Kyte Broking Ltd. Conflicts of Interest Policy Summary Statement. Page 1 of 9

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Kyte Broking Ltd. Conflicts of Interest Policy Summary Statement. Page 1 of 9"

Transcription

1 Kyte Broking Ltd Conflicts of Interest Policy Summary Statement Page 1 of 9

2 Table of Contents Page 1. Introduction Purpose and Summary of Policy Clients and counterparties What is a Conflict of Interest? Conflicts Policy and Underlying Policies & Processes... 5 Page 2 of 9

3 1. Introduction This summary document is intended to provide clients and other relevant external parties with an overview of Kyte Broking Limited s ( Kyte ) approach to identifying, managing and avoiding potential Conflicts of Interest, Inducements, Bribery and Corruption. Kyte includes Kyte Broking Limited ( Kyte ), it subsidiaries and associated entities (including Appointed Representatives, franchises, etc.). 2. Purpose and Summary of Policy The Board and Senior Management recognise the importance of ensuring that Kyte complies with both the spirit as well as the letter of the relevant laws and regulations. A violation of these requirements will damage both the reputation and viability of the business, as well as potentially exposing both Kyte and relevant individuals to prosecution. This Conflicts of Interest Policy ( Policy ) is designed to ensure that Kyte, including associated entities (including appointed representatives, franchises, etc.), manages conflicts of interest fairly, both between itself and its clients and between clients. This framework is operated in accordance with the FCA s Principles, regulations and the applicable laws ( regulations ). The objectives of the Policy, as set out in this document, are to both serve the best interests of Kyte s clients, as well as meet the requirements of the regulations. To meet this objective and its obligations the Kyte Board has established a framework to identify, control and review conflicts of interest. This Policy serves as an explanatory guide as to how Kyte actively manages and deals with conflicts in the course of day-to-day business. The Policy may not cover all eventualities and all circumstances that may be encountered. The Policy is designed to be fully self-explanatory however where circumstances are not covered by this guidance, seek input from the Compliance department. When considering the identification of conflicts of interest it is important to realise that there is a broad spectrum and is rarely categorically or clearly defined. SUMMARY The key points being summarised as follows: The Policy applies to all Kyte entities, including branches, subsidiaries, appointed representatives and franchises ( Kyte ); This Policy sets out how Kyte manages potential / actual conflicts of interest across all of its activities and the requirements placed upon Kyte Individuals. This includes procedures and controls underlying the Policy; It is the responsibility of all Kyte Individuals to be aware of, identify and notify the appropriate parties of conflicts of interest. This will include avoiding inappropriate influences, improper inducements, notifying compliance of personal account dealings, external directorships and gifts & entertainment, etc.; Kyte treats its clients in a fair and equal manner, acting in an independent and impartial manner; Page 3 of 9

4 In the unlikely event that conflicts cannot be avoided, managed appropriately or removed via mitigation (e.g. for instance via disclosure to and subsequent agreement with the client) Kyte may decline to act on behalf of the client; Kyte operates a Remuneration Policy linked to and as part of the management of the conflicts of interest; All Kyte Individuals are required to maintain their awareness and vigilance for potential / actual conflicts of interest. The Compliance and Internal Audit monitoring and review programmes will encompass the management of conflicts of interest. This will include Kyte Individuals obtaining the appropriate authorisations; Kyte operates an appropriate notification, reporting and escalation structure in relation to identified conflicts of interest. In serious cases this may include reporting to external authorities such as the FCA or NFA; Records must be maintained of all identified conflicts of interest. This will include a Conflicts Map and a Conflict Log, which are maintained by Compliance. A failure to follow this policy will be considered by Kyte as a breach, which may (depending on the severity of the issue) result in internal disciplinary processes and/or reporting to the authorities. 3. Clients and counterparties Kyte transacts business only with clients that are classified under the FCA s criteria as: Eligible Counterparties Professional Clients 4. What is a Conflict of Interest? A conflict of interest arises in a situation where a person with responsibility to act in the interests of one person may be influenced in his action by an interest or association of his own, whether personal or business or employment related. Even if there is no evidence of improper action, a conflict of interest can create an appearance of impropriety that can undermine confidence in the ability of that person to act properly in his position. Conflicts of interest may arise in many forms in a financial group such as Kyte. In particular a conflict of interest may arise when Kyte is in a position of trust which requires it to provide a service or to exercise judgment on behalf of clients and Kyte, its related entities, counterparties and/or other clients who also have interests or obligations that might influence/interfere with the appropriate provision of that service or the exercise of judgment. A responsible approach to identifying, preventing and managing conflicts of interest, and mitigating the risk of potential damage to our clients forms an important element in protecting and enhancing Kyte's reputation. Page 4 of 9

5 5. Conflicts Policy and Underlying Policies & Processes a) Conflict Identification The Firm is continually identifying potential and actual conflicts of interest which constitute or may give rise to a material risk of damage to the interests of one or more clients. These conflicts are actively managed in a responsible way due to the duty owed towards clients (and regulators). The details of specific conflicts managed by Kyte are included in this Policy Statement: 1. Confidentiality Naturally, the Firm will hold confidential information on clients and its own business matters. Kyte operates policies and procedures to segregate relevant functions / roles, in order to avoid and manage situations arising that may result in a potential for conflicts of interest. In addition there are strict security measures in place to ensure the security of physical confidential information. 2. Outside Interests Corporate Due to the Firms structure some individuals in senior positions also hold senior positions at other companies connected to the Firm or which operate in the same sector. These individuals are aware this could lead to conflicts that could, ultimately, affect the service given to clients. All individuals conflicted in this manner will take all necessary steps to manage, avoid or minimise any conflict which may arise. 3. Outside Interests Personal External personal interests of Kyte Individuals are subject to a review process by Compliance following notification to ensure the external interest would not influence the individual s actions in relation to their role. External interests are, but not limited to, PA Dealing and external directorships/remuneration. The PA Dealing policy imposes certain restrictions and reporting requirements in relation to PA Dealings. The PA Dealing Policy is designed to prevent the personal outside interests of a Kyte Individual or their associated persons (as defined in the Personal Account Dealing Policy e.g. their family) and/or access to potential price sensitive information, influencing or distracting them from the investment services provided. Kyte Individuals and/or their associated persons may hold or wish to hold external directorships or engage in outside employment. Individuals are permitted to do this but are subject to notification requirements. This is to ensure that if the directorship involves a corporate entity whose activities may result in a conflict of interest arising (e.g. as a client or competitor to Kyte), such a conflict can be managed or avoided. Compliance maintains such information on the Conflicts Log. 4. Gifts, Entertainment, Inducements and Bribes The differentiation between Gifts & Entertainment, Inducements and Bribes may be considered as a broad spectrum and is never categorically or clearly defined. A bribe is generally considered to be an extreme version of an inducement, normally resulting in a definitive course of improper action. OK & Permitted Prohibited & potentially illegal Prohibited & Illegal Reasonable Inappropriate Bribe Gifts & Entertainment Inducement Page 5 of 9

6 The categorisation of an action will depend upon the circumstances of each case and is often best determined by common sense, considering the intended outcome, whether it is reasonable and proportionate. Kyte, through its Gifts & Entertainment Policy permits reasonable Gifts and entertaining, but prohibits inappropriate inducements and any acts that may be considered to be bribery under the UK Bribery Act. The Policy applies to all Kyte Individuals in relation to any benefit or consideration (whether in monetary form or not) that is intended to place an undue obligation on the recipient or to influence them to act inappropriately (improper performance). It is an accepted market practice that the Firm provides reasonable gifts and entertainment as part of client relationships. Such reasonable rewards are required to fall within the controls and limits established by the Gifts & Entertainments Policy. Kyte is subject to the requirements under the UK Bribery Act and has a policy that it will neither give nor receive bribes, as defined under the Act. Kyte s Policy and related procedures form part of the systems and controls required to prevent the occurrence of bribery under the UK Bribery Act. It is highlighted that it is a criminal offence to offer, give and/or accept a bribe. Kyte has summarised these three categories (Gifts and Entertainment, Inducements and Bribes) and defined in Section 7 Definitions. It is very important when considering the context when giving or receiving of gifts or entertainment to have regard to any current or anticipated contractual activity with the individual or entity concerned (e.g. are there open contractual negotiations?). 5. Commission income received On occasion, Kyte may execute transactions on behalf of a client categorised as an Eligible Counterparty and receive commissions from a counterparty acting as a Market Maker. For the avoidance of doubt, if a client has been categorised as a Professional client and the order is executed with another counterparty who is acting as a Market Maker, the Firm will not receive payment for order flow from that Market Maker counterparty. This conflict with Eligible Counterparties is managed in the form of trade surveillance monitoring to ensure customers have been treated fairly and also through increased monitoring, in relation to the allocation of business to market makers, to ensure business has been placed in the best interests of the client and not for the in the interests of the Firm via payment received for order flow. 6. Production of promotional material The Firm has a number of individuals who dedicate a significant proportion of their time to producing promotional material which includes: market commentary, financial promotions and, on occasion, non-independent research. All individuals producing material in this manner communicate and deal with clients will be subject to certain restrictions in order to manage any conflict. There are additional requirements in relation to any transaction undertaken for their own account. Any material which is considered to amount to more than market colour will require pre compliance approval. The Firm does not produce Investment Research. 7. Relationships Page 6 of 9

7 Personal relationships between individuals at the Firm and individuals/entities connected to the Firm and/or in the industry are likely to exist. Where this arises the relevant individuals are subject to increased monitoring to ensure interests of clients are not being jeopardised and, where required, blocks can be put in place to prevent individuals from dealing/benefiting from the related individual/entity. 8. Third Parties, including External Auditors Kyte, through its processes, will consider its relationships and business activities with third parties and whether these may result in conflicts of interest. This specifically includes the use of statutory auditors in relation to consultancy and/or other non-financial audit roles. b) Conflict management To assist with identifying and managing conflicts, the below principles have been created. They have been designed to assist with any unforeseen conflict not covered in the policy. Note, disclosure is not relied upon as a method of managing conflicts and will only be used as a last resort after all other pro-active methods have failed to manage conflicts effectively. 1. Identification of conflicts of interest Kyte Individuals are required to consider and assess whether through their roles, activities, outside interests, etc., potential / actual conflicts arise. The principle is designed to ensure that Kyte identifies and assesses conflicts of interest appropriately. This is to enable Kyte to pro-actively manage potential / actual conflicts of interest that may entail a material risk of damage to the interests of its clients. 2. Fair and equal treatment This principle ensures that clients are always treated fairly and equally when either advising them or dealing on their behalf. In particular, where a Kyte Individual is aware that they or the Firm has a material interest, which could influence their dealings with or the provision of advice to the client, that interest must be disregarded. Kyte Individuals must act in the interests of the client. 3. Independence and impartiality Relevant persons must act independently and impartially, in the interests of the client, ignoring any conflicting interest that may arise between the client, Kyte and/or the Kyte Individual. 4. Clients, counterparties and third parties The Firm s general processes in relation to client take-on are designed to act as a supporting control, preventing any party who would not be authorised from a regulatory or internal procedure perspective, from transacting business with Kyte. 5. Segregation / Chinese Walls Kyte operates processes and procedures to segregate relevant functions / roles, in order to avoid and manage situations arising that may result in a potential for conflicts of interest. Chinese Walls are procedures used to prevent or control the flow of sensitive information (Kyte Individuals, clients and/or third parties) where there is a risk of conflict of interest arising from the exchange of information, which may harm the interests of one or more clients. This includes physical barriers, segregation of data and roles. Page 7 of 9

8 6. Declining to act Even with appropriate management techniques, there may be some situations where it may not be possible for Kyte to act on behalf of a client. Due to the nature of the investment business Kyte is involved in, it is unlikely that situations will arise whereby the conflict is so severe that that even with appropriate management techniques, Kyte would have to decline to act on behalf of a client. However in the event that such a situation arises, where it is deemed that Kyte best not act for a client, the case should be referred to the Compliance department. 7. Inappropriate influences Kyte operates procedures and controls to prevent or limit any person, including third parties, exercising inappropriate influence over the way in which a relevant person carries out services or activities. These procedures and controls include segregation of functions and oversight. 8. Firm Remuneration Kyte has a Remuneration Committee and operates under a Remuneration Policy, in accordance with the FCA s Remuneration Code. As part of the Remuneration Policy, Kyte manages the conflicts of interest, in a manner designed to ensure appropriate links exist between risks and that rewards. This is to be achieved through the combination of effective remuneration design and oversight of both remuneration policy and outcomes. Material remuneration decisions are to be approved by the Remuneration Committee. Kyte Individuals are remunerated with primarily with reference to objective benchmarks of experience, ability, conduct and performance. The remuneration appraisals and resulting remuneration will consider if there is risk impact (including conflicts of interest), being adjusted appropriately to mitigate such risks. Under the Kyte business model, the franchises and appointed representatives fall outside of the scope of the Remuneration Policy, as the individuals are not directors, partners or employees. However, in the establishment of contractual relationships with these parties, the payments for services will take into account the potential for conflicts of interests. 9. Supervision Kyte supervises individuals who carry out activities on behalf of clients. This will include scenarios where the clients interests may conflict or represent different interests that may conflict, including those of the Firm. 10. Training & awareness All Kyte individuals, including new joiners, receive training and guidance on conflicts of interest as part of the Firm's overall compliance training programme, as and when deemed necessary by Compliance. It is the duty and the obligation of all Kyte Individuals to maintain their awareness and hence vigilance for conflicts of interest. 11. Monitoring and reviews Kyte monitors and reviews the activities of the entities in the group in a proportionate manner which is designed to ensure that the scope of identified potential/actual conflicts Page 8 of 9

9 remains appropriate to their business activities. The monitoring and reviews will be used to assess and confirm that the processes and controls operated by Kyte and the Kyte Individuals adhere to the regulations and internal procedures / policies. The results of the monitoring are included within the management information generated by Kyte. 12. Notification, management information, escalation and external reporting Kyte operates appropriate notification, management information, escalation and external reporting structures in relation to conflicts and their management. These processes are designed to ensure that the required information is provided to enable conflicts to be managed appropriately. The process will include the pre or post authorisation of certain actions to be taken by Kyte or the Kyte Individual e.g. Gifts and Entertainment. Where Kyte Individuals believe that conflicts are not being identified or managed appropriately, this is escalated to Function Heads and/or Compliance. This may fall within the remit of the Whistleblowing Policy. 13. Disclosure of a conflict of interest to a client Disclosure of conflicts of interest is one of the methods used to manage conflicts, where required the Firms conflicts will be disclosed. This includes disclosures in relation to fees and non-monetary benefits received from third parties, which fall outside Kyte s Gifts and Entertainment Policy. It is highlighted that, on its own, disclosure will not exempt Kyte from the obligation to maintain and operate effective organisational and administrative arrangements. Further, under NFA rules, the Firm must disclose any promotional material that makes a recommendation regarding security futures products that the Firm may have due to its activities in the underlying security. Should serious cases of conflicts of interest arise, the escalation and reporting may include the relevant external authorities such as the FCA and/or NFA. 6. Enquiries, Questions and Issues If you have any enquiries, questions or identify any issues concerning this summary document or specific conflicts of interest, please direct these to the Kyte Compliance Department via Page 9 of 9

CONFLICTS OF INTEREST POLICY HOTTINGER INVESTMENT MANAGEMENT

CONFLICTS OF INTEREST POLICY HOTTINGER INVESTMENT MANAGEMENT CONFLICTS OF INTEREST POLICY HOTTINGER INVESTMENT MANAGEMENT SUMMARY: OWNERS: This document represents Hottinger Investment Management Limited s (HIM) Conflicts of Interest Policy (the Policy). The Compliance

More information

CONFLICTS OF INTEREST POLICY AND PROCEDURES

CONFLICTS OF INTEREST POLICY AND PROCEDURES THE ECU GROUP PLC CONFLICTS OF INTEREST POLICY AND PROCEDURES CONTENTS The Guiding Principles... 2 Overview... 2 Obligations in respect of management of Conflicts of Interest... 3 Senior Management Responsibilities...

More information

Mayur Resources Ltd. 80 Robinson Road, #02-00, Singapore

Mayur Resources Ltd. 80 Robinson Road, #02-00, Singapore MAYUR RESOURCES LIMITED BOARD CHARTER 1. INTRODUCTION The Board of Directors (Board) of Mayur Resources Limited (Company) is accountable to shareholders of the Company and for the performance of the Mayur

More information

River and Mercantile Group Conflicts of Interest Policy

River and Mercantile Group Conflicts of Interest Policy River and Mercantile Group Conflicts of Interest Policy This policy is applicable to all employees, partners, directors and contractors engaged by the following entities: River and Mercantile Asset Management

More information

Conflict of Interest Policy

Conflict of Interest Policy Conflict of Interest Policy 19. Conflict of Interest Policy 19.1 Introduction In the context of identifying and managing conflicts of interests, there are various Luxembourg legal and regulatory requirements

More information

Code of Business Conduct & Ethics

Code of Business Conduct & Ethics For internal use only Code of Business Conduct & Ethics Date Author Senior Management Policy Owner Human Resources Policy Sponsor Chief Executive Officer Issuing Department Human Resources Initially Approved

More information

Anti-bribery corporate policy

Anti-bribery corporate policy Anti-bribery corporate policy 1. Scope and purpose of this guideline One of the key factors and reasons for the favorable reputation and image of Sb Accounting & Consulting is its ability and will to conduct

More information

Code of Conduct. Integral Diagnostics Limited ACN

Code of Conduct. Integral Diagnostics Limited ACN Code of Conduct Integral Diagnostics Limited ACN 130 832 816 Date: 1 October 2015 Code of Conduct Part A Scope and application 1 Purpose of the Code The Company is committed to a high level of integrity

More information

Solium Capital UK Limited. Conflicts of Interest Policy

Solium Capital UK Limited. Conflicts of Interest Policy Solium Capital UK Limited Conflicts of Interest Policy June 2018 1 Document history Section for use by the Compliance Officer/Head of Compliance only Action Author Date Comment (Amendment/update/new release)

More information

Group Code of Ethics

Group Code of Ethics Updated July 2016 Group Code of Ethics Introduction Eurofins' mission, vision and values set out the conditions for our long-term success and are a core part of the way we expect employees of the companies

More information

ANTI-CORRUPTION POLICY

ANTI-CORRUPTION POLICY ANTI-CORRUPTION POLICY CONTENTS 1. PREFACE... 3 1.1. ASTM s Commitment to Fighting Corruption... 3 1.2. Legislative Framework... 3 1.3. Recipients and Scope of Application... 3 2. INTRODUCTION... 4 2.1.

More information

BUSINESS ETHICS AND CODE OF CONDUCT

BUSINESS ETHICS AND CODE OF CONDUCT BUSINESS ETHICS AND CODE OF CONDUCT The Countryside Group of Companies (the Group) is committed to the highest standards of business ethics and professional conduct. Maintaining a culture of honesty, trust

More information

Assume that any action you take could ultimately be publicized, and consider how you and PCA would be perceived. When in doubt, stop and reflect.

Assume that any action you take could ultimately be publicized, and consider how you and PCA would be perceived. When in doubt, stop and reflect. CODE OF ETHICS ( Code ) 8.1 Purpose The purpose of the Code of Ethics and Business Conduct is to set forth basic principles to guide you in your day-to-day activities as an employee, officer, or director

More information

Conflict of Interest Policy

Conflict of Interest Policy Conflict of Interest Policy 1 Purpose and scope When Nordea Group ( Nordea or the Group ) provides financial services, and within its business operations, Conflicts of Interest may arise between, inter

More information

INVESTMENT RESEARCH POLICY OF INDEPENDENCE AND CONFICT MANAGEMENT

INVESTMENT RESEARCH POLICY OF INDEPENDENCE AND CONFICT MANAGEMENT NEW STREET RESEARCH LLP INVESTMENT RESEARCH POLICY OF INDEPENDENCE AND CONFICT MANAGEMENT SUMMARY INTRODUCTION New Street Research LLP ( New Street ) conducts its business in accordance with the highest

More information

British Standard BS Specification for an Anti-bribery Management System. Summary

British Standard BS Specification for an Anti-bribery Management System. Summary British Standard BS 10500 Specification for an Anti-bribery Management System Summary BACKGROUND BSI Standards is the UK's National Standards Body. It is the UK representative at the International Organisation

More information

Code of Business Conduct

Code of Business Conduct Code of Business Conduct Table of contents 1 Introduction 4 2 Definitions 4 3 Compliance 4 Compliance with applicable laws Compliance with laws on competition and anti-trust Compliance with laws on corruption

More information

Code of Conduct Trans Adriatic Pipeline AG

Code of Conduct Trans Adriatic Pipeline AG Trans Adriatic Pipeline AG 2008 CONTENTS Message from the Management... 3 1 Scope of Application... 4 2 Responsibilities in External Relations... 4 2.1 Antitrust... 4 2.2 Trade Restrictions and Export

More information

Principle 6: A firm must pay due regard to the interests of its customers and treat them fairly.

Principle 6: A firm must pay due regard to the interests of its customers and treat them fairly. CONFLICTS OF INTEREST PROCEDURE THE PSIGMA INVESTMENT MANAGEMENT CONFLICTS POLICY SETS OUT ANY POTENTIAL CONFLICTS OF INTEREST THAT MAY ARISE THROUGH THE PROVISION OF SERVICES TO OUR CLIENTS. 1. Introduction

More information

Code of Business Conduct. March 2009

Code of Business Conduct. March 2009 1 GALLIFORD TRY PLC Code Of Business Conduct Introduction Galliford Try has four key values that it embraces whilst carrying out its work. These are: Excellence - Striving to deliver the best Passion -

More information

Janus Henderson Group plc. Code of Business Conduct

Janus Henderson Group plc. Code of Business Conduct Janus Henderson Group plc Code of Business Conduct This Code of Business Conduct (the Code ) has been adopted by the board of directors (the Board ) of Janus Henderson Group plc. The Code applies to all

More information

ETHICAL CODE OF CONDUCT

ETHICAL CODE OF CONDUCT S E C U R I N G T H E F U T U R E ETHICAL CODE OF CONDUCT 1 TABLE OF CONTENT 1. THE ETHICAL CODE OF CONDUCT 4 1.1 Purpose 4 1.2 Commitment 5 1.3 Presentation of the Code of Conduct 5 2. GENERAL PRINCIPLES

More information

Appendix 15 CORPORATE GOVERNANCE CODE AND CORPORATE GOVERNANCE REPORT

Appendix 15 CORPORATE GOVERNANCE CODE AND CORPORATE GOVERNANCE REPORT Appendix 15 CORPORATE GOVERNANCE CODE AND CORPORATE GOVERNANCE REPORT The Code This Code sets out the principles of good corporate governance, and two levels of recommendations: code provisions; and recommended

More information

Appendix 14 CORPORATE GOVERNANCE CODE AND CORPORATE GOVERNANCE REPORT

Appendix 14 CORPORATE GOVERNANCE CODE AND CORPORATE GOVERNANCE REPORT Appendix 14 CORPORATE GOVERNANCE CODE AND CORPORATE GOVERNANCE REPORT The Code This Code sets out the principles of good corporate governance, and two levels of recommendations: code provisions; and recommended

More information

The Bribery Act 2010 Policy and Procedure for the British Dietetic Association

The Bribery Act 2010 Policy and Procedure for the British Dietetic Association Background The Bribery Act 2010 Policy and Procedure for the British Dietetic Association The Bribery Act (the Act) creates a new offence which can be committed by commercial organisations which fail to

More information

Procurement Standard. For further information contact

Procurement Standard.  For further information contact Procurement Standard www.metrotrains.com.au/doing-business-with-metro For further information contact procurement@metrotrains.com.au Table of Contents 1. Introduction... 2 1.1 About Metro... 2 2. Procurement

More information

INTEGRITY COMPLIANCE GUIDELINES

INTEGRITY COMPLIANCE GUIDELINES AFRICAN DEVELOPMENT BANK GROUP African Development Bank Group Integrity and Anti-Corruption Department INTEGRITY COMPLIANCE GUIDELINES 1 1. Prohibition of Misconduct A clearly articulated and visible prohibition

More information

GENTING MALAYSIA BERHAD (58019-U) CODE OF CONDUCT AND ETHICS

GENTING MALAYSIA BERHAD (58019-U) CODE OF CONDUCT AND ETHICS GENTING MALAYSIA BERHAD (58019-U) CODE OF CONDUCT AND ETHICS All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means,

More information

Synergy Health Ethics Policy Outline

Synergy Health Ethics Policy Outline Synergy Health Ethics Policy Outline Introduction Dear Colleague At Synergy Health we are committed to carrying on our business ethically and in line with good business practices. This is important both

More information

SUNRISE TELECOM CODE OF BUSINESS CONDUCT AND ETHICS Overview Sunrise Telecom is committed to its customers, partners, employees and stockholders.

SUNRISE TELECOM CODE OF BUSINESS CONDUCT AND ETHICS Overview Sunrise Telecom is committed to its customers, partners, employees and stockholders. SUNRISE TELECOM CODE OF BUSINESS CONDUCT AND ETHICS Overview Sunrise Telecom is committed to its customers, partners, employees and stockholders. Accordingly, we believe that operating with integrity is

More information

This document articulates ethical and behavioral guidance for all NGA Human Resources companies, employees, and business partners (such as suppliers,

This document articulates ethical and behavioral guidance for all NGA Human Resources companies, employees, and business partners (such as suppliers, This document articulates ethical and behavioral guidance for all NGA Human Resources companies, employees, and business partners (such as suppliers, agents, vendors and sub-contractors). To help guide

More information

Code of Ethics for Senior Financial Officers

Code of Ethics for Senior Financial Officers Code of Ethics for Senior Financial Officers Department Issuing Code: Corporate Compliance Executive Sponsor: Chief Compliance Officer, Black Knight, Inc. Code Owner: Chief Compliance Officer, Black Knight,

More information

Appendix 15 CORPORATE GOVERNANCE CODE AND CORPORATE GOVERNANCE REPORT

Appendix 15 CORPORATE GOVERNANCE CODE AND CORPORATE GOVERNANCE REPORT Appendix 15 CORPORATE GOVERNANCE CODE AND CORPORATE GOVERNANCE REPORT The Code This Code sets out the principles of good corporate governance, and two levels of recommendations: code provisions; and recommended

More information

1. What is Bribery? 2. Safeguards A. Risk Assessment. B. Accurate Books and Record Keeping

1. What is Bribery? 2. Safeguards A. Risk Assessment. B. Accurate Books and Record Keeping Anti Bribery Policy Protocol is committed to the highest possible standards of openness, probity and accountability. This Anti Bribery policy applies to those who work for or on behalf of Protocol National

More information

Ethical Business Policy

Ethical Business Policy Business Policy Author : Carole O Neil / Samantha Hammond Opelt Approved By : Date : July 2016 Revision : HR Policy 026 Business Policy Revision 5 Revision No 005 Page 1 of 5 Scope of Policy At Cundall,

More information

Corporate Code of Business Conduct and Ethics

Corporate Code of Business Conduct and Ethics Corporate Code of Business Conduct and Ethics A MESSAGE FROM OUR CHAIRMAN, PRESIDENT AND CHIEF EXECUTIVE Honesty and integrity are paramount values at TRC. Our commitment to strict ethical standards has

More information

Code of Conduct Providing Safety through our Conduct

Code of Conduct Providing Safety through our Conduct Providing Safety through our Conduct 3 Dear colleagues Safety is the core service provided by Baloise. Safety is behind every product, every achievement and every service. Safety is created daily through

More information

CODE OF BUSINESS CONDUCT AND ETHICS

CODE OF BUSINESS CONDUCT AND ETHICS CODE OF BUSINESS CONDUCT AND ETHICS INTRODUCTION This Code of Business Conduct and Ethics (the Code ) embodies the commitment of Sama Resources Inc. ( Sama ) to conduct its business in accordance with

More information

CODE OF BUSINESS CONDUCT AND ETHICS

CODE OF BUSINESS CONDUCT AND ETHICS 1 ST FRANKLIN FINANCIAL CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS Introduction This Code of Business Conduct and Ethics ( Code ) describes the basic principles of conduct that we share as officers

More information

code of conduct + ethics

code of conduct + ethics code of conduct + ethics 1 Home Code of Conduct and Ethics Contents A culture of integrity Our values 3 3 Aurecon s is the focal point of our policy on ethical business and promotes acting with integrity

More information

Code of Conduct: Obligation to Stakeholders

Code of Conduct: Obligation to Stakeholders Policy Owner: Contact Officers: Policy Number: Approved by: College Director/Principal Business Manager QBIPO009 Senior Management Group Date Approved: 22 October 2011 Last Reviewed: July 2016 Related

More information

APES 320 QUALITY CONTROL FOR FIRMS

APES 320 QUALITY CONTROL FOR FIRMS May 2006 ACCOUNTING PROFESSIONAL AND ETHICAL STANDARDS BOARD APES 320 QUALITY CONTROL FOR FIRMS (Effective as at 1 July 2006) CONTENTS Paragraphs Introduction 1-5 Definitions 6 Elements of a System of

More information

Code of Conduct INTRODUCTION

Code of Conduct INTRODUCTION INTRODUCTION Kingspan Group plc is committed to acting responsibly in its business, and maintaining high standards of ethics and integrity in all its dealings with its stakeholders, be they investors,

More information

STATEMENT OF BUSINESS ETHICS

STATEMENT OF BUSINESS ETHICS STATEMENT OF BUSINESS ETHICS CONTENTS Foreword 1 About us 2 Our Code of Conduct 3 Our values 3 Guiding principles 4 - Safety 4 - Value for money 4 - Open, fair and honest 4 Essential Energy procurement

More information

ALDI Australia. Code of Conduct

ALDI Australia. Code of Conduct ALDI Australia Code of Conduct ALDI Australia Code of Conduct October 2015 2 Content 3 Introduction 4 5. Fair Competition 18 CR Principles, Code of Conduct, and AMS 6 1. General Principles 8 1.1. Compliance

More information

CORPORATE GOVERNANCE. as at 12 September Lycopodium Limited ABN: Level 5, 1 Adelaide Terrace, East Perth Western Australia 6004

CORPORATE GOVERNANCE. as at 12 September Lycopodium Limited ABN: Level 5, 1 Adelaide Terrace, East Perth Western Australia 6004 CORPORATE GOVERNANCE as at 12 September 2016 This document is the property of. It must not be copied or reproduced in any way or transmitted on to any third party without written authority from. ABN: 83

More information

PostNL group procedure

PostNL group procedure 1 January 2017 PostNL Holding B.V. Audit & Security PostNL group procedure on fraud prevention guidance on bribery and corruption Author Director Audit & Security Title PostNL group procedure on Fraud

More information

Page: Page 1 of 5 Effective Date: January 27, 2004 Authorized By: President and CEO Function: Executive

Page: Page 1 of 5 Effective Date: January 27, 2004 Authorized By: President and CEO Function: Executive Page 1 of 5 I. PURPOSE The Board of Directors has adopted the following Code of Business Conduct and Ethics (this Code ) for officers, directors and employees of RBC Bearings Incorporated (the Company

More information

Code of Ethics for Financial Advisers

Code of Ethics for Financial Advisers Financial Adviser Standards and Ethics Authority Code of Ethics for Financial Advisers Exposure Draft of Proposed Standard CONSULTATION OPEN Exposure Draft issued March 2018 Consultation closes 1 June

More information

Code of Conduct for Staff

Code of Conduct for Staff Diocese of Bristol Academies Trust Code of Conduct for Staff Date Adopted: 4 th June 2015 Date Reviewed:.v 1 Final Page 1 History of most recent Policy changes (must be completed) Date Page Change Origin

More information

Estia Health Limited ACN ( Company ) Approved by the Board on 17 November 2014

Estia Health Limited ACN ( Company ) Approved by the Board on 17 November 2014 Board Charter Estia Health Limited ACN 160 986 201 ( Company ) Approved by the Board on 17 November 2014 Board Charter Contents 1 Purpose of this charter 1 2 Role and responsibilities of the Board 1 2.1

More information

Verisk Analytics, Inc. Code of Business Conduct and Ethics As Amended June 5, 2018

Verisk Analytics, Inc. Code of Business Conduct and Ethics As Amended June 5, 2018 Verisk Analytics, Inc. Code of Business Conduct and Ethics As Amended June 5, 2018 1. Introduction This Code of Business Conduct and Ethics ( Code ) has been adopted by our Board of Directors and summarizes

More information

CORPORATE GOVERNANCE POLICY

CORPORATE GOVERNANCE POLICY CORPORATE GOVERNANCE STATEMENT Atlantic is committed to building a diversified portfolio of resources assets that deliver superior returns to shareholders. Atlantic will seek to achieve this through strong

More information

Tell Us North CIC. Anti-bribery Policy. Contents. Document details and review

Tell Us North CIC. Anti-bribery Policy. Contents. Document details and review Tell Us North CIC Anti-bribery Policy Contents 1. Introduction 2. What is bribery 3. Responsibilities of Directors, employees and volunteers 4. Areas of risk red flags 5. Raising concerns 6. Choice of

More information

Alfa Financial Software Holdings PLC Terms of Reference of The Audit and Risk Committee of The Board of Directors of The Company

Alfa Financial Software Holdings PLC Terms of Reference of The Audit and Risk Committee of The Board of Directors of The Company Alfa Financial Software Holdings PLC Terms of Reference of The Audit and Risk Committee of The Board of Directors of The Company adopted by the board on 15 May 2017 1. Background 1.1 The board has resolved

More information

Subject: Kier Group plc Business Ethics Policy. Document type: Policy Authorised by: Kier General Counsel & Company Secretary.

Subject: Kier Group plc Business Ethics Policy. Document type: Policy Authorised by: Kier General Counsel & Company Secretary. Kier Group plc Business Ethics Policy Subject: Kier Group plc Business Ethics Policy Author: Compliance Document type: Policy Authorised by: Kier General Counsel & Company Secretary Version 3 Effective

More information

April Supplier Code of Conduct

April Supplier Code of Conduct April 2017 Supplier Code of Conduct 1. Introduction Canada Post Corporation (Canada Post), a federal Crown corporation, aims to maintain the confidence of all its stakeholders by minimizing legal, financial

More information

AMF Position Compliance function requirements

AMF Position Compliance function requirements AMF Position 2012-17 Compliance function requirements Reference texts: Articles 313-1 to 313-3, 313-5 to 313-7, 313-54, 313-75 of the AMF General Regulation The Autorité des Marchés Financiers applies

More information

BOARD CHARTER TOURISM HOLDINGS LIMITED

BOARD CHARTER TOURISM HOLDINGS LIMITED BOARD CHARTER TOURISM HOLDINGS LIMITED INDEX Tourism Holdings Limited ( thl ) - Board Charter 2 1. Governance at thl 2 2. Role of the Board 3 3. Structure of the Board 4 4. Matters Relating to Directors

More information

LLOYDS BANKING GROUP AUDIT COMMITTEE TERMS OF REFERENCE (LLOYDS BANKING GROUP PLC, LLOYDS BANK PLC, BANK OF SCOTLAND PLC & HBOS PLC)

LLOYDS BANKING GROUP AUDIT COMMITTEE TERMS OF REFERENCE (LLOYDS BANKING GROUP PLC, LLOYDS BANK PLC, BANK OF SCOTLAND PLC & HBOS PLC) LLOYDS BANKING GROUP AUDIT COMMITTEE TERMS OF REFERENCE (LLOYDS BANKING GROUP PLC, LLOYDS BANK PLC, BANK OF SCOTLAND PLC & HBOS PLC) These terms of reference are the terms of reference for the Audit Committee

More information

CIOB CONFLICT OF INTEREST POLICY

CIOB CONFLICT OF INTEREST POLICY CIOB CONFLICT OF INTEREST POLICY November 2012 OPS/ November 2012 CIOB CONFLICT OF INTEREST POLICY CONTENTS Page Number 1. Introduction - about this policy 3 2 What is a conflict of interest? 3 3 Managing

More information

Anti-Bribery Policy. At First Recruitment Group we are proud of our culture and we try to ensure that integrity underpins everything we do.

Anti-Bribery Policy. At First Recruitment Group we are proud of our culture and we try to ensure that integrity underpins everything we do. Policy Statement At First Recruitment Group we are proud of our culture and we try to ensure that integrity underpins everything we do. The Bribery Act 2010 and other prevailing anti-bribery laws in countries

More information

Acceleron Pharma Inc. Code of Business Conduct and Ethics

Acceleron Pharma Inc. Code of Business Conduct and Ethics I. INTRODUCTION Acceleron Pharma Inc. Code of Business Conduct and Ethics (Amended & Restated as of March 1, 2018) This Code of Business Conduct and Ethics ( Code ) provides a general statement of the

More information

Code of Business Principles & Ethics BTG Pactual

Code of Business Principles & Ethics BTG Pactual Code of Business Principles & Ethics BTG Our Vision and Values The key to our history of success is that, at BTG, we all share a single ambition ( our vision ) and the certainty that it can only be achieved

More information

Audit, Risk and Compliance Committee Terms of Reference. Atlas Mara Limited. (The "COMPANY") Amendments approved by the Board on 22 March 2016

Audit, Risk and Compliance Committee Terms of Reference. Atlas Mara Limited. (The COMPANY) Amendments approved by the Board on 22 March 2016 Audit, Risk and Compliance Committee Terms of Reference Atlas Mara Limited (The "COMPANY") Amendments approved by the Board on 22 March 2016 1. OVERVIEW 1.1 The primary objective of the committee is to

More information

Integrity and honesty in all our business dealings are core to the reputation of Aggreko and its long-term success. Therefore, appropriate ethical

Integrity and honesty in all our business dealings are core to the reputation of Aggreko and its long-term success. Therefore, appropriate ethical Ethics policy Integrity and honesty in all our business dealings are core to the reputation of Aggreko and its long-term success. Therefore, appropriate ethical behaviour is the responsibility of all Aggreko

More information

The Molina Healthcare Code of Business Conduct and Ethics

The Molina Healthcare Code of Business Conduct and Ethics The Molina Healthcare Code of Business Conduct and Ethics The Board of Directors of Molina Healthcare, Inc. has adopted this Code with respect to the business conduct and practices governing the affairs

More information

Conflicts of Interest Policy DB Group

Conflicts of Interest Policy DB Group Level 2 Conflicts of Interest Policy DB Group The information contained herein is the property of Deutsche Bank Group and may not be copied, used or disclosed in whole or in part, stored in a retrieval

More information

ANTI-CORRUPTION AND BRIBERY POLICY

ANTI-CORRUPTION AND BRIBERY POLICY ANTI-CORRUPTION AND BRIBERY POLICY Policy statement It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are

More information

MOLINA HEALTHCARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS

MOLINA HEALTHCARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS MOLINA HEALTHCARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS The Board of Directors of Molina Healthcare, Inc. has adopted this Code with respect to the business conduct and practices governing the affairs

More information

MOLINA HEALTHCARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS

MOLINA HEALTHCARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS MOLINA HEALTHCARE, INC. CODE OF BUSINESS CONDUCT AND ETHICS The Board of Directors of Molina Healthcare, Inc. has adopted this Code with respect to the business conduct and practices governing the affairs

More information

THE ARCG CHARTER. Issued in March 2008

THE ARCG CHARTER. Issued in March 2008 THE ARCG CHARTER Issued in March 2008 Index Part A Internal Audit Purpose Charter Mission Independence Scope & Responsibilities Authority Accountability Standards Part B Compliance Introduction Guiding

More information

Corporate Governance Statement John Bridgeman Limited

Corporate Governance Statement John Bridgeman Limited Corporate Governance Statement John Bridgeman Limited 1 Definition In this document: ASX Board Chair CFO Company Secretary Corporations Act Director means ASX Limited ACN 008 624 691 or the securities

More information

EPCOR Utilities Inc. Ethics Policy

EPCOR Utilities Inc. Ethics Policy ETHICS POLICY Contents 1. APPLICATION... 2 2. POLICY REQUIREMENTS... 2 Fundamental Principles... 2 Respectful Workplace... 2 Use of EPCOR Property and Resources... 2 Appropriate Use of Technology and Electronic

More information

COATS GROUP PLC (the "Company") TERMS OF REFERENCE FOR THE AUDIT & RISK COMMITTEE Adopted by the Board on 28 July 2017

COATS GROUP PLC (the Company) TERMS OF REFERENCE FOR THE AUDIT & RISK COMMITTEE Adopted by the Board on 28 July 2017 1. CONSTITUTION COATS GROUP PLC (the "Company") TERMS OF REFERENCE FOR THE AUDIT & RISK COMMITTEE Adopted by the Board on 28 July 2017 1.1 The Committee has been established by resolution of the Board

More information

Regional Development Australia

Regional Development Australia Regional Development Australia Code of Conduct and Ethics For committee members and staff This booklet provides information for members of the community who are considering joining the national Regional

More information

POLICY ON OFFERS OF GIFTS AND HOSPITALITY RECEIVED. Policy on Offers of Gifts and Hospitality Received 1

POLICY ON OFFERS OF GIFTS AND HOSPITALITY RECEIVED. Policy on Offers of Gifts and Hospitality Received 1 POLICY ON OFFERS OF GIFTS AND HOSPITALITY RECEIVED Policy on Offers of Gifts and Hospitality Received 1 TABLE OF CONTENTS 1 INTRODUCTION... 4 2 GENERAL RULES... 4 3 RULES FOR SPECIFIC GROUPS OF PERSONS...

More information

ZPG PLC (THE COMPANY) AUDIT COMMITTEE - TERMS OF REFERENCE adopted by the Board on 6 July 2017

ZPG PLC (THE COMPANY) AUDIT COMMITTEE - TERMS OF REFERENCE adopted by the Board on 6 July 2017 1. BACKGROUND ZPG PLC (THE COMPANY) AUDIT COMMITTEE - TERMS OF REFERENCE adopted by the Board on 6 July 2017 1.1 The board of directors (the Board) has resolved to establish an Audit Committee (the Committee).

More information

Ethics and integrity. Compliance: A guide for third parties

Ethics and integrity. Compliance: A guide for third parties Ethics and integrity Compliance: Doing the right thing together Living up to our ethical standards is not only the right thing to do, but it is also critical to the efficiency and reliability of our operations.

More information

Investec Specialist Investments (RF) Limited. Conflicts of Interest Management Policy January 2017

Investec Specialist Investments (RF) Limited. Conflicts of Interest Management Policy January 2017 Investec Specialist Investments (RF) Limited Conflicts of Interest Management Policy January 2017 1 CONFLICTS OF INTEREST MANAGEMENT POLICY Document Information Application principal risk: Regulatory Principle

More information

Code of ethics Code of BUsiNess CoNdUCt ANd ethics for employees ANd directors i. PURPose of Code ii. introduction iii. CoNfLiCts of interest

Code of ethics Code of BUsiNess CoNdUCt ANd ethics for employees ANd directors i. PURPose of Code ii. introduction iii. CoNfLiCts of interest CODE OF BUSINESS CONDUCT AND ETHICS FOR EMPLOYEES AND DIRECTORS I. Purpose of Code The purpose of this Code is: to promote the honest and ethical conduct of our directors and employees, including the ethical

More information

ADES International Holding Ltd (the Company )

ADES International Holding Ltd (the Company ) ADES International Holding Ltd (the Company ) Terms of Reference of the Audit Committee (The Committee ) (approved at a meeting of the board of directors (the Board ) held on 9 May 2017) 1. Introduction

More information

Corporate Governance Framework

Corporate Governance Framework Corporate Governance Framework Corporate Governance Framework The SMEC Holdings Limited ( SMEC or the Company ) Board of Directors (Board) is committed to building and maintaining a corporate governance

More information

APPROVED. Anti-Bribery and Corruption Policy OBJECTIVES PRINCIPLES WOODSIDE POLICY. Prohibition on corruption. Gifts and entertainment principles

APPROVED. Anti-Bribery and Corruption Policy OBJECTIVES PRINCIPLES WOODSIDE POLICY. Prohibition on corruption. Gifts and entertainment principles WOODSIDE POLICY Anti-Bribery and Corruption Policy OBJECTIVES Woodside is committed to conducting its business and activities with integrity. To achieve this objective: Woodside will not engage in corrupt

More information

Deutsche Bank. Code of Business Conduct and Ethics for Deutsche Bank Group

Deutsche Bank. Code of Business Conduct and Ethics for Deutsche Bank Group Deutsche Bank Code of Business Conduct and Ethics for Deutsche Bank Group Table of contents Our vision 1 Our Values and Beliefs 2 Safeguarding our Values and Beliefs 9 Adherence to this Code 10 Our vision

More information

Audit & Risk Committee Charter

Audit & Risk Committee Charter Audit & Risk Committee Charter Status: Approved Custodian: Executive Office Date approved: 2014-03-14 Implementation date: 2014-03-17 Decision number: SAQA 04103/14 Due for review: 2015-03-13 File Number:

More information

CODE OF CONDUCT A MESSAGE FROM OUR CEO. Dear Colleagues:

CODE OF CONDUCT A MESSAGE FROM OUR CEO. Dear Colleagues: CODE OF CONDUCT A MESSAGE FROM OUR CEO Dear Colleagues: Few things are as important as your reputation. That s true for companies and individuals alike. Logitech s ethical reputation is the foundation

More information

STANDARDS OF BUSINESS CONDUCT FOR NHS STAFF

STANDARDS OF BUSINESS CONDUCT FOR NHS STAFF STANDARDS OF BUSINESS CONDUCT FOR NHS STAFF May 2015 Standards of Business Conduct for NHS Staff Contents Page 1 Introduction 3 2 Principles of Conduct within NHS Dumfries and Galloway 3 3 Action for Managers

More information

BOM / BSD 7 /April 2001 BANK OF MAURITIUS. Guideline on Corporate Governance

BOM / BSD 7 /April 2001 BANK OF MAURITIUS. Guideline on Corporate Governance BOM / BSD 7 /April 2001 BANK OF MAURITIUS Guideline on Corporate Governance April 2001 Revised August 2012 Revised August 2014 Revised May 2016 Revised October 2017 ii TABLE OF CONTENTS INTRODUCTION...

More information

Code of conduct. OneMarket Limited ACN (Company)

Code of conduct. OneMarket Limited ACN (Company) Code of conduct OneMarket Limited ACN 623 247 549 (Company) Approved by the Board on 2 May 2018 Code of conduct 1 Purpose and application 1.1 Purpose of this code The board of directors of the Company

More information

SOUTHERN CROWN RESOURCES LIMITED ACN (Company) CORPORATE GOVERNANCE PLAN

SOUTHERN CROWN RESOURCES LIMITED ACN (Company) CORPORATE GOVERNANCE PLAN SOUTHERN CROWN RESOURCES LIMITED ACN 143 416 531 (Company) CORPORATE GOVERNANCE PLAN TABLE OF CONTENTS SCHEDULE 1 BOARD CHARTER... 1! SCHEDULE 2 CORPORATE CODE OF CONDUCT... 7! SCHEDULE 3 AUDIT AND RISK

More information

CORPORATE GOVERNANCE STATEMENT

CORPORATE GOVERNANCE STATEMENT CORPORATE GOVERNANCE STATEMENT In fulfilling its obligations and responsibilities to its various stakeholders, the Board is a strong advocate of corporate governance. This statement outlines the principal

More information

Australian Agricultural Projects Ltd ABN:

Australian Agricultural Projects Ltd ABN: Australian Agricultural Projects Ltd ABN: 19 104 555 455 Head Office Suite 2, 342 South Road Hampton East VIC 3188 E:admin@voopl.com.au APPENDIX 4G AND 2017 CORPORATE GOVERNANCE STATEMENT ANNOUNCEMENT

More information

Ethics & Procurement Integrity What You Need to Know as a Federal Employee Involved in the Procurement and Acquisition Process

Ethics & Procurement Integrity What You Need to Know as a Federal Employee Involved in the Procurement and Acquisition Process Ethics & Procurement Integrity What You Need to Know as a Federal Employee Involved in the Procurement and Acquisition Process U.S. Office of Government Ethics www.usoge.gov Ethics & Procurement Integrity

More information

FIRST NATIONAL BANK ZAMBIA LIMITED CODE OF ETHICS

FIRST NATIONAL BANK ZAMBIA LIMITED CODE OF ETHICS FIRST NATIONAL BANK ZAMBIA LIMITED CODE OF ETHICS 1. INTRODUCTION 1.1 Philosophy The FirstRand Banking Group and all its subsidiaries and associates globally, referred to as the Group, are committed to

More information

Code of Conduct. English Edition

Code of Conduct. English Edition Code of Conduct English Edition Cotent I. INTRODUCTION page 3 II. KME Principles of Business Conduct page 5 1. Fair competition and anti-trust laws page 5 2. Anti- corruption page 6 3. Environment, health

More information

MAXIMUS RESOURCES LIMITED

MAXIMUS RESOURCES LIMITED MAXIMUS RESOURCES LIMITED CORPORATE GOVERNANCE STATEMENT This statement reports on the main corporate governance practices of Maximus Resources Limited (Company) as at 25 October 2018 and it has been approved

More information

Appendix 8. M&T BANK CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS

Appendix 8. M&T BANK CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS Appendix 8. M&T BANK CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS Introduction. This ( Code ) covers a wide range of business practices and procedures. There are, of course, many corporate policies

More information

BOARD CHARTER. This Charter has been approved by the Board of Iluka Resources Limited (12 December 2017)

BOARD CHARTER. This Charter has been approved by the Board of Iluka Resources Limited (12 December 2017) This Charter has been approved by the Board of Iluka Resources Limited (12 December 2017) CONTENTS Introduction... 3 Primary Role of the Board... 3 Powers / Duties... 4 Board Membership... 5 Independence

More information

Code of ethics (or conduct) of Cama 1 S.p.a.

Code of ethics (or conduct) of Cama 1 S.p.a. Code of ethics (or conduct) of Cama 1 S.p.a. RULES & STANDARDS OF CONDUCT foreword part:/01 The Code of Ethics is an integral and fundamental tool of the model of organization, management and corporate

More information