Skip to Main Content
(Press Enter)

Committed to ethics, security and governance

Operating with a high degree of integrity and responsibility is a fundamental principle at Invesco. We hold ourselves to the highest standards of ethics, integrity and accountability in how we conduct and operate our business.

Our clients choose us because they trust our brand, our people and our performance. We earn their trust by ensuring that everything we do is reliable, consistent and executed with the highest level of quality, integrity and sound governance. This includes not only our ethical practices and uncompromising commitment to product and service compliance, but also how we handle client data and conduct our own affairs.

We lead ethical integrity, risk management and fair and honest business conduct through strong corporate governance, comprehensive business principles, adherence to all laws and regulations where we operate, and policies and data security tools that guide employees’ day-to-day activities.

Corporate governance

Commitment to stakeholder engagement

Invesco is committed to maintaining the highest standards of integrity and accountability in the stewardship of our affairs, and we recognize that proper and effective corporate governance is important to shareholders and other stakeholders. We have strong policies and standards, including Invesco’s comprehensive Code of Conduct, which is designed to safeguard the interests of Invesco’s clients, ensure compliance with applicable laws, and provide accountability and control systems commensurate with our firm’s business activities.

Invesco is governed by a Board of Directors that meets throughout the year and has three established standing committees: Audit, Compensation, and Nominating and Corporate Governance. Board members are elected by the shareholders to oversee our management team and ensure that the long-term interests of the shareholders are being served.

For more information on our global corporate governance structure and policies, please visit our website at

Consolidation and automation

In 2020, Invesco continued to improve governance over policies by addressing gaps and timeliness of policy reviews to ensure alignment with regulatory change frameworks and industry best practice. For example, we consolidated a series of policies, including but not limited to the Code of Ethics and global policies surrounding incident management, to ensure alignment of practices at group level.

Invesco also continued to enhance the efficiency and effectiveness of monitoring controls by onboarding additional automated surveillance tools and rolling out an integrated incident reporting system.

Professional integrity
and business ethics

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:

Department Name of course
  • Conflict of Interest Training—New in 2020
  • 2020 Global Required Compliance Training
  • Anti-Money Laundering and Counter-Terrorist Financing Training
  • Preventing Market Abuse Training
Human Resources
  • Fostering Diversity of Thought through Hiring Practices—New in 2020
  • No Excuses—Prevention of Sexual Harassment
  • Respect in the Workplace
Information Security
  • Privileged Access Training—New in 2020
  • Global Privacy Training
  • Global Security Annual Training

In addition, Invesco made progress to increase the effectiveness of conflict identification and management through reviewing the scope and escalation process of potential and effective conflicts, consolidating policies and establishing a new governance framework.