Conflict of Interest Policy

Effective Date: 5 January 2022

Moxe Consulting (“the Firm”) is committed to ensuring that all assignments are carried out with impartiality, objectivity, and professional independence. This policy outlines the Firm’s approach to identifying and managing conflicts of interest that may arise during the course of its work. It is intended to promote transparency and accountability in support of the Firm’s due diligence and investigative services, including those conducted on behalf of government and institutional clients.

This policy is reviewed periodically and updated as necessary in response to legal, regulatory, or operational developments.

1. Purpose

The purpose of this policy is to preserve the credibility of the Firm’s work and protect the integrity of its findings. It establishes the principles by which the Firm and its representatives conduct themselves when circumstances may give rise to divided loyalties or competing interests. It also serves to reassure clients that any situation with the potential to compromise objectivity will be addressed with appropriate seriousness and care.

2. Scope

This policy applies to all individuals acting under the direction of the Firm, including full-time personnel, consultants, researchers, and affiliated professionals. It applies across jurisdictions and to all types of assignments, including reputational assessments, enhanced due diligence, and field-based research. Conflicts covered by this policy may be actual, potential, or perceived, as reasonably assessed by the Firm.

3. Principles and Interpretation

A conflict of interest may arise where a personal, financial, or professional relationship has the potential to impair, or be perceived to impair, a representative’s independence or objectivity in the performance of their duties. Examples include overlapping mandates, prior relationships with the subject of an investigation, or undisclosed interests in entities involved in the assignment. Each situation is reviewed on a case-by-case basis. Where appropriate, the Firm may implement mitigation measures or reassign personnel to maintain the impartiality of its work.

4. Duty to Disclose and Response Mechanism

All representatives of the Firm are required to disclose any actual, suspected, or potential conflict of interest promptly upon becoming aware of it. Disclosures must be made to the Firm’s management, which will assess the matter and determine an appropriate course of action. This may include reassignment, the implementation of safeguards, or, if necessary, withdrawal from the engagement. The Firm may also conduct proactive intake assessments to identify and manage potential issues at an early stage.

5. Confidential Handling and Good Faith Reporting

Disclosures of actual or potential conflicts are treated in confidence and reviewed internally. The Firm encourages open, timely reporting and does not penalize individuals for disclosures made in good faith. Where a conflict has been appropriately disclosed and managed, it will not be considered misconduct.

6. Contact Us

For any inquiries regarding this Conflict of Interest Policy, please contact us at: