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.
Words are not enough. We earn trust the same way we build value — by making the right choices, every time and everywhere we operate.
Doing the right thing, everywhere we operate
At Invictus, how we achieve our results matters as much as the results themselves. Our reputation is built on a simple principle: we do the right thing, even when no one is watching.
As a publicly listed company operating across multiple jurisdictions and sectors, integrity is not a department — it is the responsibility of every person who represents Invictus, from the Board to our newest colleague. I expect each of us to know our Code of Conduct, to speak up without fear when something isn’t right, and to treat our partners, communities and one another with honesty and respect.
I give you my personal commitment that concerns raised in good faith will be heard, protected and acted upon. That is how we earn — and keep — the trust of our shareholders, our partners and the markets we serve.
Governance that starts at the top
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 program, led by the Group Head of Compliance, that integrates risk-based policies, hands-on controls, continuous monitoring, and independent review — identifying and addressing 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.
Board of Directors
Sets the tone at the top, approves policies, resources the function.
Audit, Risk & Insider Trading Committee
Independent board-level oversight of the entire program.
Group Head of Compliance
Leads design, rollout, monitoring and enforcement across the group.
Internal Audit
Objective assurance on adherence and control effectiveness.
Explore our compliance framework
Each area below is governed by clear policies, procedures, training and oversight. Select a pillar to explore its policies and download the documents.
Speaking up & ethical culture
The foundation of how we behave, decide and treat one another — and the safe channels to raise concerns.
Anti-financial crime
Zero tolerance for bribery, fraud and money-laundering — with controls that extend to the partners we work with.
AML/CFT & Third-Party Compliance
Anti-money-laundering, terrorist-financing and partner due diligence.
Download PDFSanctions Compliance
Screening and controls to honour global sanctions regimes.
Policy in effectMarket integrity & disclosure
Protecting market integrity and ensuring accurate, timely and fair disclosure to all stakeholders.
Insider Trading
Protecting market integrity and material non-public information.
Policy in effectSecurities Trading
Rules governing how we and our people trade securities.
Policy in effectData & government engagement
Safeguarding information and engaging with public officials in a principled, transparent way.
Data Privacy & Confidentiality
Safeguarding personal data and confidential information.
Policy in effectSee something? Say something.
We will listen.
We encourage everyone — employees, contractors and 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.
Scan to Speak Up
Point your phone camera at the code to open the secure portal.
Raise it
Submit online or by phone — anonymously if you prefer, in your own language.
Get a reference
Receive a secure case number to follow up and respond confidentially.
We investigate
Trained specialists review every report with discretion and independence.
We act
Findings drive corrective action. You are protected throughout — always.
Integrity is everyone’s responsibility — from the boardroom to every desk, in every market we serve.
Aligned to the world's leading frameworks
We align with global frameworks while adapting controls to local regulations and cultural norms — ensuring consistent ethical standards and effective risk management in every market where we operate.
One code, consistently applied. Where local requirements set a higher bar, the stricter standard governs our conduct.
Compliance built into daily routines
Awareness is critical. We make ethical decision-making part of how the company works, every day.
Mandatory onboarding
FlipEvery new joiner is trained on our Code of Conduct and core compliance topics — so doing the right thing starts before the first deal is ever done.
Refresher training
FlipRegular refreshers keep standards current as regulations and risks evolve — our knowledge moves as fast as our markets.
Case studies & briefings
FlipReal scenarios from our own markets turn policy into judgment — practising the hard calls before they become real ones.
Always-on guidance
FlipOur Code, policies and the Compliance team are one message away — asking early is always the right call.
Your compass for responsible decision-making
When faced with tough choices or grey areas, ask yourself these five questions — try it:
Questions or need further guidance?
Should you have questions about our policies or program, please contact our Ethics & Compliance team. For confidential concerns, use the Speak Up platform above.
compliance@invictustrading.ae