Ethical Framework Statement

This statement sets out the standing ethical framework that Closeday applies across all insolvency appointments conducted by the firm. It supplements the case-specific ethics assessment prepared for each engagement, which documents threats, safeguards, and conclusions particular to that case.

This statement is prepared in accordance with the terms and spirit of the ICAEW Insolvency Code of Ethics 2025 (the "Code"), which applies from 1 October 2025.

Case-specific ethics assessments are drafted against templates provided by Compliance On Call and reference this statement as at their date of completion.

1. Technology governance

Closeday uses technology - including AI-assisted tools - in case administration, document preparation, research, and compliance workflows. The firm maintains oversight of the design, implementation, and operation of all technology used in the delivery of insolvency services.

Technology outputs that inform professional judgments are reviewed by qualified personnel before reliance. The firm periodically evaluates whether the technology in use remains appropriate for its intended purpose, whether personnel have sufficient understanding to use and explain it, and whether adequate controls are in place over access and use.

Where a case requires the use of technology outside the firm's standard toolset, the Insolvency Practitioner will assess the associated threats - including self-interest and self-review threats - on a case-specific basis before deployment.

Code reference: R2321.1, 2115.1 A6, 2115.1 A7

2. Bias awareness

In evaluating threats to the fundamental principles, the Insolvency Practitioner and case team have regard to the potential for cognitive bias to affect professional judgment. This includes, but is not limited to, familiarity bias, confirmation bias, anchoring bias, and automation bias.

Where relevant, the threat evaluation process includes challenge by a second individual and consideration of whether preconceptions or existing relationships may have influenced the assessment.

Code reference: 2117.3 A1 - A3

3. Specialist advice and services

The firm maintains a registry of approved vendors from whom specialist advice and services may be obtained during insolvency appointments. This registry is subject to periodic review, including a cross-case evaluation of fitness for purpose, best value, and any threats to the fundamental principles arising from the firm's relationship with each provider.

Where a vendor is engaged on a specific case, the Insolvency Practitioner will assess and document the appropriateness of that engagement at the time of instruction. This includes consideration of the nature of any relationship between the vendor and the firm or any individual within the firm, the cost of the service, the provider's expertise and regulatory status, and whether best value and service are being obtained.

Code reference: R2320.3 - R2320.6, 2320.6 A1 - A7

4. Source of introduction and referral arrangements

Where a case is introduced by a third party, the firm assesses the source of introduction for compliance with the Code's requirements on advertising, marketing, and referrals. For first-time referral sources, this includes a review of their marketing materials (website, advertising) to confirm compliance with the Code's guidance on promotional activities.

Closeday has never and will never operate a referral agreement. Regardless of whether a source of introduction will undertake work on a case, there will never be a referral fee or commission payable in connection with the introduction of an insolvency appointment, nor will there be a referral fee or commission received on a prior related engagement.

Code reference: R2340.4 - R2340.8, R2360.5 - R2360.8, R2330.5 - R2330.13

5. Inducements, gifts, and hospitality

In the exceptional circumstance where an inducement is given or received, the event alongside mitigation factors will always be recorded in the firm's Gifts & Hospitality Register and within the boundaries of Closeday's internal Compliance Manual and Anti-Bribery Policy.

Code reference: R2350.5 - R2350.13

6. Firm involvement and Insolvency Practitioner independence

The Insolvency Practitioner's contract of employment acknowledges that they have a duty to comply with the Code of Ethics and permits them to take all necessary steps deemed necessary to comply with the fundamental principles. The firm has policies and procedures in place to prohibit individuals who are not members of the insolvency team from inappropriately influencing the conduct of an insolvency appointment.

Staff in the firm are encouraged to communicate to senior management any issues relating to compliance with the fundamental principles that concern them.

Where a case-specific ethics assessment identifies a threat arising from the involvement of other principals or employees of the firm, the safeguards applied - including information barriers - will be documented in the case-specific assessment. The Insolvency Practitioner will confirm in each case-specific assessment that they are confident they have full control over the processes and internal governance of the firm insofar as they impact the appointment in question.

Code reference: R2380.5 - R2380.7, 2380.6 A1 - A5

7. AML risk assessment methodology

The firm's AML risk assessment follows the CCAB sector guidance and the firm's licensing body requirements. The firm acknowledges that most insolvency appointments involving the realisation or distribution of assets will, under CCAB guidance, attract a presumptive high-risk rating. Where the firm concludes that a lower rating is appropriate, the case-specific assessment will set out the justification for the downgrade by reference to the specific facts and circumstances of the case.

Internet and social media searches are conducted on the company, its directors, and beneficial owners as part of standard due diligence. Evidence of searches is retained in the case file.

The PSC Register is obtained for each company and compared against actual ownership as identified through CDD. Any material discrepancy is flagged, and the firm will comply with its reporting obligations under Regulation 30A of the Money Laundering Regulations where applicable.

Regulatory reference: CCAB AML Guidance for the Accountancy Sector, MLR 2017 Reg 30A

8. Anti-bribery risk assessment methodology

The firm applies a zero-tolerance approach to bribery, in accordance with the Bribery Act 2010 and Ministry of Justice guidance. The anti-bribery risk assessment is completed for each insolvency appointment as part of the case-specific ethics assessment.

The firm applies the following risk classification:

• High risk applies where any unauthorised payment, gift, or hospitality exists; any unusual circumstances suggest elevated bribery risk; or any director, partner, or employee has received unauthorised benefits.
• Normal risk applies where all payments, gifts, and hospitality are disclosed, authorised, reasonable, and proportionate.

Regulatory reference: Bribery Act 2010, Ministry of Justice Guidance

9. Ongoing monitoring

The Insolvency Practitioner will keep all identified threats - ethical, AML, and anti-bribery - under review throughout each appointment and remain alert to the emergence of new threats or changes in facts and circumstances that may affect previous conclusions. Where new information arises, the Insolvency Practitioner will re-evaluate and address threats accordingly, including by applying additional safeguards or, if necessary, considering resignation from the appointment.

The firm operates a structured periodic review schedule for ongoing monitoring across all active cases. General ongoing monitoring is automatically scheduled by way of Closeday's automated procedures. Ongoing monitoring for suspicious activity between scheduled reviews is ensured operationally through the firm's procedures, activity tracking, and automated triggers.

Code reference: R2210.7, R2116.3, 2116.3 A1 - A2

10. Signature and confirmatory statement practice

Each case-specific ethics assessment requires sign-off by the prospective officeholder(s). The sign-off includes selection of one of two confirmatory statements: (a) no threats to the fundamental principles have been identified, or (b) threats have been identified and reduced to an acceptable level through the application of safeguards. Separate confirmatory sign-offs are recorded for the ethics assessment, AML risk assessment, and anti-bribery risk assessment.

11. Network status

Closeday does not form part of a network as defined by the Code.

Code reference: R2314.1

Regulatory adherence

This statement and the firm's case-specific ethics assessments are prepared in adherence with the following regulatory frameworks:

• ICAEW Insolvency Code of Ethics 2025
• IPA Code of Ethics
• CCAB Anti-Money Laundering Guidance for the Accountancy Sector
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
• Bribery Act 2010 and Ministry of Justice Guidance

Template basis

Case-specific ethics assessments are drafted against templates provided by Compliance On Call. The following checklists are considered for each assessment:

• Ethics checklist (Insolvency Code of Ethics)
• AML risk assessment: risk, verification, and successive appointments
• Bribery Act 2010 policy and risk assessment

Template guidance: (c) Compliance On Call 2026 (v. March 26)