Acowalian Code of Conduct

Acowalian Code: Introduction

The Acowalian Code is a fundamental set of rules defining how we conduct our business with the highest integrity and ethics. The Code, which applies to all Acowale entities, supplements and in many cases goes well beyond what is required to comply with laws and regulations. The Code has been prepared to help you succeed at work. Acowale’s continued success with shareholders, customers, governments, and partners around the world depends upon your understanding of and ability to follow the Code in all of your business dealings.

From time to time, Acowale will revise the Code. If you have questions on how to interpret or comply with the Code, Acowale policies, or applicable law, contact a member of the Acowale Legal Department.
The Acowale Code applies to all personnel employed by or engaged to provide services to Acowale, including, but not limited to, Acowale’s employees, officers, temporary employees, workers (including agency workers), casual staff, and independent contractors (for ease of reference throughout this Code, all will be referred to as “employees” or “acowalers”). 

Employment by Acowale is subject to the terms and conditions established by your local organization. As part of those terms and conditions, you are also required to abide by the global standards set forth in this Code. If any part of this Code conflicts with local law, local law must be followed.

On the other hand, if a local business practice conflicts with our Code, you must follow our Code. In those instances where Acowale’s Code is stricter than local law, you must follow our Code. If at any time, a part of the Code is determined under local law, by a competent government authority, to be invalid, enforceability of its other provisions shall not be affected. Acowale may interpret the Code at its sole discretion.

Only the Board of Directors can waive a provision of the Code. Any waiver and the reason for the waiver will be promptly disclosed to Acowale’s stockholders.

Acowale Code

We expect all of our employees and Board members to know and follow the Acowale Code. Failure to do so can result in disciplinary action, including termination of employment. Moreover, while the Code is specifically written for Acowale employees and Board members, we expect Acowale contractors, consultants, contingent workers and others who may be temporarily assigned to perform work or services for Acowale to follow the Code in connection with their work for us. 

Failure of a Acowale contractor or consultant or other covered service provider to follow the Code can result in termination of their relationship with Acowale and group companies.


We are honest and choose the path of integrity in all business transactions and dealings with others


We act ethically in every business context


We comply with all laws, regulations, and Acowale policies that govern our business and employees’ actions on behalf of the company

Mutual Respect

We treat individuals with respect and dignity


We work together as a team to benefit Acowale


We share information effectively with each other, but also know how to protect the confidentiality of our information


We innovate and seek new and creative approaches to problem solving

Customer Satisfaction

We treat customer satisfaction as a top priority


We incorporate excellence and quality in our work and strive to continuously improve


We deal fairly with customers, suppliers, partners, and colleagues

Your Role: For Employees, Interns and Others:

All Acowalers are required to:

  • Act in accordance with Acowalian principles and follow the requirements of this Code    and Company policies. 
  • Act lawfully, honestly, ethically and in the best interests of Acowale and our Acowale users at all times. 
  • Complete required training, use the Code of Conduct and speak up when you have a question or concern. 
  • Cooperate with Company investigations. 
  • Never retaliate against anyone who raises a concern in good faith about a possible violation of the Code, Acowale policies or the law, or who cooperates in an investigation.
  • Lead by example, recognising that our behaviours and decisions influence others, including by championing the importance of abiding by the Code of Conduct and Company policies.
  • Promote a positive work environment in which everyone feels included and empowered to do the right thing and speak up when they have ideas or concerns – this means listening to questions and concerns and escalating when needed.
  • Promptly report potential or known violations of the law, this Code or Company policies to Legal.

Your Role: For Managers

Managers at Acowale must be leaders in compliance and ethics. Managers must serve as role models for understanding and explaining the rules and demonstrating integrity at all times. Managers must encourage the reporting of compliance issues and create environments in which employees know they can and should raise concerns without fear of retaliation. Managers must

  • Learn the Code and use it to onboard new employees and explain to teams, on a routine basis, how it applies to their line of business
  • Demonstrate through actions that you always choose integrity
  • Ensure that employees who report to you, either directly or indirectly, complete all mandatory compliance education courses and other Acowale Compliance and Ethics Program requirements in a timely manner
  • Ensure that employees who report to you, either directly or indirectly, understand where and how to report compliance concerns
  • Maintain an open-door policy that encourages employees to ask questions, including those related to business conduct and ethics
  • Encourage employees to challenge and report questionable conduct
  • Create an environment in which employees understand and believe that they may raise and report compliance concerns without fear of retaliation
  • Managers should consider an employee’s completion of compliance trainings and ethical behavior and/or violations when determining whether to promote or affect the compensation of the employees they manage
  • Managers that approve expenditures for meals, refreshments, or entertainment must use discretion and care to ensure that these events are reasonable and modest in cost, not lavish or extravagant, justified by a legitimate business purpose, and not offered improperly to influence the recipients’ business judgment

Questions & Concerns:

Speak Up

Code-Related Questions or Concerns

Acowale is committed to being a world-class company that enjoys the confidence of thousands of entities and individuals around the globe. To continue to do so, we need to understand whether problems exist with our personnel, business, or operations so that we can resolve issues promptly, take corrective action, or make needed improvements. We provide multiple resources for reporting allegations of misconduct, which Acowale will review or investigate as appropriate and, if justified, implement disciplinary actions or other remedies. As an Acowale employee, you are expected to report promptly any conduct that you believe in good faith may be a violation of the Code, as well as any other activities indicating a lack of compliance with Acowale’s or our employees’ legal or ethical obligations. Acowale will not tolerate retaliation against any employee who reports a concern in good faith or cooperates with a compliance investigation, even when allegations are not substantiated.

Options for reporting concerns or allegations of misconduct include: Your manager, Acowale People Ops Department,
A member of the Legal team, Your Regional Compliance and Ethics Officer, The Chief Compliance and Ethics Officer, Your employee representative (where applicable)
The Acowale Integrity Helpline: If you wish to remain anonymous, feel uncomfortable reporting a concern to your manager, Acowale People Ops Department, a member of the Legal team, a member of the Acowale Compliance and Ethics team, or feel that your concern has not been addressed properly, you should mail the CEO’s personal mail at You should provide as much detail as possible when raising a concern, including the parties involved, relevant dates, and specific conduct at issue. Due to confidentiality and other reasons, CEO’s office generally does not disclose the specifics of any internal investigation, but you may be able to contact to learn whether an investigation has been closed.