Code of Business Conduct

We aim to apply the highest standard in the conduct of our business. We demand honesty and integrity in everything we do, and will ask the same from our counterparties.

Herewith we lay out our core values.

We value our reputation.

Relations with our clients

Honesty and integrity in our dealings with clients are paramount and are prerequisites for a successful and sustained relationship. We aim to maintain long-term relations with our clients by providing a range of services which are adapted to clients’ needs. We endeavor to ensure that our services are adequate and up to the highest standards. We will only present 3rd party products or services of companies which to the best of our knowledge share our business conduct standards.

We maintain confidentiality of client information, save where the law requires disclosure, or the client has given prior written or electronic consent.

Relations with employees

We respect the individual and seek to provide job satisfaction by creating a friendly and productive environment in which all existing and prospective employees can access all appropriate employment opportunities. We encourage and help people in our Team, at all levels, to develop skills, knowledge, and effectiveness to enhance their contribution to our performance and share responsibilities.

We expect members of the Team to avoid situations that present a potential conflict between their interests and the policies of this Code. Members of the Team should handle any potential or actual conflict in an ethical manner in accordance with the Code.

We do not allow solicitation, acceptance or provision of any benefit or gift for services provided by or to the Team. The only exceptions to this are normal business entertainment where this can be reciprocated at the same level, or reasonable gifts and tokens that cannot be construed as influencing the business relationship.

We ensure that information received in the course of our business dealings will not be used for personal gain or any purpose except that for which it is given. We ensure that our personal or financial interests do not contravene company policy on conflicts of interest.

We expect any member of the Team to speak out where there is suspicion of fraud or undesirable practice which comes to their attention and promptly report any suspected violation of this Code.

Accounting Controls, Procedures & Records

Applicable laws and Company policy require the Company to keep books and records that accurately and fairly reflect its transactions. In addition, the Company maintain a system of internal accounting controls that will ensure the reliability and adequacy of its books and records. Failure to meet such requirement may constitute a violation of law.

To satisfy these requirements the Company has adopted procedures to ensure that only proper transactions are entered into by the Company, that such transactions have proper management approval, that such transactions are properly accounted for in the books and records of the Company and that the reports and financial statements of the Company are timely prepared, understandable and fully, fairly and accurately reflect such transactions. All Directors and employees having any responsibility for such functions must be familiar with the Company's policies, accounting controls, procedures and records and must comply with their requirements.

Compliance with the Code of Business Conduct

The policy is incorporated within procedures for each area of the business and is continuously available to all employees.

We monitor adherence to the policy as part of the overall audit process of the Company.

Relations with our third party service providers

We aim to develop relationships with third party service providers based on mutual trust.

We aim to pay third party service providers on time and according to agreed terms of trade, provided the supplier performs according to the terms of the contract.

All confidential information relating to our relationship with third party service providers will be respected as such.

We respect copyright and intellectual property rights. Unauthorised reproduction, distribution or alteration of material covered by such rights is prohibited.

Relations with our competitors

We compete vigorously, but honestly and fairly.