"Code of Business Conduct and Ethics Ethical Behavior and"
Code of Business Conduct and Ethics Ethical Behavior and Business Integrity The purpose of this ‘Code of Business Conduct and Ethics of FIRST (the Code) is to establish and maintain high standards of business conduct and ethical behavior for all of us. It guides us when we interact with our stakeholders – (clients, employees, shareholders, and business partners). • Adherence to this Code and to FIRST policies and practices is fundamental to our culture and values • Combined with our Corporate Governance commitment and our Corporate Social Responsibility Guide lines, this Code will help us deliver sustainable value to our shareholders and clients, helping to achieve the long-term success of FIRST. • The Board of Directors and the Management of FIRST fully endorse this Code and its enforcement. • We expect all employees to follow this Code and conduct themselves in a manner that is above reproach, demonstrating our desire to be responsible corporate citizens. In case of doubt, we expect you to exercise good judgment – in line with the spirit of the Code’s standards. • Your adherence to this Code is essential to preserving FIRST’S most valuable asset – our reputation. ________________________________________________________________________ 1 First Investment Group FIRST is committed to business conduct that is above reproach. 1. We owe a duty to FIRST to advance its legitimate interests. 2. We strive to adhere to high ethical standards in all decisions we make. When deciding on the appropriate courses of action we take into account not only compliance with laws, rules and regulations, but also whether a decision or activity is consistent with FIRST’S values. 3. We must consult line managers or Legal and Compliance if our own interests actually or potentially interfere, or might appear to interfere, with FIRST’S interests. 4. We seek competitive advantage through superior performance rather than using any unfair business practice. 5. We do not provide or accept improper inducements in the course of our business dealings with others. Compliance with Laws, Rules and Regulations 1. FIRST is committed to adhering to the standards and restrictions imposed by applicable laws, rules and regulations. 2. We respect and strive to comply with the laws, rules and regulations of the countries where we operate and our own internal policies, guidelines and procedures. 3. We are committed to managing our relationships with FIRST’S regulators and standard setters in an open, transparent and co-operative manner. ________________________________________________________________________ 2 First Investment Group Disclosure and Public Communications 1. FIRST is committed to providing public information that is timely, accurate and comprehensible. 2. We strive to make full, fair, accurate, timely and clear disclosure in reports, documents or communications to regulatory authorities or the public. 3. We strive to ensure that our financial disclosure is in line with industry norms as they evolve. Client Relationships 1. FIRST is committed to creating relationships with clients built on trust. 2. We are committed to treating our clients fairly and with integrity. 3. We strive to identify and act in line with our legal and ethical responsibilities to our clients Client Confidentiality 1. FIRST is committed to upholding client confidentiality and protecting client information. 2. We maintain the confidentiality of any information entrusted to us by our clients, except when disclosure is authorized by them or required by applicable laws, rules or regulations. 3. We share such information internally with appropriate discretion. 4. We apply due care when receiving, handling and storing this data, and adhere to predefined data security standards and procedures designed to prevent unauthorized access, use, modification or destruction. ________________________________________________________________________ 3 First Investment Group Conflicts of Interest 1. FIRST is committed to identifying and managing or avoiding potential conflicts of interest in its business. 2. We are mindful of conflicts of interest; take all reasonable steps to assist in their identification and proper management, and escalate concerns promptly to management or control functions as appropriate. We are committed to maintaining and operating effective organizational and administrative arrangements to identify and manage conflicts of interest. Preventing Money Laundering 1. We operate effective, dynamic, risk-based money laundering prevention programs that seek to prevent, detect and report suspicions of money laundering. 2. We seek to identify and know our clients and screen them to assure acceptability. 3. We undertake ongoing due diligence and monitoring to assist in the identification of suspicious activities. Insider Dealing and Use of Information 1. FIRST is committed to the proper handling of inside information. 2. We share inside information with internal or external parties only in strict accordance with our internal procedures and applicable laws, rules and regulations. 3. We do not use inside information for any purposes other than those for which this information has been originally given to us. ________________________________________________________________________ 4 First Investment Group Protection and Proper Use of Assets 1. FIRST is committed to protecting its assets and to ensuring their effective use. 2. We do not take improper advantage of the assets and proprietary information available to us in our professional roles. 3. We seek to observe and protect intellectual and other property rights of FIRST. 4. We treat FIRST equipment and infrastructure with care, and do not use them inappropriately for non-FIRST business. Interactions between Employees 1. FIRST is committed to treating its employees in line with its ethical beliefs as outlined in FIRST Vision, Mission and Values, and to creating a diverse workplace free of discrimination and harassment. 2. We seek to treat our colleagues with respect and collaborate with them based on trust and mutual support. 3. We respect other opinions and differences in background, perspectives and expertise. Adherence to the code FIRST expects its employees and Board of Directors to adhere to the spirit and letter of this Code. The Code will apply in all circumstances. Violations of the standards in this Code may be subject to disciplinary proceedings, up to and including dismissal. ________________________________________________________________________ 5 First Investment Group Line managers, Legal or Compliance or other appropriate functional experts should be involved, or the procedures laid out in FIRST'S “whistle blowing” policies should be consulted, in the event of any observed violations of this Code or of applicable laws, rules or regulations, or if we are uncertain how to handle a situation with regard to this Code. FIRST does not allow retaliation for reports made in good faith of misconduct by others. ________________________________________________________________________ 6 First Investment Group