Corporate
Compliance and Ethics
We hold ourselves to the standards of regulated industries, whether or not a given activity is regulated.
Compliance done well is invisible to the people who benefit from it. The day they have to think about it is the day it has already failed.
A principal, Kaelo Global
Compliance and ethics at Kaelo Global are handled as company-wide functions, with the same care whether or not the activity itself is regulated. The framework is written down, reviewed every year by the principals, and applied by the people who run the work, because separating the operating side from the compliance side is how both of them fail.
Kaelo Global compliance covers what a counterparty reasonably wants to see: a code of conduct, checks on the people and businesses we deal with, careful handling of personal data, and a confidential route for raising concerns. We would rather disclose more than leave a question hanging.
We are a small company, so the framework is deliberately simple and practical. Everything in it is something we actually do, and we say plainly when a question sits outside our licence and belongs with a lawyer or an auditor.
Code of conduct
A written code that applies across all our activities and is signed by the principals. It is reviewed every year, and breaches are dealt with in writing.
Anti-bribery and sanctions
Documented procedures, checks on counterparties appropriate to their country, and diligence on partners. We read the rules conservatively and disclose more rather than less.
Data protection
Personal data handled to the standards of the countries we work in, with internal training, documented retention periods and deletion on request.
A confidential reporting channel
A route for raising concerns that is reviewed separately from the people running the work. Reports are investigated in writing, and the findings are recorded.
Conflicts of interest
A written record of relationships that could create a conflict, disclosed to the client before work begins instead of after a problem appears.
Client confidentiality
Client material is kept to the people who need it, and we do not use a client's data, results or name without written permission.
How it is governed
The code, applied in practice
The code shapes how work is assigned and reviewed, instead of being a document signed once and filed away.
Checks before we contract
Anti-bribery, sanctions and money laundering checks on counterparties, with written limits on gifts and hospitality. The checks are recorded so they can be shown later.
Data protection in daily work
Personal data processed to the strictest standard that applies, with training for the team, documented retention and working routes for access and deletion requests. Our data protection page sets out the detail.
Raising a concern
A confidential channel reviewed independently of the operating team, with findings documented and corrective action followed through. The whistleblower policy explains how it works.
When to come to us
- 01You are a counterparty who needs documented evidence of how we handle compliance before contracting.
- 02You are a regulator or an auditor with a stated purpose for an inspection or a review.
- 03You are a partner whose own compliance rules require evidence from the businesses you work with.
- 04You are a member of staff, a supplier or a counterparty who needs to raise a concern confidentially.
What we do not do
- Treating compliance as a cost to be trimmed. The work is built into the budget instead of negotiated away.
- Arrangements that sit in a grey area. Every position we take is one we could explain in writing to an auditor.
- Retaliating against anyone who raises a concern in good faith. Retaliation is itself a breach of the framework.
- Publishing details of individual cases. Aggregate reporting stays in our internal annual review.
Regulated-industry standards, whether or not we are regulated.
We apply the same framework across every activity, instead of only where a regulator requires it. The discipline is built for the standard we want to keep, rather than for the minimum that happens to apply.
The same discipline the trade desk has always worked to.
The habits come from the textile trade, where a missed check or a loose term is felt quickly and in the same quarter. They carry into every other part of the business.
Governance & policies
We share full policy documents with counterparties and regulators on request. Internal governance papers are not published on this site, and if you need one for due diligence, please ask us.
Common questions
