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Code of Conduct


Reviewed March 2021

We are proud to operate to the highest professional and ethical standards in keeping with our Code Of Conduct below. Where other relevant codes apply, such as the ABPI and ABHI codes of practice, we also expect at least to meet their standards.

This Code applies to all employees of Newmarket Strategy Ltd. and also to agents acting alongside the company as part of a contractual or sub-contractual agreement in which the main contractor is Newmarket Strategy Ltd.


  • We will only work with reputable, bone fide organisations, whose identity and objectives are transparent.
  • We will not act for organisations whose policies or objectives are invidiously discriminatory, or that deliberately carry out illegal activities, or which are considered a threat to national security.
  • We will not advise on, or participate in, any activity that is illegal, offensive or defamatory. If we become aware of client activities that breach the law, we will bring this to the attention of the client and, if said activities continue, will cease to act for that client.
  • We will not make extravagant, exaggerated or inaccurate claims to clients about the nature and extent of our capabilities. Similarly, we will not make such claims on behalf of clients.
  • We will not claim to be able, or attempt, to provide special or privileged access to elected representatives or public officials under any circumstances.
  • We will always conduct ourselves in a professional manner. We will not offer any financial inducements or apply improper influence, either on our own or our clients’ behalf, and will act with due regard for the Nolan Principles for Standards in Public Life.
  • We will abide by all statutes and rules of the public and private institutions and buildings which we visit and complying with all reasonable requests of staff employed in those premises.
  • We will not compel any member of staff to work on an account that represents a major conflict with their personal, moral or religious beliefs.
  • We will comply with relevant codes of practice or regulations as these apply to clients, which are notified to us by clients and on which we are briefed by clients.


  • We will provide clients with accurate, factual, balanced, timely and relevant information that is verified and referenced wherever possible using its original source. Where information is unverified, this will be clearly identified.
  • We will use publicly available sources of information unless confidential information is voluntarily given and permission to use it is explicitly granted, in which case we will abide strictly by the terms of any such permission.
  • We will preserve the integrity of information we acquire; maintaining its state of confidentiality and respecting at all times the intellectual property and copyright of individuals and organisations.
  • The advice we provide to clients will be fair and balanced, including alternative options and interpretations to assist clients in making informed decisions.


  • We will conform to all legal requirements for transparency that are applicable in any country in which we are active, ensuring that all relevant staff are trained on such requirements.
  • We will not attempt to pass off the company or ourselves as being any other organisation, for the purpose of gaining access to an individual or organisation exerting influence on an individual or organisation or for any other purpose.
  • Only when there is a contractual agreement engaging the company (or member(s) of staff) to work for a client organisation in a specific seconded role, will staff state they are working for a client organisation. They will only do so on matters relating to this role.
  • We will not present ourselves in false roles to elicit information, obtain appointments or access individuals.
  • We comply with The Data Protection Act 2018 all other relevant data protection laws in the jurisdictions in which we operate.


  • We will report to a senior manager in the company all possible conflicts of interest as soon as possible.
  • We will not undertake to work with new clients where this work presents a clear conflict of interest to a current client for the duration of our contract.
  • Where a conflict of interest occurs, the member of staff will have no further contact with the client or the account. A declaration will normally be made to the client, with the involvement of the individual staff member concerned.
  • Where a conflict of interest occurs between two clients, we will either:
    • Seek informed permission in writing from all parties involved, only proceeding if all agree.
    • Resign from or cease to pursue one of the clients (depending on the circumstances).



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