Ethics & Compliance

Institutional-grade integrity for a world measured in trust.

Integrity is non-negotiable. Every mandate we accept and every market we enter operates under a single global standard: lawful, transparent, and responsible conduct that withstands regulatory, investor, and public scrutiny. This standard governs all StarBridge entities – Starforge, Stellaris, StarHaven, and StarIO – without exception.

Our Position

Ethics and compliance are not policies on a shelf; they are operating conditions for growth. The purpose of this framework is simple: protect stakeholders, preserve license to operate, and compound long-term value. It binds directors, executives, employees, contractors, and partners – across all jurisdictions and project types – under one code and one expectation: do the right thing, the right way, every time.

Code of Ethics

De nes expected conduct, decision principles,
and the duty to speak up.

Anti-Corruption & Fair Competition

Zero tolerance for bribery, facilitation payments, bid-rigging, or market abuse. Third-party due diligence and controls scale with jurisdictional risk.

Financial Market Integrity

Accurate books and records, transparent
reporting, controls against insider dealing, and robust con icts-of-interest management.

Sanctions, KYC & Export Controls

Risk-based screening of counterparties, ultimate beneficial owners, and transactions; escalation
pathways for heightened-risk geographies and
sectors.

Data, Privacy & Cybersecurity

Privacy-by-design, least-privilege access, and protection of personal and commercially sensitive data across the lifecycle.

Human Rights, Safety & Labor

Alignment with international norms; zero tolerance for modern slavery; health, safety, and dignity in every workplace.

ESG & Responsible Value Creation

Science-based environmental targets, responsible procurement, and governance practices that meet or exceed institutional benchmarks.

Leadership & Accountability

Tone from the top, proof in the controls.

  • Board Ethics Committee provides oversight and reviews program effectiveness.
  • Chief Ethics & Compliance Officer owns the enterprise framework and its continuous improvement.
  • Business Unit Ethics Leads translate standards into day-to-day controls within Starbridge’s Companies.

Consequence management applies consistently, including for leadership; no one is exempt.

How It Operates in Practice

Risk-based due diligence.

Suppliers, agents, co-developers, and investors are vetted proportionate to risk, with enhanced measures in high-risk markets.

Integrated controls.

Gifts & hospitality thresholds, political-activity restrictions, segregation of duties, and procurement integrity checks are embedded in core processes.

Training that moves the needle.

Role-specific curricula for development, capital markets, operations, and technology teams ensure real-world application.

Speak-up culture.

24/7 multilingual channels (anonymous where permitted), non-retaliation guaranteed, independent investigations, and board-level reporting.

Assurance & improvement.

Internal audits, external assessments, remediation plans, and KPI tracking inform our annual public ethics disclosure.

Global Alignment

The program aligns with leading international standards and supervisory expectations, including: UN Global Compact, UN Guiding Principles on Business & Human Rights, ILO Core Conventions, OECD Guidelines for Multinational Enterprises, GRI/PRI/GRESB, and relevant data-protection regimes. Climate-related financial governance follows TCFD guidance; nature – related risk management is progressing toward TNFD alignment.

What Stakeholders Can Expect

Regulators —

timely cooperation, transparent records, and remediation that addresses root causes.

Investors —

decision-useful disclosures, con ict-free governance, and controls commensurate with risk.

Governments & Communities —

ethical procurement, respect for local norms and heritage, and responsible fiscal citizenship.

Employees & Partners —

safe workplaces, fair opportunity, and clear rules applied consistently.

Reputation is earned in moments of pressure. StarBridge’s ethic is to choose the principled path—even when it is the harder one—because resilient value, regulatory confidence, and public trust are built no other way.

Contact Us

 Thanks for your interest in Turner. Whether you are looking to start a project, get support, or just have a general question, we want to hear from you. Drop us a line and we will get back to you.

Headquarters
Ethics & Compliance Hotline

Additional Information

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