When it comes to professional integrity, we take a client- and employee-first approach. In practice, this means that our clients’ interests must always come first and that all officers and other employees of Invesco and its subsidiaries should treat each other with respect and consideration. Together, these beliefs are a vital part of how we achieve our principal responsibility as a publicly held company: producing a fair return on our shareholders’ capital.
Our principles for managing any conflicts of interest, financial crime (including fraud, bribery and corruption), which are in accordance with regulatory principles, are outlined in the following guidelines, among others:
- Code of Conduct
- Director’s Code of Conduct
- Code of Ethics
- Global Financial Crime Prevention Policy
- Global Fraud Escalation Policy
- Global Anti-Bribery and Corruption Policy
- Global Gifts and Entertainment Policy
- Global Outside Business Activities Policy
Guiding our professional integrity are our Code of Conduct and Code of Ethics, which apply to all employees and officers of Invesco and its subsidiaries. The policies, standards and general principles in the Code of Conduct and Code of Ethics are designed to help define the expected conduct of an Invesco representative.
Our Code of Conduct contains our policies and standards, and drives our commitment to business ethics, professional integrity and compliance. It sets out essential, guiding principles for workplace conduct, compliance with applicable laws and regulations, anti-discrimination and protection of Invesco’s assets, among other standards and expectations.
Our Code of Conduct outlines our expectations of everyone at Invesco and our policies and standards against discrimination and sexual harassment, which encourage the reporting of all incidents of discrimination, harassment or retaliation, regardless of the offender’s identity or position. Any employee who engages in harassment or discrimination will be subject to disciplinary action, up to and including termination of employment.
Our Global Financial Crime Governance Committee is chaired jointly by our Chief Financial Officer and Global Assurance Officer and includes representation from a regional and functional lead. This Committee oversees financial crime, fraud, anti-corruption and anti-bribery programs and ensures that policies are actively followed.
We also provide all internal and external stakeholders with a mechanism for seeking advice and reporting concerns and violations via the Invesco Whistleblower website and a toll-free Compliance Reporting Line. It is an anonymous, independent, confidential mechanism for reporting complaints or concerns pertaining to questionable accounting, internal accounting controls or auditing matters and possible violations of the company’s Code of Conduct or law. Our Compliance Reporting Line allows employees and external stakeholders to act on managing risk and unethical behavior on behalf of Invesco.
Business ethics training
All employees, officers and directors are required to take mandatory trainings annually, covering such topics as Security, Market Abuse, Code of Ethics, Anti-Money Laundering and other key conduct subjects. Compulsory Anti-Bribery and Corruption (ABC) and Fraud Prevention trainings are mandatory and administered every other year.
We also offer a series of nonmandatory trainings focused on ethical conduct through professional training and development channels.
In 2020, Invesco’s compliance team engaged with senior management to consider new initiatives to promote and embed a good conduct mindset, where all employees can demonstrate the ability to identify conflict and conduct issues and act accordingly, especially in the new working environment brought on by the COVID-19 pandemic.
In addition to our standard trainings, Invesco rolled out additional trainings, with a focus on scenario-based instruction that increases awareness of good conduct principles:
