Code of Conduct

PMG is a global management consulting firm. We embed in our clients' organisations, hold positions of trust in leadership roles, manage sensitive information, advise on high-stakes decisions, and in some cases hold equity stakes in the businesses we serve. That breadth of engagement creates real responsibility.

This Code of Conduct sets out the standards of behaviour that PMG expects of everyone who acts on its behalf. It applies to employees, contractors, consultants, embedded leaders, and executives, whether compensated by PMG or not, and wherever in the world they operate. It is not an exhaustive list of rules. It is a statement of the values and principles that underpin every PMG policy, and a guide to the judgment we expect our people to exercise when the rules do not give a clear answer.

When in doubt about whether a course of action is appropriate, ask yourself whether you would be comfortable if PMG's leadership, your client, and a reasonable independent observer could all see exactly what you are doing and why. If the answer is no, reconsider.

Our values

PMG's values are the principles that govern how we make decisions, treat people, and conduct ourselves every day, in client engagements, in internal teams, and in every market we operate in.

Integrity

Integrity is the foundation of every relationship PMG builds. We are committed to honesty, transparency, and ethical conduct in all our interactions. We are straightforward with clients about our processes, our fees, and our limitations. We deliver on our commitments, and when we fall short, we take responsibility. Trust is earned through consistent, principled behaviour over time, not claimed.

Respect

We approach every interaction with genuine regard for the person in front of us. We actively listen to clients and colleagues, value the diversity of perspectives and experiences our teams bring, and treat everyone with courtesy and professionalism regardless of their role or background. Respect is not a minimum standard. It is the condition for doing good work together.

Innovation

PMG is driven by a commitment to continuous improvement and original thinking. We do not recycle playbooks. We encourage rigorous inquiry, challenge assumptions, and look beyond our own industry experience to find better approaches. Innovation at PMG is not a posture. It is the practical habit of asking whether there is a smarter way and being willing to find out.

Excellence

We set high standards and hold ourselves to them. We invest in developing our skills, are meticulous in our work, and measure success by outcomes rather than outputs. Excellence is not a destination. It is an ongoing commitment to doing the next piece of work better than the last.

Authenticity

We believe that genuine relationships produce better work. We value open and honest communication, encourage people to bring their authentic perspectives rather than the ones they think are expected, and work to create an environment where everyone can be themselves. Authenticity is not an invitation to be careless. It is a foundation for the trust that makes everything else possible.

These values are not independent of the conduct standards that follow. They are the reason for them.

1. Integrity In All Things

PMG's reputation is built on doing what we say we will do, giving honest advice even when it is unwelcome, and behaving consistently whether or not we are being observed.

Integrity means being honest with clients about what we know, what we do not know, and what our limitations are. It means representing our work accurately, acknowledging mistakes promptly, and never misrepresenting a deliverable, a credential, or a result. If an engagement falls outside your areas of genuine expertise, you must decline it. Overstating your capabilities to secure an opportunity is a breach of this Code.

Your professional information must be accurate, current, and verifiable at all times. This includes your career history, legal name, affiliations, and relevant experience. If any of this information changes prior to or during an engagement, you must notify PMG immediately.

The insights and work you contribute must be your own, grounded in your knowledge and professional judgement. You must not present the work, ideas, or analysis of any third party as your own. This includes work produced in previous PMG engagements. While PMG welcomes the use of approved AI tools to support consulting work, AI-generated content may not be passed off as your own professional insight. AI is a support instrument, not a substitute for genuine expertise.

It also means behaving with integrity toward colleagues and partners. We do not mislead, manipulate, or take advantage of information asymmetries within PMG's own teams. We do not claim credit for work we did not do, and we give credit where it is due.

Dishonesty, fraud, and misrepresentation of any kind are grounds for immediate termination and, where applicable, legal action.

2. Client Trust & Confidentiality

Every engagement at PMG is governed by four core compliance undertakings. These are not aspirational. They are mandatory conditions of participation for all PMG personnel.

Non-disclosure

You must not disclose information specific to any company where you are currently employed, or where you serve as an officer, director, consultant, agent, or representative. Your obligations to your current and former employers remain in force during any PMG engagement.

Confidentiality

You must not disclose any material non-public, confidential, or proprietary information about any subject matter while working with PMG or any of our clients. This applies regardless of how the information was obtained and regardless of whether it has been formally marked as confidential.

Conflict of interest

You must not participate in a transaction if it creates a personal conflict of interest or if it conflicts with any duty you owe to a current or former employer, engagement, or third party. Where a potential conflict exists, you must disclose it before proceeding.

Transaction confidentiality

Every transaction must remain confidential, including its participants, its subject matter, and the identity of the client. This obligation continues after the engagement concludes.

Beyond these four undertakings, PMG's broader data handling rules apply in full. Client data is always treated as Highly Confidential. It must be stored within PMG's enterprise-managed cloud environment, encrypted in transit and at rest, and accessible only to those who need it for the specific engagement. It is never stored on personal devices or local hard drives. Client data is never used to train AI models, never shared with third-party platforms without explicit documented consent, and never used for the benefit of a different client. These are absolute rules.

This obligation does not end when an engagement does. Confidential information obtained during a client engagement remains confidential indefinitely.

Eligibility and participation standards

PMG does not permit participation in engagements by individuals who have, in a personal or professional capacity have been:

• convicted of a felony involving financial matters, employment obligations, or trustee or fiduciary duties;
• subject to sanctions administered by any jurisdiction;
• the subject of an investigation by a securities regulator in any jurisdiction;
• been subject to any equivalent conviction, sanction, listing, investigation, or proceeding not listed above.

Any change in circumstances that brings you within any of these categories must be disclosed to the Ethics Officer at ethics@askpmg.com immediately. Failure to disclose is itself a breach of this Code and grounds for termination of engagement.

3. Conflicts Of Interest

PMG's business model spans consulting, equity partnerships, fractional leadership, licensing, and white-label services. This creates genuine potential for conflicts of interest. We manage this through transparency and process, not by pretending the potential does not exist.

Every PMG consultant and embedded leader is personally responsible for identifying potential conflicts before accepting a role or engagement. The existence of a potential conflict is not automatically disqualifying. Failing to disclose one is.

Conflicts must be disclosed in writing to the Ethics Officer at legal@askpmg.com before accepting an engagement. This includes situations where you are working for two clients who compete directly with each other, where PMG holds an equity stake in a company connected to the engagement, where you are a licensee operating near the boundary of your exclusive territory, or where a personal financial interest could influence your professional judgement.

Where a conflict is found, the Ethics Officer will determine the appropriate response, which may include recusal, information barriers, or, in serious cases, withdrawal from the engagement. All disclosures and outcomes are documented and retained.

PMG takes conflict of interest violations seriously. They represent a fundamental breach of the trust that clients, partners, and colleagues place in us.

4. Anti-Bribery & Anti-Corruption

PMG has zero tolerance for bribery and corruption in any form, in any jurisdiction, under any circumstances. No business objective, client relationship, or commercial outcome justifies any departure from this standard.

You must never offer, give, promise, request, or accept anything of value to improperly influence a business decision or government action. This applies to direct payments and to arrangements made through third parties. It applies in every country PMG operates in, including those where facilitation payments or informal advantages are common practice. PMG's prohibition is absolute.

Gifts and hospitality are permitted where they are transparent, proportionate, not in cash or cash equivalents, and valued under USD $100 per instance. Anything at or above that threshold must be logged in the gifts and hospitality register within five business days. Any gift or hospitality involving a public official requires pre-approval from legal@askpmg.com, regardless of value.

If you encounter a demand for a facilitation payment, decline, document it, and report it to legal@askpmg.com immediately. Do not pay it.

PMG's anti-bribery obligations are governed by applicable law across all operating jurisdictions, including the Canadian CFPOA, the US FCPA, and the UK Bribery Act 2010. The UK Bribery Act in particular imposes strict liability for failure to prevent bribery, and this Code is structured to constitute adequate procedures under that Act.

5. Fair Treatment & Equal Opportunity

PMG is committed to a workplace where every individual is treated with dignity and respect, and where decisions about hiring, development, compensation, and advancement are based on merit and qualifications, nothing else.

We do not discriminate on the basis of race, colour, ethnicity, national origin, religion, age, marital status, sex, gender identity or expression, sexual orientation, disability, or any other characteristic protected by applicable law. This commitment applies to every aspect of employment and engagement with PMG, from recruitment through to separation. Hostile or abusive language, slurs, and personal attacks of any kind are prohibited in all forms of communication.

Harassment of any kind is prohibited. This includes conduct that creates a hostile, intimidating, or offensive environment, whether directed at employees, contractors, clients, or any other person associated with PMG. Anyone who experiences or witnesses harassment is encouraged to report it. PMG will investigate all reports promptly and will not retaliate against anyone who raises a concern in good faith.

Professional conduct is expected at all times in interactions with PMG employees, clients, and third parties. This includes being available and punctual for scheduled engagements. If you need to reschedule or anticipate a delay, inform the primary consultant or your immediate manager as soon as possible so clients can be notified where necessary. PMG's reputation depends on the reliability of the people who represent it.

PMG personnel are not to be approached persistently or repeatedly regarding new engagement opportunities. PMG's team will make contact when an appropriate opportunity arises. PMG is under no obligation to provide engagement opportunities to any associate, and repeated unsolicited contact is not an acceptable way to pursue them.

PMG's hiring process is designed to be fair, transparent, and merit-based. Hiring decisions are not influenced by external pressure, internal lobbying, or financial incentives. Pre-employment assessments must not exceed two hours of a candidate's unpaid time.

6. Protecting Intellectual Property

PMG's methodologies, frameworks, tools, and systems represent significant investment and constitute proprietary intellectual property. All work created by PMG personnel using PMG resources belongs to PMG. This includes documents, analyses, models, software, and any other creative or analytical output developed in the course of an engagement.

Clients receive a perpetual licence to use work product delivered to them for their own internal business purposes. They do not receive ownership of the underlying IP. PMG's proprietary methodologies, trade secrets, and frameworks are not to be disclosed, reproduced for commercial gain, or transferred to any third party, whether by clients, personnel, or licensees.

The PMG name, logo, and marks may not be used without prior written authorisation from PMG management. Unauthorised use for personal, commercial, or promotional purposes is strictly prohibited.

PMG equally respects the intellectual property of others. Do not reproduce, distribute, or use third-party materials in a manner that infringes copyright or other IP rights. This applies to content used in client deliverables, internal tools, marketing materials, and any other PMG output.

7. Information Security & Data Handling

PMG's reputation depends on protecting the information entrusted to us. Every person acting on PMG's behalf is responsible for handling data in accordance with PMG's information security standards.

Client data is always treated as Highly Confidential. It must be stored within PMG's enterprise-managed cloud environment, encrypted in transit and at rest, and accessible only to those who need it for the specific engagement. It is never stored on personal devices or local hard drives.

Multi-factor authentication is mandatory on all PMG accounts without exception. Passwords must meet complexity requirements and be rotated every ninety days. Suspected security incidents such as lost devices, phishing attempts, accidental disclosures, and unauthorised access must be reported immediately to the Data Protection Officer at dpo@askpmg.com. PMG will not retaliate against anyone who reports an incident in good faith.

8. Responsible Use of AI

PMG uses AI tools to support consulting work across research, analysis, drafting, and ideation. All AI use is subject to PMG's approved platforms list and risk assessment framework. Tools not on that list require assessment before use.

AI does not make decisions, produce final recommendations, or act autonomously in any client engagement. Every deliverable that leaves PMG reflects the judgment of a human consultant, regardless of what tools contributed to its development.

Client data is never used to train or fine-tune AI models. Client data is never shared with AI platforms without explicit, documented consent. Where a task requires client data and adequate anonymisation is not achievable, AI processing is not used for that task.

Consultants are expected to critically evaluate AI-generated outputs, validate results, and override AI suggestions when their professional judgement requires it. AI is an instrument in the service of human expertise, not a substitute for it.

9. Modern Slavery & Human Rights

PMG is unconditionally opposed to forced labour, child labour, human trafficking, and all forms of modern slavery. This applies to PMG's own operations and to the third parties, suppliers, and subcontractors we work with.

If you encounter any situation in the course of your work that raises concerns about labour exploitation, human trafficking, or unsafe working conditions, whether within PMG's operations or at a client, supplier, or partner, you are expected to report it. Reports can be made through the Whistleblower & Speak-Up mechanism described below, directly to HR, or to the Data Protection Officer.

PMG complies with applicable modern slavery and human rights legislation across all jurisdictions in which it operates, including Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act, the UK Modern Slavery Act 2015, the Australian Modern Slavery Act 2018, and equivalent frameworks in every market where PMG is active.

10. Political Activity & Government Engagement

PMG does not make corporate political contributions of any kind, in cash or in kind, to any political party, candidate, campaign, or political action committee. This prohibition is absolute and applies globally.

When PMG provides advisory services to government clients or engages with public officials, heightened standards apply. All gifts and hospitality involving public officials require pre-approval regardless of value. Any engagement that involves advising on government procurement, regulatory outcomes, or policy decisions is subject to PMG's Political & Government Advisory Services Policy, which requires enhanced due diligence and explicit compliance review before the engagement commences.

PMG personnel are free to hold personal political views and to engage in lawful political activity on their own time and in their own capacity. They must not represent those views as PMG's, use PMG resources to advance them, or allow them to influence their professional work.

11. Speaking Up

PMG's ability to uphold this Code depends on people being willing to raise concerns when they see conduct that falls short of it. Speaking up is not just permitted. It is expected.

Concerns about misconduct, ethical violations, legal breaches, or policy violations can be reported through PMG's Whistleblower & Speak-Up mechanism. Reports can be made to the Ethics Officer at ethics@askpmg.com. Where the concern involves the Ethics Officer personally, reports go to legal@askpmg.com. Where the concern involves PMG's legal function, reports go to headsup@askpmg.com, which is accessible exclusively to PMG's executive leadership.

Reports can be made anonymously. PMG will consider all reports and investigate where sufficient information exists to do so. The identity of every reporter is treated as strictly confidential. PMG will not disclose a reporter's identity voluntarily under any circumstances.

Retaliation against anyone who makes a good-faith report is strictly prohibited. Any person found to have retaliated against a reporter will face disciplinary action up to and including termination. Retaliation is itself grounds for a report under this policy.

A report is made in good faith where a reasonable person, with the information available at the time, would have believed the concern was warranted. A report that turns out to be unsubstantiated is not a bad-faith report, provided it was not made maliciously or with knowledge that it was false.

12. Accountability

This Code does not replace PMG's detailed policies. It is an orientation to the values that underpin them. Where this Code and a specific policy address the same issue, the more specific policy governs.

Violations of this Code are taken seriously. Depending on severity and circumstance, consequences may include formal warnings, removal from an engagement, suspension, termination of employment or contract, and, where conduct constitutes a legal violation, referral to appropriate authorities.

PMG's Ethics Officer is responsible for administering this Code and for receiving questions about its application. Questions and concerns should be directed to ethics@askpmg.com.

This Code is reviewed annually. Material updates will be communicated to all PMG personnel.