Primacy Consulting Group
Legal · 04

Anti-bribery and corruption.

Last updated: 1 March 2026

PCG operates under a strict zero-tolerance position on bribery and corruption, in line with the UK Bribery Act 2010 and equivalent regulations in the markets in which we work.

Our commitment

  • We do not offer, give, solicit or accept any improper financial or other advantage.
  • Facilitation payments are prohibited, regardless of local practice.
  • Gifts and hospitality must be modest, transparent and recorded.
  • We decline mandates where we are not satisfied a counterparty operates to comparable standards.

Diligence

Counterparty diligence is built into every engagement involving emerging-market exposure. Where on-the-ground intermediaries are used, we apply enhanced screening and require contractual anti-bribery undertakings.

Training and reporting

All partners and senior advisors receive periodic anti-bribery training. Concerns can be raised in confidence to ethics@the-pcg.co.uk without fear of detriment.

Governance

Compliance with this policy is overseen by the Partner responsible for Risk and Compliance, reporting to the board.