Code of Conduct

Every professional of the firm shall be straightforward and honest in all professional and business relationships. Misstatement, concealment of a material fact, or the dressing of a weak position as a strong one is a breach of this Code, whether the audience is a client, a counterparty, a regulator, or a court.

We do not assist a client to evade tax, to mislead a regulator, or to misrepresent the affairs of a company. Lawful tax planning is part of the practice. Evasion, false documentation, and backdating are not.

Advice is given on the evidence and the law, not on the outcome the client would prefer to hear. Where a course of action is available but unwise, or lawful but fragile, that is to be said plainly.

Independence of mind is required on every file. A professional who cannot be objective — because of a financial interest, a personal relationship, a prior instruction, or a threatened fee — shall recuse and shall say so.

Information acquired in the course of an enquiry, a pitch, or an engagement is confidential. It is not to be disclosed, used for personal advantage, or discussed in a place where it can be overheard. The duty survives the end of the instruction and the end of the professional’s association with the firm.

Disclosure is permitted only where the client has given informed consent, where the law or a competent court or regulator requires it, or where it is necessary to defend the firm against a professional complaint. In the last of those cases, disclosure is limited to what the defence requires.

Working papers, drafts, data rooms, and correspondence are to be stored and transmitted with care proportionate to their sensitivity. Client files are not to be left on unattended screens or in unsecured personal accounts.

A conflict exists where the firm’s duty to one client stands against its duty to another, or against the firm’s own interest, or where a professional’s personal interest may colour the advice.

Before a new matter is accepted, a conflicts check is to be completed. If a conflict is identified, the matter is declined unless, after full disclosure, each affected client gives informed written consent and the firm can still discharge its duties with integrity. Some conflicts cannot be waived. Those matters are declined.

Acting on both sides of a dispute, or on both sides of a transaction without informed consent and appropriate safeguards, is prohibited.

We accept only work we are competent to perform, or that we can perform by engaging, under proper supervision, a professional who is. A file is not a place to learn a discipline at the client’s risk.

Work is to be performed with the care a reasonably competent practitioner in the relevant discipline would exercise. Deadlines that cannot be met are to be raised before they are missed. Drafts that are not ready are not to be issued as if they were.

Where a matter requires a reserved legal act, it is handled by a licensed advocate. Where it requires financial computation, it is handled by the financial advisory team. The two are not to be blurred in a way that misleads the client or a forum about who is responsible.

The firm’s practice comprises financial and tax consultancy, corporate secretarial work, commercial and corporate legal counsel, dispute support, estate and succession work, family-office architecture, business research, and related advisory work, as described on this website and in the relevant engagement letter.

The firm does not undertake statutory audits, reviews, or other reserved assurance engagements. We will not hold ourselves out as auditors, nor will we issue an audit opinion or anything that could reasonably be mistaken for one.

The firm is not licensed by the SECP as an Investment Adviser, Asset Management Company, or Securities Manager. We do not take discretionary mandates over client securities, we do not operate a collective investment scheme, and we do not hold client money or securities except where the law and the engagement letter expressly permit a defined, identified sum. Portfolio implementation is referred to a licensed intermediary.

Where a client needs a service we do not provide, we say so and, where appropriate, refer. We do not stretch an engagement to cover a reserved function.

Within the law and this Code, the client’s legitimate interest comes first. That interest is not the same as every instruction the client may give. An instruction to do what we must not do is refused, with the reason stated.

Counterparties, employees, and public officials are to be dealt with courteously and accurately. Aggressive advocacy is not an excuse for a misleading letter or an abusive notice.

Fees are agreed in writing before substantive work begins, save for genuine emergency instructions which are regularised as soon as practicable. Proposals are milestone-driven. Estimates that will be exceeded are revised before the additional work is done.

We do not charge secret mark-ups on disbursements. We do not hold client money except where the law permits it, the engagement letter provides for it, and the funds can be identified and accounted for. Contingent fee arrangements that would compromise objectivity — including any arrangement that pays the firm to produce a predetermined tax or valuation outcome — are not accepted.

Professionals of the firm shall comply with the laws of Pakistan applicable to the work in hand, including the Companies Act, 2017, the Limited Liability Partnership Act, 2017, the Income Tax Ordinance, 2001, the Sales Tax Act, 1990, and the rules, circulars, and orders of the Securities and Exchange Commission of Pakistan and the Federal Board of Revenue, as they apply to the matter.

Advocates practising through the firm remain subject to the Pakistan Bar Council’s Canons of Professional Conduct and Etiquette. Members of other institutes remain subject to the codes of those institutes. The stricter rule applies.

Bribery, facilitation payments, and the offering or receiving of improper gifts or hospitality are prohibited, whether the recipient is a public official or a private person.

The firm will not accept an instruction where the source of funds cannot be reasonably understood, where the purpose of the structure is to conceal beneficial ownership, or where the matter appears designed to launder the proceeds of crime. Suspicious activity is to be escalated internally and, where the law requires, reported to the competent authority. Tipping-off is prohibited.

Know-your-client information is collected before, not after, a relationship of substance is formed. A client who will not identify themselves, their beneficial owners, or the nature of the matter is not taken on.

Letters, notices, pleadings, and filings go out in the firm’s name only when they have been reviewed by the professional responsible for the file. Informal messages are not a substitute for a position the firm may later have to defend.

Public commentary, including on social media, shall not disclose client information, shall not tout in a manner forbidden to the relevant profession, and shall not disparage a court, a regulator, or a counterpart. The firm’s name is not to be used in a personal publication without approval.

Nothing on the website or in marketing is a guarantee of result. Past matters are not cited in a way that identifies a client without consent.

Each matter has a file. The file records the instruction, the conflicts check, the advice given, the drafts issued, the client’s decisions, and the fees billed. Oral advice of consequence is confirmed in writing.

Working papers are retained for the period required by law and by the engagement letter, and are then disposed of securely. They are the firm’s records; the client is entitled to the deliverables contracted for and to such copies as the engagement or the law requires.

Partners are responsible for the quality of work issued in the firm’s name and for the conduct of those they supervise. Delegation does not discharge that responsibility.

Colleagues, clients, and visitors are to be treated with respect. Harassment, discrimination, and intimidation have no place in the practice. A professional who is unfit to work a file — through impairment, exhaustion, or any other cause — is to step back before the client is harmed.

Anyone in the firm who believes this Code, the law, or a professional rule is being breached is expected to raise it with a partner without delay. Good-faith reports are protected from retaliation.

Clients who have a concern about the firm’s conduct should put it in writing to the corporate desk. Complaints are recorded, considered, and answered. Where a professional regulator has jurisdiction, the client is not discouraged from using it.

A breach of this Code is a professional matter. Depending on its gravity it may result in supervision, removal from a file, termination of association with the firm, and, where required, a report to a regulator or to the client.

Ignorance of this Code is not a defence. It is issued to every person who acts for the firm and is available on the firm’s website.

This Code may be amended by the partners. The version published on the firm’s website is the current version. Material changes will be dated. Engagements already underway continue under the Code as it stood when the engagement letter was signed, except where a change is required by law.