Effective Date: 1st October 2025
1. Integrity and Honesty
- Employees and representatives shall act with *honesty*, integrity, and fairness in all business dealings.
- Misrepresentation, fraud, or deception is strictly prohibited in client interactions and disclosures.
2. Transparency and Disclosure
- All communications with clients shall be *accurate*, clear, and timely.
- The firm shall disclose material facts, conflicts of interest, fees, and risks associated with investment products and services.
3. Confidentiality and Data Protection
- Personal and financial client information must be handled with strict *confidentiality*.
- Safeguard all data in accordance with international privacy standards and regulations.
4. Professional Competence
- Employees must maintain the necessary training, licenses, and expertise for their roles.
- Continuous learning and professional development are encouraged to uphold industry standards.
5. Client-Centric Approach
- Place client interests *above all else*—avoid conflicts and recommend only suitable products/services.
- All investment recommendations should be reasoned, researched, and beneficial to clients’ financial goals.
6. Compliance with Laws and Regulations
- Adhere to all relevant local and international laws, including anti-money laundering, anti-bribery, and securities regulations.
- Promptly report any suspected violations or unethical conduct.
7. Accountability and Reporting
- Cultivate a workplace culture where *ethical concerns* can be raised confidentially, without fear of retaliation.
- All employees are responsible for reporting violations and lapses in conduct.
8. Social Responsibility
- Promote sustainability, diversity, and responsible investing in all firm activities and recommendations.
- Reject discrimination and foster inclusive hiring and business practices.
9. Anti-Corruption and Bribery
- Zero tolerance for bribery, corruption, or improper influence in internal or external interactions.
- Conduct periodic risk assessments and audits for compliance.
10. Enforcement and Monitoring
- Regular training is required for all staff members.
- The firm will conduct ongoing monitoring and enforce disciplinary action for reaches of the code.