Ethics and compliance

Ethics & compliance

Our clients choose us because they trust our products, our people and our performance.

When it comes to professional integrity, we take a client- and employee-first approach. In practice, this means that our clients’ interests must always come first and that all officers and other employees of Invesco and its subsidiaries should treat each other with respect and consideration. Together, these beliefs are a vital part of how we achieve our principal responsibility as a publicly held company: producing a fair return on our shareholders’ capital.

Our principles for managing any conflicts of interest or financial crime (including fraud, bribery and corruption), which are in accordance with regulatory principles, are outlined in the following guidelines, among others:

  • Code of Conduct
  • Code of Ethics and Personal Trading Policy
  • Conflict of Interest Policy
  • Director’s Code of Conduct
  • Global Anti-Bribery and Corruption Policy
  • Global Anti-Money Laundering/Counter-Terrorist Financing Policy
  • Global Financial Crime Prevention Policy
  • Global Fraud Escalation Policy
  • Global Gifts and Entertainment Policy
  • Global Outside Business Activities Policy
  • Global Political Contributions
  • Global Remuneration
  • Global Violation Escalation
  • Identity Theft Prevention Program
  • Insider Trading Policy

Guiding our professional integrity are our Code of Conduct and Code of Ethics, which apply to all employees and officers of Invesco and its subsidiaries. The policies, standards and general principles in the Code of Conduct and Code of Ethics are designed to help define the expected conduct of an Invesco representative.

Our Code of Conduct drives our commitment to business ethics, professional integrity and compliance. It sets out essential guiding principles for workplace conduct, compliance with applicable laws and regulations, anti-discrimination and protection of Invesco’s assets, among other standards and expectations.

Our Code outlines our expectations of everyone at Invesco and our policies and standards against discrimination and sexual harassment, which encourage the reporting of all incidents of discrimination, harassment or retaliation, regardless of the offender’s identity or position. Any employee who engages in harassment or discrimination will be subject to disciplinary action, up to and including termination of employment.

In 2022, Invesco engaged in several initiatives that further promote a culture of ethics and integrity across our firm.
They include:

  • Technology enhancements overseeing employee behavior on compliance requirements.
  • Transformation of Conflicts of Interest through the embedding of a Conflict of Interest framework in the Europe, Middle East and Africa (EMEA) region.
  • Additional and refreshed trainings on conflicts and conduct.

Our Global Financial Crime Governance Committee is chaired jointly by our Chief Financial Officer and Global Head of Compliance and includes representation from a regional and functional lead. This Committee oversees financial crime, fraud, anti-corruption and anti-bribery programs and ensures that policies are actively followed.

2022 trainings

Department                                                                                         Name of Course
  • Conflict of Interest Training 
  • Global Required Compliance Training 
  • Anti-Money Laundering and Counter-Terrorist Financing Training 
  • Preventing Market Abuse Training 
  • Culture & Conduct at Invesco 
  • Fraud Prevention Training
Human Resources
  • Fostering Diversity of Thought through Hiring Practices 
  • No Excuses: Prevention of Sexual Harassment (India only) 
  • Respect in the Workplace
Global Security
  • Privileged Access Training
  • Global Privacy Training
  • Global Security Annual Training

Ensuring quality and integrity

Operating with a high degree of integrity and respect for one another is a fundamental principle at Invesco.

We provide all internal and external stakeholders with a mechanism for seeking advice and reporting concerns and violations via the Invesco Whistleblower website and a toll-free Compliance Reporting Line. These are anonymous, independent, confidential mechanisms for reporting complaints or concerns pertaining to questionable accounting, internal accounting controls or auditing matters and possible violations of the company’s Code of Conduct or law. Our Compliance Reporting Line allows employees and external stakeholders to act on managing risk and unethical behavior on behalf of Invesco.


In 2022, the firm clearly noted the continued benefits of implementing the enhanced escalation procedure relating to violations surrounding ethics policies with a further decrease in violations from the previous year.

All employees, officers and directors are required to take mandatory trainings annually, covering such topics as Security, Market Abuse, Code of Ethics, Anti-Money Laundering and other key conduct subjects. Anti-Bribery and Corruption and Fraud Prevention trainings are mandatory and administered every other year.


We also offer a series of nonmandatory trainings focused on ethical conduct through professional training and development channels. All trainings focus on scenario-based instruction to increase awareness of good conduct principles.

Our ethical conduct and compliance policies, standards and procedures are reinforced by Invesco’s overarching risk management framework. The risk framework structures investment and business risk management, with particular focus on key risk areas: strategy and governance, investments, clients, people, operations and financial.


Invesco’s Board of Directors has principal responsibility for oversight of the company’s risk management processes, including those set forth in the risk management framework, and for understanding the overall risk profile of the company.


In 2022, we incorporated specific feedback from the Board and senior leaders, industry best practices and global regulatory expectations to enhance Invesco’s enterprise risk management framework. This modernized global approach is more data-driven, supports proactive and action-oriented risk management and will enable us to further identify, assess, manage and report on risks and opportunities that could impact Invesco’s ability to successfully achieve its strategic objectives and meet our clients' needs.


Generally, our clients integrate ethical standards as a key component of the analysis of the quality of an asset manager. The due diligence carried out is focused on the controls put in place, but also on the trend observed in terms of compliance with ethical standards and policies reflected in the number of violations reported, notably around personal transactions.

We conduct periodic Anti-Bribery and Corruption risk assessments that cover all business lines and regions globally. Our assurance functions undertake control effectiveness testing through a risk-based approach. After assessing our business for risks related to corruption in 2022, we noted some areas of inherent higher risk, but no material, confirmed cases of corruption or policy breaches were identified.

Our compliance team regularly reviews, records and updates an assessment of key regulatory and business risks to determine ongoing areas of focus. Compliance policies and procedures are subject to ongoing monitoring and periodic testing, the results of which are reviewed, escalated and remediated to further mitigate risk and/or control weaknesses. Exceptions and errors noted during the normal course of business, as well as periodic regulatory interactions, contribute to the overall view of effectiveness. The firm’s Internal Audit group also conducts regular reviews of compliance activities as part of its independent testing procedures.


During the course of 2022, our compliance team continued to improve monitoring systems and processes and supported broader improvements at the firm, all in line with the firm’s goal “Simplify to Succeed.” Notably, we established a working group to develop a global approach to trade surveillance with the Center of Excellence, based in Hyderabad. Additionally, we implemented a new global restricted list management platform, which further automated controls and improved the books and records attached to material nonpublic information.

We encourage employees of Invesco and its subsidiaries, as private citizens, to exercise their rights and duties in any political or civic process. This includes voting in elections or making contributions supporting candidates or parties of their choice.


However, as a corporate policy, Invesco does not give direct payments to political activities in the U.S. As outlined in our Code of Conduct, no covered person may, under any circumstances, use company funds to make political contributions, nor are they allowed to represent their personal political views as being those of the company. While we do not give direct payments to political activities in the U.S., we do support political activities through our Political Action Committee (PAC). For Invesco’s PAC details, see reporting available on the Federal Election Commission website at Invesco’s lobbying disclosure reports are also available through the United States Lobbying Disclosure Act database.


In 2022, Compliance completed its onboarding of a new political contribution surveillance system, which enables further monitoring of political contribution records and compares those records to Invesco’s list of Covered Associates.

We consider our procurement relationships and seek to partner with high-quality vendors who share our values and commitment to client service and responsible business practices. This effort is led by our Global Procurement Department, which is charged with promoting fair and ethical business practices in selecting vendors, mitigating risk, negotiating commercial transactions and delivering value to Invesco and our clients. Our Global Procurement Policy also outlines our responsible sourcing and procurement practices and expectations for our vendors.


To ensure that we are procuring the best vendors for business needs, our Global Procurement Department team partners with Invesco’s business units to execute their respective strategies. Together, the procurement team and business unit make recommendations for selecting a vendor based on capability, quality, price, reliability, risk and other applicable criteria, including the vendor’s adherence to Invesco’s standard contract terms and conditions, which obligate our vendors to comply with all applicable country, regional and local laws, rules and regulations, including, but not limited to, laws prohibiting bribery, slavery and human trafficking.


In addition, all procurement personnel are required to abide by Invesco’s Code of Conduct and Procurement Code of Ethics and conduct themselves in a manner that avoids the appearance of impropriety, conflicts of interest or issues of influence when interacting with vendors.