WE ARE COMMITTED TO

Governance and Ethics

Our policy on governance and ethics

At First Circle, we are committed to strong corporate governance as the foundation of a transparent, ethical, and accountable organization. We uphold the highest standards in decision-making, compliance, and risk management to ensure our operations align with our mission of empowering SMEs across the Philippines and Southeast Asia.

Through clear policies, internal controls, and a culture of integrity, we strive to protect stakeholder interests, foster long-term trust, and contribute to a well-governed and sustainable financial ecosystem

Board of Directors

As a subsidiary of Carabao Capital Global (CCG), First Circle benefits from the strategic guidance and advisory support of the CCG Board of Directors.

Patrick Thomas Lynch

Executive Director & Chairman.
Chief Executive Officer at First Circle.
Previously MoneyHero Group and Morgan Stanley.

Christopher Mark Burgess

Executive Director.
Chief Investment Officer at First Circle.
Previously Bridgewater Associates and Morgan Stanley.

Rostan Hernani Schwab

Investor Director.
Southeast Asia Co-Head for Tech Investments at the International Finance Corporation.

Plern (Tee) Suraphongchai

Investor Director.
Co-Founder and Managing Partner of Koru Partners.

Ciaran O’Flynn

Independent Director.
Previously Head of European Rates Flow Trading, Global Co-Head of Fixed Income Electronic Markets, and Head of Bank Resources Management at Morgan Stanley.

David Evan Luck

Non-Executive Director.
Founder & Executive Chairman at CapitalOnTap, Europe’s largest Corporate Card Issuer to SMEs.

Code of Conduct

At First Circle, our Code of Conduct reflects our commitment to building a high-performing, ethical, and inclusive workplace that supports our mission to economically empower SMEs across Southeast Asia. This Code is essential in determining our identity as employees, officers, and stakeholders of First Circle, and reinforces our shared responsibility to uphold our values of Meritocracy, Outcome Ownership, Relentless Application, Personal Growth, and Teamwork.

We are committed to ensuring accountability through clear procedures for handling violations, including our Grievances & Whistleblowing Policy and the imposition of appropriate Penalties.

In line with this, the Code also includes the following core policies: Anti-Sexual Harassment Policy, Anti-Discrimination Policy, Anti-Corruption and Anti-Bribery Policy.

Compliance Manual

At First Circle, we are committed to maintaining the highest standards of legal, regulatory, and ethical conduct across all our operations. Our Compliance Manual guides how we fulfill these responsibilities, ensuring that our actions align with applicable Philippine laws, regulations, and contractual obligations.

While the full manual is an internal document, it reflects our company-wide commitment to integrity, accountability, and transparency—values that help us reduce risk, strengthen stakeholder trust, and support sustainable business growth.