TPI Capital Ltd is committed to maintaining appropriate standards of governance, accountability and professional conduct across all business activities.

The Director(s) has overall responsibility for:

• Establishing, implementing and reviewing company policies and procedures.
• Ensuring compliance with applicable legislation and professional obligations.
• Monitoring business performance and risk.
• Maintaining appropriate insurance, professional competence and business controls.
• Promoting ethical business practices and continual improvement.

All personnel, associates and subcontractors engaged by TPI Capital Ltd are expected to:

• Act professionally, ethically and with integrity.
• Comply with applicable laws, regulations and company policies.
• Maintain confidentiality where required.
• Report concerns, incidents or breaches promptly.
• Support the continual improvement of company processes and performance.

Policy compliance forms part of TPI’s overall governance arrangements and applies to all business activities undertaken on behalf of the company.

TPI Capital Ltd is committed to protecting personal data, confidential information and commercially sensitive information entrusted to it by clients, partners, suppliers and other stakeholders.

TPI recognises the importance of maintaining appropriate standards of data protection, privacy and information security and seeks to ensure that information is processed lawfully, fairly, securely and transparently.

TPI will:

• Comply with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and any successor legislation.
• Process personal data only where there is a lawful basis to do so.
• Collect and retain only information that is necessary for legitimate business purposes.
• Ensure personal data is accurate, relevant and kept up to date where reasonably practicable.
• Implement appropriate technical and organisational measures to protect information against unauthorised access, loss, disclosure, alteration or destruction.
• Restrict access to information on a need-to-know basis.
• Maintain appropriate password, device and access management controls.
• Promote secure handling, storage and transmission of information.
• Report, investigate and manage actual or suspected data breaches or security incidents.
• Ensure third parties handling information on behalf of TPI are subject to appropriate contractual and security arrangements where required.

TPI is committed to processing personal information fairly, transparently and in accordance with applicable legal requirements.

Information regarding the collection, use, sharing, retention and protection of personal data is set out in TPI’s Privacy Notice.

Personal data and business records will be retained as follows:

• For as long as necessary to fulfil the purposes for which they were collected, including legal, regulatory, contractual, accounting and business requirements.
• Retention periods may vary depending on the nature of the information and the purpose for which it is held.
• When information is no longer required, it will be securely deleted, destroyed or anonymised as appropriate.

All personnel, associates and subcontractors engaged by TPI are expected to:

• Protect confidential and sensitive information.
• Use company systems responsibly and securely.
• Prevent unauthorised access to information and devices.
• Report security concerns promptly.
• Comply with applicable data protection and information security requirements.

TPI will periodically review its data protection and information security arrangements to ensure they remain appropriate to the nature and scale of its operations.

TPI is committed to safeguarding the health, safety and wellbeing of employees, associates, clients, contractors and members of the public who may be affected by its activities.

TPI will:

• Comply with applicable health and safety legislation.
• Maintain safe systems of work.
• Identify and manage foreseeable risks.
• Promote safe working practices during office, home-working and site-based activities.
• Encourage the reporting of hazards, incidents and near misses.
• Review health and safety arrangements periodically.

All personnel are expected to take reasonable care of their own health and safety and that of others who may be affected by their actions.

TPI is committed to providing equality of opportunity and maintaining an inclusive and respectful working environment.

TPI will not unlawfully discriminate including on the basis of:

• Age
• Disability
• Gender
• Marriage
• Pregnancy
• Race
• Religion
• Sex

Recruitment, appointments and business decisions will be based on merit, competence, qualifications and business requirements.

Discrimination, harassment, bullying and victimisation will not be tolerated.

TPI recognises its responsibility to minimise the environmental impact of its operations and to promote sustainable practices wherever reasonably practicable.

TPI will:

• Comply with applicable environmental legislation.
• Reduce waste and unnecessary consumption of resources.
• Encourage digital working practices and minimise paper usage.
• Promote remote meetings and sustainable travel where appropriate.
• Consider environmental impacts when making business decisions.
• Seek continual improvement in environmental performance.

TPI maintains a zero-tolerance approach to bribery, corruption and unethical conduct.

TPI will not:

• Offer, promise or give bribes.
• Request or accept bribes.
• Make facilitation payments.
• Engage in corrupt business practices.
• Use third parties to undertake activities that would breach this policy.

Reasonable and proportionate business hospitality may be accepted or provided where lawful, transparent and appropriate.

Any concerns regarding bribery, corruption or unethical conduct should be reported to the Director immediately.

TPI opposes all forms of slavery, servitude, forced labour and human trafficking.

Although TPI is not currently required to publish a statement under Section 54 of the Modern Slavery Act 2015, the business supports the principles of the Act and seeks to operate responsibly and ethically.

TPI will:

• Operate a zero-tolerance approach to modern slavery.
• Seek to work with reputable suppliers and business partners.
• Avoid knowingly engaging with organisations involved in exploitative labour practices.
• Promote fair treatment and equal opportunity.

TPI is committed to delivering high-quality professional services that meet client requirements and industry standards.

TPI will:

• Deliver services using appropriate professional skill, care and diligence.
• Maintain effective communication with clients and stakeholders.
• Monitor performance and lessons learned.
• Encourage continuous improvement.
• Seek feedback to improve service delivery.
• Maintain appropriate professional qualifications and competence.

TPI Capital Ltd is committed to acting independently, impartially and in the best interests of its clients whilst maintaining the highest standards of professional conduct.

The company recognises that actual, potential or perceived conflicts of interest may arise during the course of business and seeks to identify and manage such situations appropriately.

TPI will:

• Take reasonable steps to identify actual, potential and perceived conflicts of interest.
• Maintain transparency with clients and stakeholders.
• Implement appropriate mitigation measures where conflicts arise.
• Decline appointments where conflicts cannot be adequately managed.
• Protect confidential information obtained through professional engagements.

Personnel, associates and subcontractors are required to:

• Disclose any conflict of interest as soon as it becomes known.
• Avoid situations where personal interests may improperly influence professional judgement.
• Maintain confidentiality and professional integrity at all times.
• Comply with applicable professional codes of conduct.

Where a conflict is identified, the Director will determine appropriate mitigation measures which may include disclosure, management arrangements, restricted involvement or withdrawal from an appointment.

TPI Capital Ltd seeks to engage competent, qualified and reputable personnel, associates and specialist consultants.

Prior to appointment, TPI may undertake reasonable due diligence appropriate to the nature of the services being provided.

Such due diligence may include:

• Verification of qualifications and professional memberships.
• Review of relevant experience and competence.
• Confirmation of professional indemnity and other relevant insurance.
• Review of references, recommendations or previous project performance.
• Assessment of capability, capacity and suitability for the proposed role.
• Verification of compliance with applicable legal and professional requirements.

TPI expects associates and subconsultants to:

• Operate in accordance with applicable laws and regulations.
• Maintain appropriate professional standards.
• Act ethically and professionally.
• Support the principles contained within this Corporate Policies & Compliance Manual.

The level of due diligence undertaken will be proportionate to the nature, value and risk profile of the appointment.

TPI Capital Ltd recognises that effective risk management is essential to the successful delivery of professional services.

The company seeks to identify, assess, manage and monitor risks associated with its business activities, projects, appointments and operational arrangements.

Key risk categories may include:

• Health and safety risks.
• Commercial and financial risks.
• Programme and delivery risks.
• Legal and contractual risks.
• Information security and data protection risks.
• Reputational risks.
• Supply chain and subcontractor risks.

TPI will:

• Consider risks during project planning and delivery.
• Implement proportionate mitigation measures where appropriate.
• Monitor significant risks throughout the duration of appointments.
• Escalate material risks where necessary.
• Review lessons learned to support continual improvement.

Risk management is embedded within decision-making processes and forms part of TPI’s overall governance and quality arrangements.

TPI Capital Ltd recognises its duty of care to employees, associates, clients, project stakeholders and members of the public who may be affected by its activities.

The company is committed to taking reasonable steps to safeguard the wellbeing, security and welfare of personnel and to protecting information, assets and business operations from foreseeable risks.

TPI will:

• Consider health, safety and security risks when planning and delivering services.
• Promote safe working practices during office, home-working and site-based activities.
• Ensure personnel are aware of their responsibilities regarding personal safety and security.
• Encourage the reporting of incidents, hazards, security concerns and near misses.
• Take reasonable measures to protect confidential, personal and commercially sensitive information.
• Maintain appropriate arrangements for business continuity and resilience.
• Seek to ensure that associates, suppliers and subcontractors operate in a safe and responsible manner.
• Review incidents and lessons learned to support continual improvement.

All personnel engaged by TPI are expected to:

• Take reasonable care for their own safety and that of others.
• Comply with applicable health, safety and security requirements.
• Report concerns promptly.
• Act responsibly when handling company, client and project information.

TPI will review its duty of care and security arrangements periodically to ensure they remain appropriate to the nature and scale of its activities.

This document will be reviewed periodically and updated as required to reflect changes in legislation, business operations and best practice.

Last updated: May 2026