Kiroyan Partners is committed to maintaining independence, objectivity, and integrity in all advisory work. We recognize that conflicts of interest—whether actual, potential, or perceived—can undermine trust and compromise professional judgment.

This Policy establishes the principles and expectations for identifying, disclosing, and managing such situations.

Overview

A conflict of interest arises when personal, professional, or external interests interfere—or appear to interfere—with an individual’s ability to act in the best interest of clients or the firm.

Conflicts may take various forms, including:

  • Actual conflicts, where competing interests directly affect decision-making.
  • Potential conflicts, where a situation could develop into a conflict.
  • Perceived conflicts, where circumstances may reasonably give rise to concerns about objectivity.

All forms of conflict must be taken seriously and managed appropriately.

Our Commitment

We are committed to:

  • Maintaining independence and impartiality in all engagements.
  • Avoiding situations that compromise, or appear to compromise, professional judgment.
  • Acting in the best interest of clients while upholding the integrity of the firm.
  • Ensuring transparency in identifying and managing conflicts.

Our credibility as an advisory firm depends on consistent adherence to these principles.

Scope and Application

This Policy applies to all personnel of Kiroyan Partners, including partners, consultants, support staff, interns, and external experts engaged in our work.

It covers all professional activities, including:

  • Client engagements and advisory assignments.
  • Business development and project acquisition.
  • Interactions with government, stakeholders, and partners.
  • External roles or affiliations that may affect professional judgment.

Key Principles

Identification and Disclosure

All personnel are expected to proactively identify and disclose any actual, potential, or perceived conflicts of interest as soon as they arise.

This includes situations involving:

    • Personal or family relationships
    • Financial interests
    • Prior or concurrent engagements
    • External affiliations or advisory roles

Independence in Decision-Making

Individuals must not participate in decisions or activities where their objectivity may be compromised.

Where necessary, appropriate steps must be taken, including recusal or reassignment.

Client Conflict Management

Where potential conflicts arise between client interests, the firm will assess the situation carefully and determine appropriate safeguards.

This may include:

    • Limiting access to information.
    • Assigning separate teams.
    • Declining or withdrawing from engagements where conflicts cannot be effectively managed.

Use of Information and Assets

Confidential information obtained through professional work must not be used for personal advantage or disclosed without proper authorization.

Company resources and access must not be used to benefit personal, family, or affiliated interests.

Fairness and Integrity

All decisions must be made objectively and without favoritism. Preferential treatment, undisclosed relationships, or undue influence in recruitment, procurement, or project allocation are strictly prohibited.

Reporting and Management

Any conflict of interest—actual, potential, or perceived—must be reported promptly.

Reports may be made through:

  • Direct reporting to a supervisor, or
  • Established internal reporting mechanisms.

Once disclosed, the firm will assess and determine appropriate mitigation measures, which may include:

  • Disclosure to relevant stakeholders.
  • Recusal from specific activities.
  • Adjustment of roles or responsibilities.
  • Other safeguards as necessary.

Accountability

Failure to disclose or properly manage a conflict of interest may result in disciplinary action in accordance with applicable internal policies.

Governance and Alignment

This Policy should be read in conjunction with:

  • Code of Conduct
  • Anti-Bribery & Anti-Corruption
  • Whistleblowing & Reporting Mechanism

Further Information

This page provides a high-level overview of our Conflict of Interest Policy. Additional guidance may be provided internally or upon request, where appropriate.

For inquiries, please contact:
info@kiroyan-partners.com

Last updated: March 2026.

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