Independence on the page.
We accept no work where independence of judgement cannot be maintained. We disclose every relationship that could shape a recommendation on the cover sheet of the engagement, before the file opens.
A.01 / Pledge
Ethics is the filethe rest of the firmis built on top of.
A short, declarative pledge. Six commitments, a written list of mandates we refuse, and the protocol we follow when a conflict surfaces.
02 / Commitments
Six commitments.Signed on the cover.Held to without footnote.
These are not aspirations. They are the conditions under which Lequent will accept and continue to hold a file. A breach is a withdrawal event.
06 pledges2 × 3
Counsel before commerce.
We name the answer we believe is correct before we name the answer that is commercially convenient. If the two diverge, we say so in writing and we keep the receipt.
No file we cannot defend.
We decline mandates we cannot defend in public if they reached public scrutiny. The standard is not legality. The standard is whether we would explain ourselves on the front page without hedging.
Confidentiality is the floor.
The floor under every conversation, before the NDA is signed. The Non-Disclosure Policy describes how information is held; this pledge guarantees that the policy is observed.
No trade on what is on our desk.
No member of the firm trades in the securities or instruments of an entity on whose file we are retained, for the duration of the engagement and for thirty trading days after the information is public.
Public memory.
When a finding stops being decisive for an active mandate, it is published in the Observatory. We do not hoard intelligence to extend a billable life. We retire it into the record.
03 / Refusal
The list of fileswe will not open.
A short list, kept short on purpose. Each entry was written in response to a real mandate we declined. The list is reviewed annually and lengthens only when reality requires it.
- R.01Mandates whose only outcome is regulatory capture against the public interest.
- R.02Mandates whose visible client is a front for an undisclosed principal we cannot vet.
- R.03Mandates that require the firm to deceive a regulator, a counterparty, or a court.
- R.04Mandates that require us to act for both sides without a written waiver and aligned files.
- R.05Mandates in sectors barred under our sanctions screening, full list available on request.
04 / Protocol
Conflicts are nota management problem.They are a refusal.
The protocol below applies to every prospective and active engagement. It is run by the file principal, not by a separate compliance function downstream of the work.
Pre-engagement screen.
Every prospective file is screened against the engagement register before a first substantive conversation. Hits stop the conversation until they are resolved on the record.
Disclosed, not managed.
Conflicts that survive the screen are disclosed on the cover sheet. Silence is not neutrality. If a disclosure would itself breach a duty, the firm declines.
Information barriers fail.
We do not rely on Chinese walls inside a small firm. Where information would have to be partitioned, we decline the second mandate or we exit the first.
Withdrawal is unconditional.
A conflict that surfaces mid-engagement requires withdrawal. We do not litigate the threshold; we withdraw and we explain.
05 / Whistle
If we have failed,tell us in writing.
A direct channel to the firm principal. Anonymous reports are accepted; identified reports are answered within five working days. Retaliation against a reporter is itself a withdrawal event.
Channel
- W.01Identified reportethics@lequent.com
- W.02Anonymous postCasella postale 01, 20121 Milano
- W.03In personBy appointment, with counsel of your choice present
- W.04RegulatorGarante · CNF · CNDCEC, where appropriate
Reports are logged on a register held by the principal. Reports concerning the principal are routed to the supervisory board named in the engagement letter.
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05 / Engage
Let's get to knoweach other.
Every collaboration starts with a conversation. No agenda, no pitch — just two parties comparing what they see from where they stand. If you're building something interesting, we want to hear about it.
Or join the Observatory
A signal cut from active files. Insights, mandates and tools — published the day they stop being load-bearing for an engagement. No promotion, no tracking pixels, no schedule.
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