerance policy toward corruption and bribery.
- Prohibited Conduct
- Employees and representatives may not:
- Offer, promise, give, or accept bribes or improper payments
- Provide anything of value to influence business decisions improperly
- Engage in facilitation payments or kickbacks
- Use third parties to circumvent anti-corruption laws
- Employees and representatives may not:
- Compliance with Laws
- C&P complies with all applicable anti-corruption regulations, including:
- U.S. Foreign Corrupt Practices Act (FCPA)
- UK Bribery Act (where applicable)
- Local anti-corruption laws in all markets of operation
- C&P complies with all applicable anti-corruption regulations, including:
- Gifts and Hospitality
- Must be reasonable, transparent, and appropriate
- Must not influence or appear to influence decision-making
- Must comply with client and legal guidelines
TRANSPARENCY AND BUSINESS PRACTICES
Transparency is fundamental to how we operate.
- Client Transparency
- We commit to:
- Clear and accurate communication of services and deliverables
- Transparent billing and financial reporting
- Honest representation of results and performance
- We commit to:
- Conflicts of Interest
- All employees must:
- Disclose any actual or potential conflicts of interest
- Avoid situations where personal interests conflict with client or company interests
- All employees must:
- Accurate Records
- C&P maintains:
- Accurate financial records
- Clear documentation of activities and decisions
- Proper reporting practices aligned with regulatory requirements
- C&P maintains:
CONFIDENTIALITY
- We protect confidential and proprietary information belonging to:
- Clients
- Employees
- Partners
- Confidential information must not be disclosed without proper authorization.
WHISTLEBLOWER AND REPORTING CHANNEL
Colangelo & Partners is committed to creating a safe environment where concerns can be raised without fear of retaliation.
- Reporting Misconduct
- Employees and stakeholders are encouraged to report:
- Violations of this Code
- Unethical or illegal conduct
- Conflicts of interest
- Fraud, corruption, or misconduct
- Employees and stakeholders are encouraged to report:
- Reporting Channels
- Reports can be submitted through the following confidential channels:
- Email: ethics@colangelopr.com
- Direct Reporting: Any member of senior leadership
- Anonymous Reporting: Available upon request via secure submission process
- Reports can be submitted through the following confidential channels:
- Non-Retaliation Policy
- C&P strictly prohibits retaliation against any individual who:
- Reports a concern in good faith
- Participates in an investigation
- Any act of retaliation will be subject to disciplinary action.
- C&P strictly prohibits retaliation against any individual who:
ENFORCEMENT
Violations of this Code may result in:
- Disciplinary action
- Termination of employment or contract
- Legal action where applicable
All reports will be reviewed and investigated appropriately.
GOVERNANCE AND REVIEW
This Code is reviewed periodically to ensure alignment with:
- Legal requirements
- Industry best practices
- Organizational values
ACKNOWLEDGMENT
All employees and representatives of Colangelo & Partners are required to:
- Acknowledge receipt of this Code
- Commit to compliance
PUBLIC AVAILABILITY
This Code of Ethics is publicly available and reflects Colangelo & Partners’ commitment to ethical conduct, transparency, and accountability in all business activities.
Colangelo & Partners
Integrity. Transparency. Accountability.
