GMA is only as credible as the company it keeps. We ask our clients to know who they are doing business with — which means we hold ourselves, and everyone we work with, to that same standard. This statement sets out what GMA expects of every vendor, supplier, and strategic partner it engages with, and why those terms are not open to negotiation.
Wissam Maroun, CAMS | Founder & General Manager, GMA Consultancy S.A.R.L
This statement governs GMA Consultancy’s relationships with every vendor, supplier, strategic partner, and other third party it engages with in the course of its business. It applies regardless of the size, sector, or jurisdiction of the counterparty, and regardless of whether that counterparty maintains its own formal compliance policies.
These terms are non-negotiable as a condition of doing business with GMA. Where a prospective third party is unable or unwilling to commit to the standards below, GMA will not proceed with the relationship.
GMA is a compliance and risk advisory firm. Our credibility with regulators, clients, and the public depends on our own relationships being demonstrably clean — not just our advice. A third party we engage becomes, in a practical sense, an extension of GMA’s own risk profile: their conduct in the context of our relationship reflects on GMA, and GMA’s standing can be affected by a counterparty’s misconduct even where GMA itself did nothing wrong.
For this reason, GMA requires every third party it engages with to complete a Third-Party Compliance & Integrity Questionnaire before, or as a condition of, onboarding — signed by that organization’s General Manager, Managing Director, or equivalent senior officer. This statement is the public summary of what that Questionnaire requires.
GMA requires every third party it engages with to operate, at minimum in the context of its relationship with GMA, consistently with the Ten Principles of the United Nations Global Compact — covering human rights, labour standards, environmental responsibility, and anti-corruption. A third party need not already have its own UN Global Compact commitment; by entering into a relationship with GMA, it commits to these standards within that relationship.
Within human rights specifically, GMA requires two standards with no exception and no tolerance: zero tolerance for sexual exploitation and abuse in any form — including any sexual activity with a person under 18 regardless of local consent law, exchanging anything of value for sex, and any sexual activity that is exploitative or degrading to any person — and a prohibition on any involvement, direct or indirect, in human trafficking. A third party must never knowingly engage, on GMA’s behalf or in connection with GMA’s business, any individual or entity involved in either.
GMA expects every third party to extend fair treatment to its own employees and workers, consistent with applicable local labour law: payment of legally compliant wages at regular intervals, working hours and conditions consistent with local law and industry norms, a workplace reasonably safe from foreseeable health and safety risk, and an environment free from harassment, threats, verbal or psychological abuse, and inhumane treatment. Where a third party engages in labour recruitment — directly or through an intermediary — it is expected to do so fairly, without charging recruitment fees to workers where prohibited by law, and without practices that increase a worker’s vulnerability to forced labour or trafficking.
Where a third party itself engages subcontractors, suppliers, or agents in connection with its relationship with GMA, GMA expects that third party to communicate the substance of this Statement to those subcontractors, suppliers, or agents — in their own local language and in a manner they can reasonably understand — and to exercise reasonable leverage to encourage those parties to meet comparable standards. GMA recognises this is a standard to work toward, not a guarantee the third party can give on behalf of every party in its own chain.
GMA requires every third party to confirm that it, and to the best of its knowledge its ultimate beneficial owners and senior officers, are not designated on any sanctions list issued by the United Nations, the European Union, the United States (OFAC), the United Kingdom (HM Treasury), or any other applicable authority, and that it does not knowingly conduct business with any sanctioned or designated party.
GMA applies the same zero-tolerance standard to its third parties that it applies to itself under its own Anti-Bribery and Corruption Manual: no bribes, no facilitation payments, and full disclosure of any gift, hospitality, or conflict of interest arising in connection with the relationship.
Every third party is required to keep confidential any non-public information shared by GMA, to handle personal data in accordance with applicable law, to refrain from using GMA’s name or affiliation without prior written consent, and to disclose promptly any conflict of interest arising in connection with the relationship. This runs both ways: a third party must also disclose to GMA if it becomes aware that any GMA personnel holds a personal financial interest of any kind in the third party’s own business, so that GMA can assess and manage that conflict on its own side.
The commitments above are not a one-time check completed at onboarding. GMA requires every third party to notify GMA promptly upon becoming aware of: any investigation, inquiry, or administrative or judicial procedure initiated against it, its controlling parties, or its senior officers, in connection with any standard set out in this Statement — including but not limited to financial crime, labour, human rights, or environmental matters; and specifically, any financial crime red flag connected to the relationship, including a new sanctions designation affecting the third party, its controlling parties, or beneficial owners, or any sanctions violation or enforcement action that could affect the third party’s reputation or its relationship with GMA. This is a standing obligation for the full duration of the relationship, not a disclosure made only once.
For a period of twelve months following the conclusion of a specific engagement, a third party should not directly solicit for employment any GMA employee who was personally and substantially involved in delivering that engagement, without GMA’s prior written consent. This restriction is intentionally narrow — it applies only to the individuals actually involved in the relevant engagement, and only for a defined period — and exists to protect the integrity of GMA’s engagements, not to restrict ordinary professional mobility.
The standards in Section 3 are not a one-way demand. GMA holds its own personnel — the Founder, employees, and anyone acting for GMA — to a reciprocal set of commitments in every dealing with a third party, under GMA’s own Anti-Bribery and Corruption Manual and Code of Conduct.
A third party dealing with GMA should treat any of the following, from any GMA personnel, as a clear violation of GMA’s own standards — not a normal part of doing business, and not something to accommodate quietly:
If you experience or become aware of any of the above, please report it directly to Contactus@Gmaconsultancy.com, marked “Confidential — Third-Party Report.” Reports are treated in strict confidence, reviewed by GMA’s compliance function independently of the individual concerned, and will never be held against you or your organization’s relationship with GMA — GMA would rather lose a piece of business than keep one obtained improperly.
GMA does not treat the Questionnaire as a formality. Responses are reviewed by GMA’s compliance function as part of the onboarding process, and GMA reserves the right to request supporting information, decline an engagement, or terminate an existing relationship where a third party’s conduct is inconsistent with the standards set out in this statement.
A standing commitment, not a one-time check.
Third parties are expected to maintain these standards for the duration of their relationship with GMA, and to notify GMA promptly of any material change.
This statement should be read alongside GMA’s Anti-Bribery and Corruption Manual, Compliance Statement, and Code of Conduct, each available in full at www.gmaconsultancy.com.
This Third-Party Governance & Compliance Statement is approved and issued by:
Wissam Maroun, CAMS
Founder & General Manager
GMA Consultancy (Governance, Monitoring & Advisory) S.A.R.L
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