Living Our Values:

McKinsey Code of
Professional Conduct

Our values define who we are as a firm and who Finally, we have this, our Code of Professional
we aspire to be. Conduct, which defines a set of expectations for the
behavior of all firm members. The Code of Professional
They provide the guiding principles that shape our
Conduct does not replace our policies. Rather, it
actions and are essential to fulfilling our two-part
serves as a guide to help colleagues understand the
mission to: help our clients make distinctive, lasting
core elements of our policies and how those policies
and substantial improvements in their performance
are anchored in our values.
and to build a great firm that attracts, develops,
excites and retains exceptional people. The Code of Professional Conduct highlights our
personal responsibility for professional conduct.
We expect all colleagues to live our values every day.
We expect all colleagues to comply with this Code of
And when faced with a difficult situation we expect
Professional Conduct and we expect others working
everyone to challenge themselves, and to consult with
on our behalf, such as contractors, advisors and other
colleagues, to determine what course of action would
suppliers, to act in a manner that is consistent with
be most consistent with our values.
our Code.
While our values guide our behavior and help us to
make the right choices, we also have firm policies.
These policies establish our obligations as members of
the firm and define the rules of conduct in a range of
very specific, often complex, situations. They apply to
all firm members globally, and we expect all colleagues
to comply fully with these policies. We hold ourselves
to the highest standards of integrity and behavior,
and consequently, our policies often go well beyond
what is required by law. Failure to comply with our
policies may result in disciplinary action including
termination of employment.

McKinsey & Company Code of Professional Conduct 1

Our code of professional conduct
Our Code of Professional Conduct serves as a guide
to our values and policies in action and outlines the
expectations we have for all firm members in the
areas of:
1. Serving our clients with the highest
professional standards
2. Creating a working environment that
inspires and motivates our people
3. Fulfilling our responsibility to society
4. Managing risk to the firm
5. Seeking advice and raising concerns

The McKinsey Code of Professional Conduct

is supported by the full set of firm policies.

McKinsey & Company Code of Professional Conduct 2

1. Serving our clients with the
highest professional standards
We are privileged to have the trust of the clients that Professional independence
we serve, and we earn that trust by always acting We must avoid engaging in outside activities that
with the highest integrity; by providing objective and could interfere with our responsibilities to our clients
independent advice; by putting our clients’ interests and the firm. It is incumbent on each of us to ensure
ahead of our own; and by protecting our clients’ that there is never any confusion about whether we
confidential and sensitive information. We expect all are acting in our capacity as a member of the firm,
colleagues to act at all times in ways that justify and or in some other role. Therefore, firm members are
reinforce the trust in which we are held. restricted from undertaking employed work outside
the firm, and may not operate or actively manage a
Client impact business, run for political office, or accept an official
As a firm, we set a high aspiration for the positive role in a political campaign. In addition, firm members
impact we have through our client service. We will only are restricted from sitting on the board of directors of
undertake work where we can be confident that the any for-profit company, whether privately held, publicly
objectives of the work are to bring material, positive listed, or state owned, and must gain clearance prior to
and lasting impact; that the impact of our work has the accepting membership on non-profit Boards to ensure
potential to far exceed our professional fees; that we no conflicts exist with our clients. Interim roles in client
will not be pressured to compromise our values; and organizations are permitted only under a very limited
that we will be keeping faith with our commitment to set of circumstances and only when cleared
do work that attracts, develops, excites and retains by the firm’s Client Service Risk Committee. All firm
exceptional people. We are committed to delivering members are required to disclose any potential
impact to the best of our abilities to all our clients and conflicts of interest, whether real or perceived, and
we hold our leaders accountable for that impact. We to consult with relevant firm leaders and governance
expect our leaders to oversee our work, ensure that bodies on how best to handle the situation.
the conditions for impact are in place, and to bring
our best capabilities to every situation. All colleagues Misuse of client information
have the obligation to speak up if they feel that our To ensure that there is no risk of insider trading,
ability to deliver on these aspirations for impact firm members and members of their households are
is compromised. prohibited from purchasing or selling publicly traded
securities (including securities issued by state, local,
Client confidential information or municipal government entities in the US) of any firm
In the course of our work we are entrusted with client client and are required to pre-clear purchases and
and third-party confidential information and we take sales of any publicly-traded securities. In addition, firm
exceptional care with the information that has been members are prohibited from holding an investment
entrusted to us. Client confidential information is all in a non-public company that they serve or making an
non-public information (written or oral), including investment that creates a conflict of interest for the
business plans and trade secrets, client names, the firm or themselves. Firm members are also prohibited
nature of our client services, our recommendations from using client confidential information for any
or advice, client data, and information we purchase at reason other than the service of that client. Such
our clients’ expense. We only share client confidential information cannot be used for personal or political
information with colleagues who have a legitimate ends, or in service of a different client.
need to know, or those we know are authorized to
access the information. In their use of social media, Client resources and assets
we expect colleagues to safeguard client confidential We expect colleagues to treat client assets, including
information, including anything that could reveal a facilities and equipment, with respect, and to spend
client’s identity or our presence there. Colleagues are only what is necessary to perform our work to the
also expected to ensure that our clients’ data and the highest standard.
firm’s data environment is protected from
unauthorized external access by adhering to the
cyber security standards as described in the firm’s
cyber policies.

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2. Creating a working environment
that inspires and motivates our people
We attract, develop, and seek to excite and retain, Our meritocracy
truly exceptional people. We do this through the We require all colleagues to uphold both the reality
opportunities for impact, growth, and development we and the perception of our meritocracy and to do so in
provide; by providing a work environment in which our a caring way, with respect, dignity, and empathy. Our
people feel respected, and can thrive, grow, and be individual evaluation processes – which are critical to
their best; and by maintaining a caring meritocracy. our meritocracy – are holistic and confidential, and all
colleagues are expected to contribute to these with
Inclusion, diversity and a safe and respectful candor. Attempts to subvert our evaluation processes
work environment runs counter to our values. Any hiring, including for
We value an inclusive culture and celebrate diversity temporary positions or for the provision of external
of all types. Diversity in our teams improves the services, must comply with firm processes and be
creativity of our thinking, the quality of our work, based solely on merit. Favoritism, or the perception
and the development experience for our people. of favoritism, represents a risk to our meritocracy and
We expect every colleague to hold themselves as such, we prohibit personal romantic, physical, or
and each other accountable to ensure a working familial relationships between firm members who are
environment that celebrates the benefits of diversity in any kind of supervisory relationship or are actively
and one in which everyone is treated with respect working together. We likewise prohibit the hiring of
and dignity, feels welcomed and safe, and can grow, children of firm Partners. Colleagues are expected to
develop, and perform their best work. We do not declare where they have a personal relationship that
tolerate discrimination, harassment, or bullying in may interfere with our meritocracy or create any other
any form. Our expectations of behavior extend to all conflict of interest.
interactions within and beyond the office environment
including team, practice, and office events, and via Our colleagues’ personal information
electronic communications. We handle our colleagues’ personal data fairly and with
respect and will only collect personal data for specific,
explicit, and legitimate purposes, and limit the data
collected to only what is necessary for the purpose
for which it was collected.

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3. Fulfilling our responsibility to society

As a firm, we are committed to positive social impact. Environment

We help address societal challenges in the way we McKinsey is committed to minimizing the impact
conduct ourselves in the course of our business; our firm has on the environment and we seek to
through our engagement in our communities; and in continually strengthen our environmental policies
the investments we make to support significant and and practices. We are making efforts to manage, and
lasting impact on pressing social issues. reduce, our global greenhouse-gas emissions and
our waste footprint. We expect colleagues to take into
Societal impact of our activities consideration the environmental impact when making
In the course of client service, colleagues are expected choices about how they work. This includes reducing
to think broadly about the impact of our work on our emissions from travel, where possible, minimizing
clients’ multiple stakeholders, to help our clients to waste, and increasing recycling at McKinsey
be mindful of their social impact, to actively debate locations and client sites.
the impact of our recommendations on shareholder,
customer, and societal interests, and to always act Competition and trade
in a manner that is consistent with relevant laws and We are committed to promoting free, fair and
regulations. We encourage colleagues who wish competitive markets, and compete on the quality and
to give back to their communities – for example, by impact of our work. We abide by international trade
participating in volunteering, non-profit board service, regulations that prohibit or restrict trade with certain
and charitable giving. Firm members are, however, not countries, organizations, or individuals. Further,
permitted to run for political office or accept an official all colleagues must comply with all relevant laws,
role in a political campaign. regulations, and internal policies relating to anti-trust,
fair competition, anti-money laundering, funding
Human rights terrorist organizations, and trade controls.
We are committed to human rights and comply with
all human rights laws. Our commitment to human
rights informs whom we serve and on what topics, and
we will not do work that supports or enables human
rights violations. We do not tolerate physical violence,
threats, bullying, or verbal abuse of any kind in the
workplace, whether in our own or our clients’ locations.
We require suppliers to comply with McKinsey’s
Supplier Code of Conduct which prohibits all forms
of forced labor, child labor and human trafficking,
and requires compliance with all laws regarding
discrimination, harassment and retaliation.

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4. Managing risk to the firm

We have the trust not only of the clients that we serve, Regardless of whether a colleague is speaking for
but also of the communities in which we operate and the firm, or simply using social media for personal
of the talented people who join our firm. That trust, use, we expect colleagues to maintain both client
and our reputation for integrity and independence, is and firm confidentiality, and to protect the firm’s
precious – our ability to have impact for our clients, reputation. Colleagues must not present their personal
provide opportunities for our people, and contribute to political views in ways that could compromise the
the economies and societies in which we live and work, firm’s reputation for political neutrality. All external
depends on it. All colleagues therefore, are expected publication and communication with the press requires
to act at all times to proactively manage risks to the approval by firm External Communications and
firm and to build and protect the firm’s reputation. colleagues are required to complete media training
prior to any interview with journalists or bloggers.
Corruption, bribery, gifts, and entertainment
We will not participate in any form of corruption and we Data security and protection
have an obligation to inform our clients if we encounter All colleagues are required to protect the firm’s data
actual or perceived corruption in their organizations. and its data environment from unauthorized access. All
Firm members, and anyone acting on our behalf, must digital deployments by the firm including applications,
not offer gifts or favors to gain any form of advantage platforms, technology and third-party products,
for ourselves, our colleagues, or any third party. Nor must conform to approved standards to ensure that
can we accept gifts that are intended to influence us, confidential information is protected by strong security
and we do not give preferential treatment in our merit- controls. Any exceptions must be approved by the
based hiring processes. We must avoid both the reality Cyber Risk team and colleagues who are uncertain
and the perception of improper influence and should about the security of a system or technology should
therefore also avoid entertainment which could be e-mail for help.
perceived as inappropriate or excessive.
McKinsey resources and assets
Higher risk client service situations We expect colleagues to be thoughtful in how they
The firm has identified a number of client service use firm resources and protect the firm’s information
situations that require colleagues to follow specific and assets. McKinsey assets, including proprietary
additional requirements to manage risks to clients, information, software, frameworks, tools and
our firm, and our people. These include analytics, methodologies, must be used only in accordance
M&A, Public, Social or State-linked Sectors, with firm policies and for firm-related activities.
Pharmaceutical and Medical Product Compliance, Colleagues may not use McKinsey resources such
Purchaser-Supplier engagements, restructuring as e-mail distribution lists for political purposes, for
and bankruptcy, compensation, software application soliciting investments, or for other personal interests.
delivery and support, work requiring interaction with We expect all colleagues to be fiscal stewards of the
regulators, and work conducted in partnership with firm, to fully and consistently comply with our expense
third parties. Approval from the Client Service Risk policies, and to reflect on how their use of resources
Committee (CSRC) is required before committing would be perceived externally and by their colleagues.
to work in these areas, and colleagues undertaking
this work are required to be familiar with the specific Accurate records
policies covering these areas, to undertake all required We maintain accurate records for the appropriate
training, and to comply with requirements to engage length of time to enable us to comply with all relevant
appropriate experienced practitioners to oversee laws and regulations. It is explicitly against our policy
the work. to maintain firm or client records outside of the firm’s
systems, or to destroy, falsify or alter records that are
Social media and the press required to be maintained (for example, in the context
All colleagues are expected to present themselves of an investigation). Colleagues are expected to file
professionally on social media. Even in the use of any required firm records, such as expense reports
private social media accounts, we expect colleagues and timesheets, accurately and in a timely way.
to be mindful of the perceptions that can be created.

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Working with third parties
We partner with other firms and engage individuals,
including Senior Advisors, from outside the firm
to bring the best to our clients and the firm. These
relationships are increasingly important enablers of our
impact and innovation. At the same time, working with
other organizations and individuals raises potential
financial, legal and reputational risks. These situations
therefore require additional syndication and expert
advice. All colleagues are required to ensure that
any third-party partnering with the firm or delivering
services to the firm is appropriately vetted, and to
comply with our consulting intermediaries, external
workers and partnering policies.

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5. Seeking advice and raising concerns

Not every situation can be neatly captured in a policy Hotlines

or code of conduct, and colleagues should always We recognize there are times where colleagues may
seek advice when faced with a difficult situation, feel the need for an opportunity to raise a concern or
or whenever they are unsure of the correct course ask a question without coming forward directly to a
of action. colleague. For those instances, we have established
hotlines, as an alternative vehicle for colleagues to use.
If a colleague observes something they believe may
be inconsistent with our values, our policies, or this You may ask a question or raise a concern through an
Code, could put the firm or an individual colleague at internal link, which is hosted by an external service
risk, or may be against the law, they have an obligation provider to keep the information confidential, to the
to speak up. extent permitted by law.
Colleagues in any kind of supervisory position,
for example Partners or Managers, have an Ombuds
additional obligation to report anything that could The firm Ombuds are available to all firm members
be a violation of our Ensuring an Environment Free to provide informal, confidential advice and support.
from Harassment or Discrimination Policy. As an informal resource, our Ombuds will not direct
you on what to do, act on anything you discuss, or
The firm does not tolerate retaliation against a (except if they determine there is imminent risk of
colleague who in good faith raises a concern about serious harm) escalate your situation to others inside
any aspect of professional conduct, or who fulfills their or outside the firm. Our Ombuds will offer assistance
obligation to participate honestly in a firm or external to help colleagues make a decision on how and where
investigation. Retaliation in any form is a violation to formally report the concern. If you are aware of a
of policy and may result in disciplinary action, potential breach of our values, professional standards,
including termination of employment. policies, or the law, please raise it through one of the
The following resources are available to all colleagues methods listed above so the firm can review it and take
to seek advice, ask a question or raise a concern. appropriate action.

Advice from a colleague

Our aspiration is that colleagues feel comfortable
seeking advice or raising concerns directly with a firm
colleague. Examples of colleagues who may be able
to help address your concern include:
— The ED or other leader of your client service team
— Your DGL, Office Managing Partner, cell leader,
supervisor, or department manager
— Your Regional People Leader, PD or HR
— The firm’s Chief Risk Officer, Chief People Officer,
General Counsel or leader of Personnel Risk
— Any member of the firm Legal department
— For concerns related specifically to the behavior
of a Partner or Senior Partner:
Chair of the Professional Standards Committee,
Leader of Personnel Risk, or Chief People Officer
— For concerns related to client service:
Any member of the Client Service Risk Committee
(CSRC) or our Director of Risk

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Conclusion

Our Code of Professional Conduct highlights that This Code of Professional Conduct is intended to be
each of us has an obligation to maintain the highest a living document. The Risk, Audit and Governance
professional standards in our client service; create Committee of the Shareholders Council is responsible
an environment in which our people are respected, for periodically refining and updating the content of
inspired and motivated; consider the wider this Code.
implications of our actions on society; and uphold
To provide input or suggestions to improve this Code of
the firm’s reputation.
Professional Conduct please see the firm’s intranet.
We are each responsible for applying the standards
outlined in this code, and of taking the responsibility
to speak up and voice any questions or concerns
related to possible violations of this code, of our
values, our policies, or the law.
Following this code will allow us to truly live up to
our values, fulfill our dual client service and people
mission, and continue to earn the trust of the clients
we serve and the communities in which we live and
work. Our collective aspirations for positive impact
in the world depend on that trust and therefore on
us living by the behaviors highlighted in this Code
of Professional Conduct.

Adopted: May 11, 2019

Updated: November 2020

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