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Business Ethics

Built on Integrity.
Driven by Accountability.

At Invictus, ethical conduct is our compass. As a publicly listed company operating across multiple jurisdictions and sectors, we earn trust by making the right choices, every time, everywhere. Our approach goes beyond words; it is reflected in our culture, governance, and daily operations.

Our Ethics & Compliance Program

Our Board sets the tone at the top, approving key policies and resourcing the compliance function. The Board Audit, Risk and Insider Trading Committee drives policy clarity, champions our Code of Conduct, and ensures executive accountability.

We maintain an enterprise-wide Ethics & Compliance Program, led by the Group Head of Compliance and overseen by the Board Audit, Risk and Insider Trading Committee. This program integrates risk-based policies, hands-on controls, continuous monitoring, and independent review to identify and address potential misconduct before it impacts our business or stakeholders.

Our Internal Audit function provides objective assessments of policy adherence and control effectiveness, reporting directly to the Audit, Risk and Insider Trading Committee

Key Program Components

Each area below is governed by clear policies, procedures, training, and oversight:

Code of Conduct

Sanctions Compliance

Data Privacy & Confidentiality

Insider Trading

Disclosure and Transparency

Anti-Fraud

Anti-Bribery & Corruption

AML/CFT & Third-Party Compliance

Conflict of Interest

Government Engagement

Speak Up

Securities Trading

Speak Up

We encourage everyone, employees, contractors, partners, to report concerns through our independent Speak Up platform. Available for everyone, it supports anonymous submissions and assures non-retaliation. Every report is handled with discretion, investigated promptly, and tracked via a secure reference number.
speak up Portal

Global Standards, Local Execution

We align with global frameworks, UK Bribery Act, U.S. FCPA, OECD Guidelines, Whistleblower Directives, while adapting controls to local regulations and cultural norms. This dual approach ensures consistent ethical standards and effective risk management in every market where we operate.

Awareness, Communication & Training

Awareness is critical. All employees undergo mandatory onboarding and refresher training on our Code of Conduct and core compliance topics. We reinforce learning through real-world case studies, briefings, and readily available support, making ethical decision-making part of daily routines.

Policy Centre & Downloads

For full details, our key ethics and compliance documents are publicly available:
Should you have questions or need further guidance, please contact our Ethics & Compliance team at compliance@Invictustrading.ae
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