The Charter sets our principles. This Code sets the rules that put those principles into operation. It binds every partner, employee, contractor, and divisional officer of UG UAE and its subsidiaries. Field Operations, Defense Technology, UG Cortex, and Intelligence Advisory & Investigations.

We do not aspire to these standards. We hold them. Personnel who cannot meet them do not work here.

01.1. Code of Conduct

Integrity. We tell clients, regulators, and colleagues the truth, including when the truth is inconvenient. We do not embellish capability, falsify records, or sign off on work we have not done.

Accountability. Every action taken under the firm's name is attributable to a named operator and a named approver. Mistakes are reported the same day they are discovered. We do not bury, delay, or distribute blame.

Confidentiality. Client information is held to the standard of the most sensitive item in the file. We do not discuss engagements outside the engagement. Disclosure occurs only where compelled by lawful order or expressly authorized in writing by the client.

Proportionality. Force, surveillance, and intelligence collection are calibrated to the threat. We use the minimum capability required to achieve the lawful objective. Excess is a failure of planning, not a sign of resolve.

Lawful Conduct. We operate under the laws of the jurisdiction of operation, the laws governing the contracting party, and applicable international humanitarian and human rights law. Where these conflict, the stricter standard governs. Personnel are not authorized to break the law on the firm's behalf, and no instruction from a client or supervisor lifts that prohibition.

Treatment of Non-Combatants. Civilians, medical personnel, journalists, and humanitarian workers are protected at all times. We do not target them, we do not use them as cover, and we plan operations to remove them from harm before action commences. Collateral risk is documented and reviewed before execution, not after.

Treatment of Detainees. Persons taken into custody during a security engagement are handed to lawful authority without delay. We do not interrogate, restrain beyond the period required for transfer, or transport detainees outside their jurisdiction of detention. Torture, cruel, inhuman, or degrading treatment is absolutely prohibited and not subject to client waiver.

Treatment of Clients. We give clients direct counsel, including counsel they did not ask for. We decline instructions that breach this Code. We do not bill for hours not worked or capabilities not delivered. When an engagement is failing, we say so.

Treatment of Colleagues. Harassment, discrimination, and retaliation have no place in this firm. Disagreement is encouraged; personal attack is not. Senior personnel hold the higher duty of care toward junior personnel, and that duty is enforced, not assumed.

Treatment of Competitors. We compete on capability, not on disparagement. We do not solicit confidential information from competitor personnel, place persons inside competitor firms for intelligence purposes, or pursue legal action calculated to bleed a competitor rather than resolve a dispute.

02.2. Conflict of Interest Policy

Declarations. Every employee files a personal interests declaration on hiring, on annual review, and within fourteen days of any material change. Declarations cover financial holdings above USD 25,000 in any single instrument, board or advisory positions, immediate family employment relevant to firm engagements, and political office or party position. Declarations are reviewed by the General Counsel and the External Ethics Chair.

Recusal. Personnel recuse themselves from any engagement where a declared interest, a family relationship, or a prior professional relationship creates an actual or perceived conflict. Recusal is documented in the engagement file. The recused individual receives no engagement information thereafter; access controls are enforced at the system level via UG Cortex.

Gifts. Cash gifts are prohibited in any amount. Non-cash gifts above USD 250 in nominal value are prohibited. Gifts at or below the threshold are logged in the firm gift register within seven days of receipt and may be retained, donated, or returned at the General Counsel's direction. Hospitality incidental to ordinary business meetings is exempt from logging up to USD 500 per occurrence.

Outside Engagements. No employee accepts external paid work, board seat, or advisory position without prior written approval. Approval is denied where the outside engagement competes with the firm, draws on firm-confidential information, or creates client-side conflict. Pro bono work for charities, academic teaching, and authorship are presumptively approved subject to disclosure.

Post-Employment Restrictions. For twelve months after departure, former personnel do not solicit firm clients, recruit firm personnel, or take engagements that rely on firm-confidential methodology. For twenty-four months, former personnel do not accept employment with any party against whom they ran a firm engagement of intelligence or investigative character. These restrictions are enforced by the firm and survive termination of any individual employment agreement.

03.3. Categorical Client and Engagement Exclusions

We do not list clients we have refused. We list categories. The categories below are absolute, they are not subject to negotiation, fee adjustment, or executive override.

We do not engage with:

  • Sanctioned entities or individuals on the lists maintained by the United States Office of Foreign Assets Control, the European Union, or the United Kingdom HM Treasury, or beneficial owners of such entities.
  • Operations directed against civilian populations, including kinetic action, intimidation, surveillance for the purpose of suppression, or information operations designed to provoke civil violence.
  • State actors seeking capability to deploy against their own civilian population, regardless of how the request is framed in domestic legal terms.
  • Any engagement that would compromise an existing firm engagement, whether by dual representation, by exposure of methodology, or by creating an obligation incompatible with prior commitments.
  • Engagements where lawful jurisdiction over the operating area, the client, and the firm cannot be jointly established and documented before the engagement begins.
  • Engagements involving weapons of mass effect, chemical, biological, radiological, nuclear, or area-effect munitions, directed at population centers, civilian infrastructure, or any target where civilian harm is the intended or substantially likely outcome.
  • Engagements that require the firm to deceive regulators, auditors, courts, or lawful investigative authorities, including by fabricating records, structuring transactions to evade reporting, or providing cover identities for the purpose of misleading public officials.

A request that falls into any category above is declined in writing by the General Counsel. The decline is logged. The request is reviewed by the External Ethics Chair on the next quarterly cycle.

04.4. Grievance Mechanism

Internal Channel. Any employee may raise a concern with their direct supervisor, with the General Counsel, or, for matters concerning either of those parties, directly with the External Ethics Chair. Concerns may be raised verbally; the firm reduces them to writing on the employee's behalf.

Anonymous Channel. A confidential reporting line is operated by an independent third-party intake provider, accessible by web, telephone, and encrypted message. Reports are forwarded to the General Counsel and the External Ethics Chair without identifying the reporter. Where the reporter elects to be identified, identity is held in restricted access and disclosed only with the reporter's consent.

External Channel. Affected non-employees, clients, vendors, persons in the area of operation, members of the public, may submit a concern through the same anonymous channel or by direct correspondence to the External Ethics Chair. The address of record is published on the firm's public site.

Investigation. Reports are acknowledged within five business days. Investigation is conducted by personnel with no reporting line to the subject of the complaint. Investigations involving senior officers, division heads, or matters above USD 1 million in firm exposure are conducted by external counsel on direct retainer to the External Ethics Chair. Findings are documented, reasoned, and shared with the reporter to the extent permitted by law.

Protection from Retaliation. Retaliation against a person who has raised a concern in good faith is itself a terminable offense. This protection extends to good-faith reports later found to be unsubstantiated. The protection does not extend to reports made in bad faith with intent to harm a colleague's reputation.

External Escalation. Where a reporter believes the internal process has failed, the report may be escalated to the External Ethics Chair directly, to the relevant national regulator of the jurisdiction in question, or, for security-sector concerns, to the International Code of Conduct Association's complaints mechanism. The firm does not condition continued employment, contracting status, or settlement on any waiver of the right to external escalation.

05.5. External Ethics Chair

Role. The External Ethics Chair is an independent senior figure appointed to oversee the firm's ethical conduct. Eligible candidates are retired senior judges, former regulators of financial, defense, or intelligence sectors, or recognized academic ethicists with operational sector experience.

Selection. The Chair is selected by the firm's Managing Partners on recommendation of an independent search committee, ratified by unanimous vote of the partnership, and confirmed for a fixed three-year term renewable once. The Chair is not a current or former employee, contractor, client, or material counter-party of the firm. Compensation is fixed at appointment, paid on a flat retainer, and is not contingent on firm performance, engagement volume, or any individual matter.

Authority. The Chair receives all materials submitted under the grievance mechanism, all logged refusals under the categorical exclusions, all annual conflict declarations, and unredacted access to engagement files on request. The Chair has authority to direct further investigation, to require recusal of any individual including a Managing Partner, and to refer a matter to external counsel or to a competent authority. The Chair may publish a dissent in the annual ethics report without firm pre-approval.

Removal. The Chair may be removed during a term only for documented incapacity, conviction of a serious offense, or a finding of conflict undisclosed at appointment. Removal requires unanimous partnership vote and is itself disclosed in the next annual ethics report.

Current Appointment. The External Ethics Chair is appointed by the partnership. The identity of the current Chair is disclosed to counterparties on request and recorded in the firm's annual ethics report.

06.6. ICoCA Membership

UG UAE, in respect of its Field Operations and Defense Technology divisions providing private security services, intends to operate consistently with the International Code of Conduct for Private Security Service Providers and to maintain membership in the International Code of Conduct Association (ICoCA). The firm's current ICoCA membership status is confirmed to counterparties on request.

We comply with the Code's substantive obligations, on use of force, treatment of detained persons, prohibition of torture, anti-trafficking, anti-corruption, and grievance handling, irrespective of formal membership status, and we accept the ICoCA grievance mechanism as a legitimate external escalation path for affected persons.

07.7. Reporting and Audit

Annual Ethics Report. The firm publishes an annual ethics report on or before 31 March of each year, covering the prior calendar year. The report is signed by the Managing Partners and the External Ethics Chair and is published in full on the firm's public site.

Contents. The report discloses, at minimum: the count and category of engagements declined under the categorical exclusions; the count and disposition of grievances received through each channel; the number of disciplinary actions concluded, by category and outcome; conflict declarations received and recusals enforced; gift register summary; and any material incident in the field involving non-combatants, detainees, or use of force.

Public Summary. A public summary accompanies the full report and is written for non-specialist readers. It does not name clients, engagements, or individuals. It discloses categories, counts, and the Chair's commentary in full.

External Audit. The annual report and the underlying records are audited by external counsel of recognized standing, retained directly by the External Ethics Chair, on a rotation no longer than five years per firm. The auditor has unredacted access to the records audited and reports its findings to the Chair, the Managing Partners, and, where the auditor identifies a material breach, to the relevant regulator.

Methodology Audit. Separate from the ethics report, the firm commissions a triennial independent review of operational methodology against this Code. The reviewer is a retired senior officer of a competent state authority with no current commercial relationship to the firm. The review's executive summary is published; the technical body is held confidential to protect operational security and is shared with the External Ethics Chair in full.

It is done. Anytime. Anywhere. Within these limits, without exception.