Code of Conduct

Last Updated: September 2018

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    The successful business operation and reputation of Rakoma & Associates is built upon the principles of fair dealing and ethical conduct of our Employees. Rakoma & Associates' reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations, as well as a scrupulous regard for the highest standards of conduct and personal integrity. Rakoma & Associates' commitment to a policy of fair dealing and integrity in the conduct of their business is actively endorsed by the Directors of Rakoma & Associates Inc. and is based on a fundamental belief that business should be conducted honestly, fairly, and legally.

    Our continued success is dependent upon our customer's trust, and we are dedicated to preserving that trust. Employees owe a duty to Rakoma & Associates, our customers, and shareholders to act in ways that will merit the continued trust and confidence of the public.

    As an organization, Rakoma & Associates will comply with all applicable laws and regulations and we expect our Directors, Clients, and Employees to conduct business in accordance with the latter, spirit, and intent of all relevant laws and to refrain from any illegal, dishonest, or unethical conduct.

    It is the responsibility of every employee to comply with our policy of business ethics and conduct. Disregarding or failing to comply with this standard could lead to disciplinary action, up to and including possible termination of employment.

    Definitions and Abbreviations

    EP: Engagement Partner 

    MP: Managing Partner

    HoS: Head of Support 

    EXCO: Executive Committee

    Employee/Official: All those in the employ of Rakoma and Associates Inc.

    Employer: Rakoma and Associates Inc.


    To promote and enforce ethical business practices and standards within employees and Rakoma & Associates stakeholders.

    Scope and Applicability

    The Code applies equally to all Employees. Please study the code carefully so that you that you understand employee's expectations and your obligations.

    Policy Content/Principles

    Disclosure of Information

    The interests of Rakoma & Associates will at all times be protected in the divulging of information, other than Published information, and more particularly as follows:

    4.1 No information, legal or otherwise, regarding any clients of Rakoma & Associates will be divulged to outsiders, without the prior written authority of the client and/or Rakoma & Associates Inc. 

    4.2 No employee will divulge any information regarding the business or matters concerning the business of Rakoma & Associates, without the prior written consent of the Manager or any Director.

    4.3 Any publication, e.g. letters to the press, articles in journals or magazines, text books or an academic thesis, written by an employee who directly or indirectly relates to the business of Rakoma & Associates, shall be referred to the Manager or any Director for prior approval before publication.

    4.4 No employee will divulge any information regarding the business or matters concerning the business of Rakoma & Associates, after resignation from the employment of the Rakoma & Associates or dismissal in terms of and in accordance with this Code.

    4.5 No person will divulge any information about an employee:

    4.5.1 Without the written consent of the employee; or

    4.5.2 Unless required by law or custom.

    Conflict of Interest

    6.1 Employees are expected to perform their duties conscientiously, honestly and in accordance with the best interests of Rakoma & Associates to optimize business objectives.

    6.2 Employees must not use their positions, or knowledge gained through their employment with Rakoma & Associates, for private or personal advantage or in such a manner that a conflict or an appearance of conflict arises between Rakoma & Associates interest and their personal A conflict could arise where an employee's family or a business with which the employee or family is associated obtains a gain, advantage or profit by virtue of the employee's position with Rakoma & Associates or knowledge gained through that position.

    6.3 If Employees feel that a course of action which they have pursued, are pursuing or are contemplating pursuing, may involve them in a conflict of interest situation or a perceived conflict of interest situation, they should immediately make all the facts known to the person to whom they report and any Manager or Director.

    6.4 The onus for the prior disclosure of any conflict of interest rests with the employee and includes, inter alia, prior disclosure of the following:

    a) All appointments as directors or officers of public or private companies outside Rakoma & Associates and to any close corporations or public bodies.

    b) Any representation on external Committees or bodies, either on behalf of Rakoma & Associates or in the employee's personal capacity.

    c) Any direct or indirect involvement in or interest in another business, undertaking or profession.

    6.5 The Directors of Rakoma & Associates may grant perm1ss1on for an employee to hold such position or interest, provided the employee makes prior disclosure and such permission is granted in A copy of the written permission is to be placed on the employee's personal file.

    6.6 Employees will declare to Rakoma & Associates Directors any representation held on external Committees or bodies, whose activities are relevant or related to the business in which Rakoma & Associates is involved, which representation is either on behalf of Rakoma & Associates or in the employee's personal The declaration is required:

    a) On commencement of employment.

    b) At the request of any Rakoma & Associates Directors; or

    c) As required to reaffirm acceptance of this Code from time to time.

    Gifts, Hospitality and Favors

    7.1 Conflicts of interest can arise where Employees are offered gifts, hospitality or other favors which might, or could be perceived to influence their judgment in relation to business transactions such as the placing of orders and contracts.

    7.2 Employees may under no circumstances accept gifts that can be regarded as bribes. Without limitation to the generality of this statement, any gift that would compromise future objectivity is not acceptable and no cash gift may ever be accepted. Any offer of this kind must be politely declined or immediately returned to the sender if it is delivered without prior notice.

    7.3 On the other hand, small gifts like company pens, ashtrays or the like are not regarded as bribes.

    7.4 Business lunches are a necessary part of the promotion of business relationships and such invitations shall not be regarded as a contravention of this Code or as constituting a conflict of interest.

    7.5 If there is any doubt in a particular instance, the matter must be referred to the manager or his/her nominee Manager for a ruling.

    7.6 In addition, no bribes of any kind should be made by any Rakoma & Associates employee to any customer or potential customer to secure business.

    7.7 All accepted gifts must be recorded in the transparency book.


    All employees are responsible for complying with this policy and associated guidelines developed with this policy. Non- compliance with this policy may lead to appropriate sanction against the employee. This policy should be read in conjunction with the Employee Code of Conduct of Rakoma and Associates and all other policies of the firm.

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