Code of Professional Conduct

1. Why this code exists

Sagentix Advisors is a principal-led advisory firm. Our principal holds three certifications, each carrying a binding code of conduct: Certified Management Consultant (CMC), administered by CMC-Canada; CISSP, administered by ISC2; and Professional Engineer (P.Eng.), licensed by the Ordre des ingénieurs du Québec under Québec's Engineers Act. Those codes bind an individual. This code carries the same obligations onto the firm, so that a client contracting with Sagentix — not with a person — receives the same standard.

It also states plainly where our work stops. Most of the harm an advisory firm can do comes from acting past the edge of its competence or its independence, so this code names those edges rather than leaving them to be inferred.

Where this code and a professional code conflict, the stricter obligation applies. Where either conflicts with the law, the law applies and we say so.

2. The public interest comes first

We regard our duty to public welfare as paramount, ahead of the interests of the firm and ahead of the instructions of a client (Ordre des ingénieurs du Québec [OIQ], 2026, s. 2.01; ISC2, n.d., Canon I).

If work we are asked to do would endanger people, mislead a regulator, or damage the trust that financial and public institutions depend on, we say so in writing, we propose an alternative, and if the matter cannot be resolved we withdraw from the engagement.

We do not express public opinions on matters where we lack adequate knowledge and honest conviction (OIQ, 2026, s. 2.04).

3. Competence — and the boundaries of our practice

We accept only work for which we hold both the relevant education and the practical experience, and we decline work outside that range even where a client, knowing the limitation, asks us to take it on (CMC-Canada, 2024, cl. 4.03.1–4.03.2). Proposals name the people who will do the work, their qualifications, and their role.

Four boundaries define what Sagentix does not do. We name them at the proposal stage, not after an engagement begins:

• We advise on readiness; we do not assess, certify or attest. We prepare organizations for third-party assessment and authorization. We are not an accredited assessment body, and we do not audit or certify the work we ourselves have advised on.
• We do not perform accounting, audit, valuation or brokerage. We assess and cite financial information; we do not audit or attest to it, place a value on a business, or arrange or broker financing. Financial models we build are illustrative and identified as such, pending review by a licensed accountant.
• We do not provide legal advice. We work to legal and regulatory requirements and cite them; interpreting them for a client's circumstances is counsel's role.
• We do not guarantee quantitative outcomes beyond our control (CMC-Canada, 2024, cl. 4.01.6–4.01.7). Where a client asks us to quantify intended benefits, we state the client's own responsibilities, the assumptions and risks, and the measures used.

Where a client needs work beyond these boundaries, we say so and help them find it. One published commitment sits beside them and should not be mistaken for one: if our Phase 1 market intelligence reveals nothing a client did not already know, they receive a full refund within 14 days and keep the deliverable. That is a term of business, on the conditions published at sagentix.ca and subject to the engagement terms. It is not a guarantee of results, and nothing in it displaces the paragraph above.

4. Objectivity and conflicts of interest

We provide objective and independent advice, and we do not let any party inside or outside a client organization influence that independence (CMC-Canada, 2024, cl. 4.01.5).

We disclose to a client or prospective client any personal, professional or business interest that might reasonably be seen to affect their confidence in our integrity, objectivity or independence, and we do it before accepting the work (CMC-Canada, 2024, cl. 4.06.2, which is subject to any confidentiality owed to another client and sets no deadline — the timing is our own, stricter commitment; OIQ, 2026, ss. 3.05.03–3.05.04). We do not accept engagements with a client's competitors, or others whose interests conflict with that client's, without the informed permission of everyone involved.

We serve the interest of the client organization as a whole, not the interest of a faction within it or a party outside it. We do not recruit a client's staff, or refer them elsewhere, without the client's prior consent. If our objectivity is compromised during an engagement and cannot be restored in discussion with the client, we withdraw. That is a stricter standard than CMC-Canada, 2024, cl. 4.08.2, which reserves withdrawal as a right rather than requiring it.

5. How we contract

Work does not begin until the client has accepted written terms of reference (CMC-Canada, 2024, cl. 4.04.3). Those terms set out the objectives, the work plan and its milestones and deliverables, the timeline, the named consultants and their roles, the fees, and the billing arrangements including expenses, disbursements and taxes.

If scope changes, we agree the effect on fees and timeline in writing before continuing. We do not quietly reduce consulting time or seniority to protect a budget where doing so would drop quality below what was promised, and we do not take on engagements whose fee arrangements would represent a substantial business risk to the client (CMC-Canada, 2024, cl. 4.05.3–4.05.4).

We compete on merit. We do not use misleading advertising or pressure tactics (CMC-Canada, 2024, cl. 4.02.2), and we do not disparage another firm to win work — cl. 4.02.1 reaches criticism of other Certified Members, and we apply it to every competitor.

6. Evidence, and honesty about what we do not know

Our deliverables assert things a client may act on, so the standard of proof matters as much as the advice.

Every load-bearing claim is verified against two independent authoritative sources. Figures, dates and citations are never estimated to fill a gap; anything we cannot substantiate is either removed or explicitly marked as unverified. We do not present a source as saying something it does not say.

Third-party data and research are used only within the terms of the licence we hold for them, which for some sources means internal client use only and no publication.

When we discover that something we have published or delivered is wrong, we correct it and tell the people who relied on it. We keep a register of claims we have withdrawn so that retired figures do not resurface in later work.

7. Confidentiality, privacy and client information

We treat all information obtained from a client as confidential, and we do not disclose it without the client's specific consent (CMC-Canada, 2024, cl. 4.07.3 and 4.07.1; OIQ, 2026, ss. 3.06.01–3.06.02). The obligation does not expire when the engagement does.

Client material is held on controlled systems, segregated from anything we publish. We do not name a client, quote a client, or describe an engagement publicly without that client's written permission. Personal information is handled in accordance with Canadian privacy law, including PIPEDA, and with any stricter policy the client applies to its own data.

We encourage clients to classify sensitive information and, wherever the work allows, we would rather not hold it at all (CMC-Canada, 2024, cl. 4.07.6). On request, and at the end of an engagement, we return or destroy client material. If confidential information is ever exposed beyond our control, we inform the client immediately and act to protect their interests (CMC-Canada, 2024, cl. 4.07.5).

We do not extend credit, hold credit files, or take part in lending decisions. Where financing-readiness work brings us into contact with a client's financial or credit information, it is confidential under this section and constrained by the accounting boundary in section 3.

Confidentiality yields only to a validly issued and enforceable legal compulsion, and then only so far as the law requires.

8. Artificial intelligence in our delivery

Our methodology runs on AI-assisted analysis. It is core to how we work, not an optional accelerant, and we say so plainly before an engagement rather than describing it as a choice we do not actually offer.

We do not process any client material with AI tools until that client has given written permission. Permission is obtained at engagement setup, records what will be processed, and carries the client's exclusions.

Control rests where it is real: with what the client sends us. A client may withhold any category of material, sanitize what they provide, or narrow the scope at any time, without penalty and without having to explain. If a client withdraws permission, we re-scope the engagement honestly rather than claiming a delivery method we do not have.

9. Lawful conduct, financial crime and gifts

We comply with all applicable legislation, we do not cause any person to contravene it, and we do not act for anyone who would require us to (CMC-Canada, 2024, cl. 1.01.1–1.01.3).

Before accepting an engagement we satisfy ourselves as to who the client is and who ultimately controls them, and we screen against applicable sanctions lists. We do not accept cash. We decline or discontinue work where we know or suspect it would further money laundering, terrorist financing, sanctions evasion, bribery or fraud, and we report where the law requires it.

We neither offer nor accept gifts, hospitality or other benefits that could reasonably be seen to influence a business decision. Ordinary, modest hospitality is acceptable; anything beyond it is declined or disclosed. We do not pay or accept a commission for securing work without disclosing it to the client (OIQ, 2026, s. 3.02.09).

10. People who work under our name

Anyone working under Sagentix's name on a client engagement — associate, subcontractor or employee — is bound by this code in writing before the work starts, and we answer for their compliance. CMC-Canada, 2024, cl. 2.03.1 requires us to ensure they understand and comply; cl. 2.03.2 holds a member liable where they were aware, or ought to have been aware, of a breach. We do not rely on that limit. We give proper credit for others' work and treat other practitioners with courtesy and good faith (OIQ, 2026, s. 4.02.03).

11. Raising a concern, and what follows

Anyone — a client, a member of their staff, a subcontractor, or a member of the public — may raise a concern about conduct under this code by writing to conduct@sagentix.ca. We acknowledge within two business days and respond substantively within fifteen business days. Concerns may be raised in English or French. We do not retaliate against anyone who raises one in good faith.

Where a breach is found, the response is proportionate: correcting the work and informing anyone who relied on it; withdrawing from the engagement; ending a subcontract; or, where the conduct is our own, refunding the affected fees. We record every concern and its outcome.

Conduct by our principal is additionally answerable to CMC-Canada, ISC2 and the Ordre des ingénieurs du Québec — whose syndic receives complaints — and their disciplinary processes operate independently of this code and of us. Nothing here limits a complainant's right to go directly to them, to a regulator, or to a court.

The principal reviews compliance with this code annually, and the code itself is reviewed and updated at least once every three years.

Appendix A — Coverage map

A coverage map for anyone running supplier due diligence on this firm — the ten areas most financial-services conduct requirements ask about, and where each is addressed. The Caribbean Association of Banks names these ten in §5 of its own Code of Conduct; Sagentix is a service member, and this map was first built to that list.

Note — where these clause numbers come from

Two English editions, one title, two numbering schemes. CMC-Canada publishes both, and both are called Code of Professional Conduct, which is what makes the confusion possible. The edition cited above — filed as `CMC-Canada Uniform Code Of Conduct (May 2024).pdf` — numbers its clauses 1.01.1 to 4.08.2. The edition offered as "Download (English)" from cmc-canada.ca/codeofprofessionalconduct numbers the same duties 1.1.1 to 4.8.2. Every clause cited here comes from the first, and the reference points straight at that file, so a reader checking a citation is not sent to the edition whose numbering would appear to contradict it. Both files were downloaded and read on 3 September 2026; all twenty-one cited clauses were confirmed present in the cited one, including 1.01.2, which sits inside the range cited at §9 and was checked individually.

ISC2 prints its four canons as an unlabelled list. The Roman numerals are ISC2's own, used on the same page in its complaint-standing rule — "any member of the public may complain about a breach of Canons I or II" — which fixes the order. Canon I reads: "Protect society, the common good, necessary public trust and confidence, and the infrastructure."

References

CMC-Canada. (2024). Code of Professional Conduct [Uniform Code edition, May 2024; clauses numbered 1.01.1 to 4.08.2]. Canadian Association of Management Consultants. https://cmc-canada.ca/web/default/files/users/15/CMC-Canada%20Uniform%20Code%20Of%20Conduct%20(May%202024).pdf

ISC2. (n.d.). ISC2 code of ethics. https://www.isc2.org/ethics

Ordre des ingénieurs du Québec. (2026). Code of ethics of engineers [CQLR c. I-9, r. 6, made under the Engineers Act, CQLR c. I-9, and the Professional Code, CQLR c. C-26, s. 87]. Légis Québec. https://www.legisquebec.gouv.qc.ca/en/document/cr/I-9,%20r.%206

All three retrieved and read 3 September 2026.