SAIME3i — Ethics charter

Preamble

What this charter commits

The commitments that follow are not intentions. They are binding: this charter is annexed to every engagement letter and forms an integral part of the contract. Any established breach constitutes grounds for immediate termination, without penalty to the client.

It is dated and versioned. Engagements in progress remain governed by the version applicable at their date of signature.

It is read together with two further documents: our general terms, which carry its contractual consequences, and our separation and independence charter, which sets out its operational rules on conflicts of interest.

Commitment 01

What we refuse

We decline the following engagements whatever the fee offered, whoever the requester, and without any circumstance justifying an exception.

Surveillance of an individual, in any form and for any reason whatsoever.

Any engagement whose manifest purpose is to harm, intimidate or damage the reputation of a person or group.

Unauthorised access to an information system, a network or protected data.

Any data collection by circumvention, social engineering, or any non-publicly accessible means.

The production of disinformation, false evidence, misleading content or documents intended to deceive a third party.

Any remuneration linked to access to a public official, an elected representative or a diplomat, directly or through a fee conditional upon obtaining a public decision.

Holding, on the same transaction, both a development mandate and an assessment presented as independent.

Any advice aimed at deliberately circumventing an applicable rule, in any jurisdiction.

Any engagement we cannot honour within the scope or timeline requested. We say so, and refer to a third party.

A commitment that has never cost anything is not a commitment. These make us give up engagements.

Commitment 02

Legality and methods

Our analyses are conducted exclusively from publicly accessible sources. No intrusion, no unauthorised access, no data obtained by circumvention.

This limit applies across all our practice areas. It is not a commercial precaution: it defines the scope of what we know how to do, and of what we agree to do.

The analysts and correspondents we engage are bound by the same requirements under contract. Our responsibility remains entire: the client deals with us alone.

We employ artificial intelligence systems in production. None of their outputs enters a deliverable without re-examination, and third-party data is anonymised before any processing involving an external system.

Commitment 03

Independence

We carry on activities that, if poorly separated, would compromise one another: opening a market means serving an interest, assessing a counterparty means having none.

We never simultaneously hold a development mandate and an independent assessment on the same transaction.

Any connection with a party is disclosed to the client before acceptance of the engagement
Where an engagement includes an assessment, our remuneration in no way depends on the tenor of our conclusions nor on the outcome of the transaction
A cooling-off period applies between an independent assessment and any development mandate with the party concerned
A register of interests is kept for each engagement, available to the client on request

The network conflict

Part of our activity rests on relationships built over time. We may therefore be led to assess a party we know, or one we previously introduced to a third party.

This situation is disclosed before acceptance. The client decides whether to maintain the engagement, restrict its scope, or entrust it to a third party. We do not make that decision for them.

The operational rules — cooling-off periods, presumption of incompatibility, reasonable perception test — are set out in our separation and independence charter, annexed to every engagement.

Where doubt arises as to the application of a rule, the interpretation preserving the independence of the analysis prevails over the one preserving commercial opportunity.

Commitment 04

Confidentiality

Our clients' identity, the nature of their requests and the content of our work are never disclosed to any third party.

We cite no client as a reference, whether in conversation, in a document, or by allusion
Our engagements are mentioned in no public or professional context
Deliverables are transmitted to the commissioning party alone
The final client’s identity is not disclosed to affiliated analysts, save operational necessity and under equivalent undertakings

This undertaking binds both parties and remains in force for five years after the end of the engagement, without prejudice to information whose confidentiality is protected by law.

Publication of cases

We publish analyses of public objects, with no client involved. No publication based on an engagement occurs without the client’s specific prior written consent, the text being submitted before release. The client may refuse without reason and withdraw consent at any time.

Commitment 05

Analytical neutrality

Our conclusions are influenced neither by the client’s expectations, nor by our interests, nor by the difficulty of establishing them.

Each of our deliverables expressly distinguishes three levels:

The analysis: What is established, and what is not. Contestable: you may revisit our sources and verify our conclusions using our own criteria, which are published.
The recommendation: What we would do in your position. Reasoned judgement, supported by the analysis but not established. Debatable without invalidating our work.
The decision: It belongs to you. We do not decide, we do not co-decide, and we never represent our work as having determined a decision.

We produce no judicial verdict, no accusation, no unsubstantiated assertion. Our verdicts bear on assertions, never on persons.

A rule on which we do not compromise

Where an element could not be established, we write it down — and we specify that such a statement constitutes neither an accusation nor a denial.

Absence of evidence is not evidence of absence. Confusing the two is the gravest error an analyst can make, and the most frequent.

Commitment 06

Respect for persons

Our work concerns entities and the persons who bind them, in their professional capacity alone.

We seek no special category data — origin, opinions, beliefs, health, sexual life, trade union membership
We process no data concerning a person’s private life unconnected to their professional capacity
We process no data concerning the relatives of a person examined
Should such data appear incidentally in a public source, it is neither used nor reported

Any verification request must pursue a legitimate and proportionate purpose — the assessment of risk prior to a contractual or financial commitment. We decline those that do not.

The terms of this processing, and the rights of the persons concerned, are set out in our privacy policy.

Commitment 07

Transparency on our limits

We state what our work permits, and what it does not.

Each deliverable states its methodological limits and what fell outside its scope
We never assert a certainty where only a probability exists, and our verdicts carry the level of establishment of each assertion
Our conclusions are valid as at a date, within a scope and with determined sources — we say so systematically
We inform the client without delay of any element likely to affect the reach of an engagement
Our work consists of decision-support instruments. It constitutes neither legal advice, nor financial advice, nor certification, nor judicial expertise

Where possible, we also indicate the shortest path to resolve what remains uncertain — including where it is not our concern, and including where the client can do it alone.

Commitment 08

Our errors

We will make them. A firm claiming otherwise would not deserve to be believed.

Where an error is identified in a delivered work:

We inform the client without delay, without waiting for them to discover it
We issue a dated correction, stating what changes and why
We examine whether other work delivered to the same client is affected
We correct the cause, not merely the consequence

It is precisely because error is possible that we retain our sources and date our conclusions. We do not sell infallibility: we sell traceability. You will always know what a conclusion rests on, and therefore when to treat it with caution.

For any question concerning this charter: contact@saime3i.com. Every request receives a written response.

Version 2.0 — July 2026. Any change gives rise to a numbered and dated version.