Rules, Procedures, and Internal Controls Manual BRAM Bradesco Asset Management

Size: px
Start display at page:

Download "Rules, Procedures, and Internal Controls Manual BRAM Bradesco Asset Management"

Transcription

1 Rules, Procedures, and Internal Controls Manual BRAM Bradesco Asset Management MP_8231_ /06/ / 12

2 Table of contents 1. OBJECTIVE... Erro! Indicador não definido. 2. DEFINITIONS... Erro! Indicador não definido. 3. SCOPE... Erro! Indicador não definido. 4. REVIEW... Erro! Indicador não definido. 5. INTERNAL CONTROLS SYSTEM... Erro! Indicador não definido. 6. CONFLICT OF INTERESTS... Erro! Indicador não definido. 7. RULES FOR THE TREATMENT OF SOFT DOLLARS... Erro! Indicador não definido. 8. RULES OF SELECTION, RECRUITMENT AND SUPERVISION OF SERVICE PROVIDERS Erro! Indicador não definido. 9. PREVENTION OF MONEY LAUNDERING AND FINANCING OF TERRORISM... Erro! Indicador não definido. 10. BUSINESS CONTINUITY PLAN... Erro! Indicador não definido. 11. CONFIDENTIALITY RULES... Erro! Indicador não definido. 12. INFORMATION SECURITY SYSTEMS... Erro! Indicador não definido General Rules for Information Security TRAINING PROGRAM... Erro! Indicador não definido Learning path TreiNet PENALTY... Erro! Indicador não definido. MP_8231_ /06/ / 12

3 1. OBJECTIVE Establish guidelines that guarantee, through appropriate Internal Controls, the continued compliance with the standards, policies and existing regulations relating to investments, the activity of portfolio and securities management and ethical and professional standards. This document aims to establish the procedures adopted by the organizational structure in place at Bradesco Asset Management (BRAM). 2. DEFINITIONS For the purposes of this Manual, the words and expressions listed below shall have the following meanings, when began with capital letters, in the singular or in the plural form: (i) Manager of Securities Portfolios: conforming to ICVM 558, an individual or corporation, as applicable, that performs in a professional manner and is duly accredited by the Securities and Exchange Commission ("CVM") the activities related, directly or indirectly, to the operation, maintenance and management of a portfolio of securities, including the application of funds in the securities market on behalf of an investor; (ii) BRAM: Bradesco Asset Management S.A. DTVM., hereinafter referred to as a company, a duly authorized investment manager to manage portfolios of securities by the CVM; (iii) Conflict of Interest: a set of conditions in which professional judgment concerning a primary interest tends to be unduly influenced by a secondary interest; (iv) Internal Control: a set of regulatory activities and actions formally established by the Organization, in order to reduce financial losses or damage to the institution s reputation, increase the quality of the accounting, financial and management information, and safeguard compliance with laws, regulations, codes of conduct and self-regulation; (v) Managed Portfolio: portfolios managed by BRAM this is the composition of a portfolio of investments by an asset manager formally hired directly by the investor, for selection, acquisition, disposal and management of the risks inherent in such investments, as described in the service contract; MP_8231_ /06/ / 12

4 (vi) Funds: mutual funds under the management of BRAM a collective of resources in the form of open, closed or pooled funds, intended for investment in financial assets, securities, and/or other goods as provided for in the applicable legislation; and (vii) Related Parties: directors, employees, interns, outsourced employees and operators involved in the business activities of BRAM. 3. SCOPE This Manual applies to all Related Persons, especially to those who, through their duties, could have or do have access to confidential or privileged information, and must comply with the procedures described. This Manual complements the Bradesco Organization s Code of Ethical Conduct, and the Bradesco Organization s Code of Ethical Conduct of Financial and Capital Market these are also required knowledge for all Managers, Employees, and Collaborators. 4. REVIEW This manual should be reviewed, at least once a year and/or at any time, according to relevance, to ensure its suitability for the process, and requires the generation of a new revision. 5. INTERNAL CONTROLS SYSTEM The provisions of this chapter are in line with the Internal Controls and Compliance Policy of the Bradesco Organization. The structure of Internal Controls adopts mechanisms for evaluation and reporting of the control environment, in order to provide reasonable assurance regarding the proper conduct of business and achievement of specified objectives, in accordance with laws and external regulations, policies, standards, and procedures, codes of conduct and self-regulation. The methodology of internal controls used by the Organization was developed based on aspects of business, information technology, and governance. It consists of a cycle divided into eight phases, which provide systematic monitoring of internal controls. For the implementation phase, there is the involvement of MP_8231_ /06/ / 12

5 Departmental managers (first line of defense) and the area of Internal Controls (second line of defense) as well as work carried out by Internal Audit (third line of defense) evaluating the effectiveness of the internal controls system. In this context, the Department of Integrated Risk Control ( DCIR ) is responsible for exercising and subsidizing the risk management and internal control processes. Its functions are performed by professionals with the exclusive role of advising the Organization in the understanding and application of regulations, standards, and procedures related to internal controls, as well as supporting the implementation of methodologies, concepts, criteria and tools aimed at management of activities, with descriptions of all tests carried out. The management of internal control adopted by the Organization is supported by internationally recognized structures (ERM - Enterprise Risk Management COSO (2013) Entity Level Control (ELC) - PCAOB and Control Objectives for Information and Related Technology (COBIT) and meets the recommendations and requirements of local and foreign regulators. 1 The DCIR has a structure of Internal Control Agents ("ICAs") to advise, assist and monitor the implementation and enforcement of regulations, policies, standards and procedures, and in the evaluation of the implementation of internal controls to mitigate operational risks within BRAM. The Director Responsible for Internal Control must support managers in identifying, assessing and responding to risk, making sure the control is performed regularly and effectively, and to recommend, where necessary, corrective action or an action plan to ensure acceptable levels of risk in the processes of management of securities portfolios. 6. CONFLICT OF INTERESTS BRAM has a standard that establishes the guidelines for the identification, management, and mitigation of potential or actual conflicts of interest that may exist during the performance of third-party asset management for the purpose of preserving and protecting the client interests and ensure independence in management. 1 Source: External Audit Report. MP_8231_ /06/ / 12

6 Additionally, BRAM has established rules and procedures for the physical and computing segregation of all activities carried out at the company. 7. RULES FOR THE TREATMENT OF SOFT DOLLARS For the handling of the receipt of gifts and benefits (soft commissions) BRAM uses the Internal Regulations of the Bradesco Organization 2 and the Code of Conduct and Ethics of the Bradesco Organization 3 as guidelines, which prohibits to accept, obtain, fund, grant, pay, promise, sponsor or authorize, directly or indirectly, any benefit, monetary or not, in any manner whatsoever, in favor of the person or anyone that may represent an improper relationship. 8. RULES OF SELECTION, RECRUITMENT AND SUPERVISION OF SERVICE PROVIDERS In the case of managed portfolio, CVM Instruction 558 authorizes contracting with third parties, duly authorized, and where appropriate, authorized in the exercise of their respective activities for the provision of additional services to portfolio and securities management. In hiring service providers, the Outsourced Services Procurement and Management Policy and Procurement Policy of Bradesco Organization should be observed. In addition, to the organizational policies and procedures, BRAM uses criteria defined in internal procedures for selecting, contracting and supervision of service providers through: The process of "Due Diligence": that is based on a previous analysis, in which the service provider must allow access to information, documents and, if necessary, conducting a visit, in order to verify that the corporate structure and operation of the service provider is compatible with the exercise of activities for which they are to be hired; Evaluation and formal approval in committees; and Monitoring with semiannual reviews. 2 Normative System Number Version: 02 Updated: 12/03/ Normative System Number Version: 04 Updated: 08/07/2015 MP_8231_ /06/ / 12

7 9. PREVENTION OF MONEY LAUNDERING AND FINANCING OF TERRORISM The Bradesco Organization considers Prevention as part of its institutional commitment and responsibility to society. In light of this, it has policies, standards, and procedures aligned with ethical principles reproduced in its codes of conduct, and invests in training its managers and employees and Related Parties, to observe and comply with the provisions of the Customer Registration Information Policy 4 ; Know Your Customer Policy 5 ; Know Your Administration and Employee Policy 6 and Know Your Customer Normative 7. To be observed and enforced among the practices 8, we quote: a) The achievement or maintenance of a relationship with a client that should always be guided from the perspective of transparency and fairness of activities within the concept of "Know Your Customer", not only for commercial and/or for-profit interest that this client can provide in their relationship with the Bradesco Organization; b) Client data registration should be accurate, complete, updated, timely and thoroughly analyzed, ensuring its reliability and consistency, creating an understand their activities, source(s) of income and assets, average invoices, in addition to economic and financial profiles; c) In the case of corporate clients, the registration information should cover individuals authorized to represent them as well as its controllers. When there is participation of a corporation in the capital of the client, this should also be identified, including their representatives until it reaches an individual characterized as the final beneficiary; d) It should be taken into account at the beginning or maintenance of a relationship involving a Politically Exposed Person PEP, domestic or foreign, their families and/or related persons, that there are specific procedures in order to commence a relationship for the establishment of permanent business or to continue an existing relationship, with the enhanced monitoring of 4 Normative System Number Version: 04 Updated: 01/26/ Normative System Number Version: 05 Updated: 01/26/ Normative System Number Version: 06 Updated: 01/26/ Normative System Number Version: 01 Updated: 03/02/ Normative System Number Version: 01 Updated: 03/02/2016 MP_8231_ /06/ / 12

8 transactions and movements of these clients, as per the Politically Exposed Persons Corporate Standard - Account Opening and Maintenance 9. Every precaution should be taken for the timely identification of clients, investors, savers and those purchasing goods and/or services, domestic or foreign, maintaining full knowledge of transactions carried out, acting in this was to prevent operations and/or situations which exhibit evidence of being directly or indirectly related to any criminal infraction. When this refers to the Liabilities of the Funds under Management of BRAM, information on movements of shareholders (account holders and non-account holders) are centralized in an internal system, making it possible to identify the transactions carried out. For Assets, BRAM also considers issues of the Prevention of Money Laundering when making investment decisions to preserve the financial return of the managed assets, as well as in the care of their clients through products tailored to the demands and needs of each audience. Relying on methodologies, public surveys, and visits to invested companies, reports are generated by BRAM s analysis team, which are considered in the recommendations of buying and selling stocks, influencing the formation of portfolios, also used in support for investment decisions. In the case of the identification of suspected cases, these are deliberated upon at BRAM s Committee for Prevention and Money Laundering and Financing of terrorism. Thus, as for operations whose issuer or counterparty is involved with suspected money laundering or terrorist financing, a decision is made if the assets will remain invested or not. 10. BUSINESS CONTINUITY PLAN Taking the Continuity Management Policy of the Bradesco Organization as a guideline, and in line with the Business Continuity Management Standard 10, BRAM s Business Continuity Plan, aims to act in a planned and organized way before the occurrence of incidents, preserving the continuity of the areas of business considered as critical. 9 Normative System Number Version: 01 Updated: 03/02/ Normative System Number Version: 02 Updated: 01/02/2016 MP_8231_ /06/ / 12

9 Employees are directed to the Business Continuity Site, which is fully operational, so that in the event of an incident, there will be no interruption of management and controls. 11. CONFIDENTIALITY RULES For the good and faithful performance of BRAM s activities, it is necessary that employees have access to confidential information, normally understood as all information disclosed that is not public, regardless of the medium used, whether written, visual, physical, electronic (Confidential Information), to perform their duties is up to all Related Parties to commit themselves their successors to secrecy and not using Confidential to gain personal advantage. The Code of Conduct and Ethics of the Bradesco Organization 11 considers privileged information that which relates to acts or facts not disclosed to regulators, Stock Exchanges or other similar entities and, simultaneously, to shareholders and investors in general through distribution and publication by media outlets. The Code of Ethical Conduct for Financial and Capital Market Professionals of the Bradesco Organization 12 provides duties and rules on the confidentiality and protection of information assets, and on the handling of insider information, and Related Parties to its observance. 12. INFORMATION SECURITY SYSTEMS The Information Security Corporate Policy of the Bradesco Organization is the guideline for this chapter. Information security consists of a set of controls, including policies, processes, organizational structures, rules, and safety procedures. Its objective is the protection of client and company information, in terms of confidentiality, integrity and availability 13. Below is an illustration of information security cycle: 11 Available at: <Governance> 12 Available at: <Governance> 13 (accessed in June/2016). MP_8231_ /06/ / 12

10 Accessed in June/ General rules for information security 14 a) All of the Organizations equipment must be checked by Security and Monitoring Corporate Solutions; b) There should be restricted access to content on the Internet that does not comply with business activities and/or that which violate the ethical and legal principles that guide the Organization's activities; c) There must be technological solutions for network monitoring, with the aim of protecting sensitive information in accordance with pre-established rules; d) Changes in operating systems and other equipment settings of the Organization should only be carried out by the responsible technical area; e) Basic Corporate Profiles should be developed, evaluated and approved before they become official; f) Record obtained from monitoring can be used as evidence to show a violation of the Policy and Information Security Corporate Standards, which may serve as evidence in administrative and/or legal processes; g) The documentation of the specific access permits and/or justifications must be retained for verification; h) Any exceptions to the Corporate Profiles being monitored by Corporate Solutions should be documented and authorized, with an understanding of the risks involved; i) The management/control of exception authorizations should be configured with basic settings; 14 Normative System Number Version: 06 Updated: 07/10/2016 MP_8231_ /06/ / 12

11 j) In the event of information security incident, the Office of Inspector General shall be informed; 13. TRAINING PROGRAM This chapter is in line with the Strategic Statements for the Management of Human Resources of the Bradesco Organization, and with the Training and Development Policy of the Bradesco Organization. Annually, BRAM estimates the budget for investment in the training and development of skills of its employees. After approval of the budget by the Executive Board, BRAM plans the implementation of learning solutions with the UniBrad Universidade Corporativa Bradesco, which takes on the management of the budget Learning Path 15 Learning paths suggested by UniBrad are designed to facilitate employee career planning, with alternatives that take into account activities that have been planned technical or managerial the level of experience in the role and the competencies that each Professional requires to focus in on their full development TreiNet 16 The investment in the training and development, by way of actions that provide the potential for our employees to improve, is fundamental in the career strategy adopted by Bradesco. This way, the Organization offers all employees equal learning opportunities, in any location, the Organization offers a number of distance learning media, the highlight being TreiNet, which has content that meets internal and external policies and standards, in addition to good governance practices. Periodically, the Organization is inspected by regulatory agencies, which require that all employees be trained on a number of topics, as they seek to ensure the Organization's compliance with the regulations, the safety of employees, in addition to reliability in the relations with clients. 15 Normative System Number Version: 02 Updated: 09/25/ Normative System Number Version: 07 Updated: 05/25/2016 MP_8231_ /06/ / 12

12 The training available on TreiNet includes Information Security, Prevention of Money Laundering and Financing Terrorism, Ethics and Conduct, Internal Controls, Anti-Corruption, among other topics. With obligatory courses, the study of content, on the IntraNet, and on completing an evaluation, on TreiNet, must occur, exclusively, at the place and time of work. TreiNet is an important learning tool offered by the Bank to benefit its employees, enabling them to broaden their knowledge and manage their own personal growth plan. 14. PENALTY Any breach of the rules and procedures described in this document is subject to administrative penalties set by the CVM, as well as self-regulation of capital market entities, without prejudice to the civil and criminal liability for damage directly caused to the Fund and Portfolio Managed, its Shareholders and the market, as provided for in current regulations. MP_8231_ /06/ / 12

Anti-corruption Code of the Hitachi Rail Italy Group

Anti-corruption Code of the Hitachi Rail Italy Group of the Hitachi Rail Italy Group Issued by the Board of Directors on 10 th February 2016 INTRODUCTION Pag.3 1. PURPOSE Pag.3 2. COMPETENCY Pag.3 3. DEFINITIONS Pag.3 4. NORMATIVE REFERENCES AND BEST PRACTICES

More information

CODE OF ETHICS/CONDUCT

CODE OF ETHICS/CONDUCT CODE OF ETHICS/CONDUCT This Code of Ethics/Conduct ( Code ) covers a wide range of business practices and procedures. It does not cover every possible issue that may arise, but rather provides information

More information

PRYSMIAN GROUP ETHICAL CODE

PRYSMIAN GROUP ETHICAL CODE PRYSMIAN GROUP ETHICAL CODE the Prysmian ethical code Ethical Code Introduction pag. 1 Articles: Article 1 Article 2 Article 3 Article 4 Article 5 Article 6 Article 7 Article 8 Article 9 Article 10 Article

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

RELM WIRELESS CORPORATION (the Company ) CODE OF BUSINESS CONDUCT AND ETHICS

RELM WIRELESS CORPORATION (the Company ) CODE OF BUSINESS CONDUCT AND ETHICS RELM WIRELESS CORPORATION (the Company ) CODE OF BUSINESS CONDUCT AND ETHICS Introduction This Code of Business Conduct and Ethics covers a wide range of business practices and procedures. It does not

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

Metso Code of Conduct

Metso Code of Conduct Metso Code of Conduct From the CEO Dear colleague, Metso is a big global company with more than 12,000 employees and operations in over 50 countries. It is important that we work as a team that shares

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

PUBLIC AUTHORITY BOARD MEMBER DUTIES Anita Laremont, SVP - Legal & General Counsel Empire State Development Corporation December 2005

PUBLIC AUTHORITY BOARD MEMBER DUTIES Anita Laremont, SVP - Legal & General Counsel Empire State Development Corporation December 2005 PUBLIC AUTHORITY BOARD MEMBER DUTIES Anita Laremont, SVP - Legal & General Counsel Empire State Development Corporation December 2005 I. The duties and legal responsibilities of board of director members

More information

International investment bank. International Investment Bank Compliance Policy

International investment bank. International Investment Bank Compliance Policy International investment bank International Investment Bank Compliance Policy 2016 Contents 1. GENERAL PROVISIONS... 3 1.1. Scope of application... 3 1.2. Terms and definitions... 3 1.3. Abbreviations...

More information

Code of business conduct

Code of business conduct CODE OF BUSINESS CONDUCT OUR PRINCIPLES OF ACTION OUR PRINCIPLES OF ORGANIZATION OUR POLICIES Code of business conduct Code of business conduct Contents 01 Introduction 02 Compliance with laws and regulations

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

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

Corporate Governance Framework

Corporate Governance Framework Corporate Governance Framework Seera is committed to effective corporate governance, as this is a key aspect of the Bank's strategic direction and encompasses the Bank's overall operating mission. More

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

PRINCIPLES OF BANKING ETHICS (*)

PRINCIPLES OF BANKING ETHICS (*) 1 THE BANKS ASSOCIATION OF TURKEY PRINCIPLES OF BANKING ETHICS (*) I. Introduction: Ethics can be defined as a system of criteria and measures examining the values, norms and rules underlying the individual

More information

CODE OF ETHICS & BUSINESS CONDUCT

CODE OF ETHICS & BUSINESS CONDUCT CODE OF ETHICS & BUSINESS CONDUCT OF GROUP OF COMPANIES SIDMA S.A. Page 1 of 7 CODE OF CONDUCT SIDMA S.A., because of its long-lasting development and its many-years experience in business area, has succeed

More information

CODE OF CONDUCT Version 3 August 2016

CODE OF CONDUCT Version 3 August 2016 CODE OF CONDUCT Version 3 August 2016 Table of Contents 1. INTRODUCTION... 3 2. COMPLIANCE WITH LOCAL LAWS AND REGULATIONS... 3 3. FAIR COMPETITION... 4 4. ANTI BRIBERY AND ANTI CORRUPTION... 4 5. WORKING

More information

QUALITY MANAGEMENT SYSTEM

QUALITY MANAGEMENT SYSTEM Page: 1 of 13 Integrity Program Rev Date Description Reason 0 04/28/2017 Initial Issue - FUNCTION NAME SIGNATURE DATE Author/Reviser Antonio Gama 04/28/2017 Commentator Carlos Peixoto/Robert Smits 04/28/2017

More information

Anti-Corruption Compliance Program. December 2014

Anti-Corruption Compliance Program. December 2014 Anti-Corruption Compliance Program December 2014 AGENDA ANTI-CORRUPTION COMPLIANCE PROGRAM MESSAGE FROM THE CEO YOOX VALUES YOOXCOMPLY YOOXCOMPLY In Conducting Business with Third Parties YOOXCOMPLY In

More information

B. Braun Group. Code of Conduct

B. Braun Group. Code of Conduct B. Braun Group Code of Conduct Principles In accordance with our Corporate Strategy we, the family-owned B. Braun Group, have adopted legality and corporate responsibility into our Corporate Governance

More information

English Translation (For Information Purposes Only) CODE OF BEST CORPORATE PRACTICES. Introduction

English Translation (For Information Purposes Only) CODE OF BEST CORPORATE PRACTICES. Introduction English Translation (For Information Purposes Only) SCHEDULE A CODE OF BEST CORPORATE PRACTICES Introduction Upon the initiative of the Business Coordinating Council, the Corporate Governance Committee

More information

(Free Translation: For reference only Original in Portuguese)

(Free Translation: For reference only Original in Portuguese) 1 Summary 1. Purpose...3 2. Area of Application...3 3. Definitions and Abbreviations...3 4. Guidelines on the conflicts of interest...4 4.1 General Rules..........4 4.2 Specific Cases... 5 4.2.1. Equity

More information

The Company seeks to comply with both the letter and spirit of the laws and regulations in all jurisdictions in which it operates.

The Company seeks to comply with both the letter and spirit of the laws and regulations in all jurisdictions in which it operates. 1. Policy Statement CRC HEALTH GROUP, INC. CRC HEALTH CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS It is the policy of CRC Health Group to conduct its business affairs honestly and in an ethical manner.

More information

Risk management framework: compliance risk policy

Risk management framework: compliance risk policy Meeting of the Board 26 28 February 2019 Songdo, Incheon, Republic of Korea Provisional agenda item 30 1 February 2019 Risk management framework: compliance risk policy Proposal by the Risk Management

More information

Corporate Social Responsibility Policy

Corporate Social Responsibility Policy Corporate Social Responsibility Policy February 2018 Contents 1. Objectives 3 2. Scope of application of the Policy 3 3. Mission, vision and values 4 4. Operating procedures 4 4.1. Operating principles

More information

POLICY The following are the principles of the Conduent Global Ethics Policy that govern all practices concerning business ethics:

POLICY The following are the principles of the Conduent Global Ethics Policy that govern all practices concerning business ethics: SCOPE Conduent Business Services, LLC and its subsidiaries provide this policy as a guide for employees. This policy applies to all employees of Conduent Business Services, LLC and its subsidiaries and

More information

General Policies & Procedures. SV 5.0 Clean Harbors Vendor Code of Business Conduct and Ethics

General Policies & Procedures. SV 5.0 Clean Harbors Vendor Code of Business Conduct and Ethics 1. Purpose This Code is intended to govern the conduct of Clean Harbors, Inc. and all of its subsidiaries Vendors when doing business with or on behalf of Clean Harbors, Inc. For the purpose of this Code,

More information

B. Braun Group. Code of Conduct

B. Braun Group. Code of Conduct B. Braun Group Code of Conduct Principles In accordance with our Corporate Strategy we, the family-owned B. Braun Group, have adopted legality and corporate responsibility into our Corporate Governance

More information

Auditing of Swedish Enterprises and Organisations

Auditing of Swedish Enterprises and Organisations Auditing of Swedish Enterprises and Organisations March 1st 2018 version 2018:1 1 General Application 1.1 These General Terms govern the relationship between the auditor ( the Auditor ) and the client

More information

DRAFT MALAYSIAN STANDARD

DRAFT MALAYSIAN STANDARD DRAFT MALAYSIAN STANDARD STAGE : PUBLIC COMMENT (40.20) DATE : 25/04/2017-25/06/2017 Anti-bribery management systems- Requirements with guidance for use ICS: 03.100.01 Descriptors: Company organization

More information

Computer Programs and Systems, Inc. Code of Business Conduct and Ethics

Computer Programs and Systems, Inc. Code of Business Conduct and Ethics (as of January 28, 2013) Introduction This sets forth the guiding principles by which we operate Computer Programs and Systems, Inc. (the Company ) and conduct our daily business with our stockholders,

More information

Model 231. Adopted by the Board of Directors of Brainlab Italy s.r.l. on December 9, 2013.

Model 231. Adopted by the Board of Directors of Brainlab Italy s.r.l. on December 9, 2013. Model 231 Adopted by the Board of Directors of Brainlab Italy s.r.l. on December 9, 2013. Table of Contents Introduction Development of the Model Risk & Control Assessment Offences The Fundamental Principles

More information

The Company seeks to comply with both the letter and spirit of the laws and regulations in all countries in which it operates.

The Company seeks to comply with both the letter and spirit of the laws and regulations in all countries in which it operates. 1. Policy Statement ROOT9B HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS The Nasdaq listing standards require that the Company provide a code of conduct for all of its directors, officers and employees.

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

ASSOCIATED BANC-CORP CODE OF BUSINESS CONDUCT AND ETHICS

ASSOCIATED BANC-CORP CODE OF BUSINESS CONDUCT AND ETHICS ASSOCIATED BANC-CORP CODE OF BUSINESS CONDUCT AND ETHICS Introduction This Code of Business Conduct and Ethics covers a wide range of business practices and procedures. It does not cover every issue that

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

BUSINESS COMPLIANCE POLICY FOR BUSINESS PARTNERS

BUSINESS COMPLIANCE POLICY FOR BUSINESS PARTNERS BUSINESS COMPLIANCE POLICY FOR BUSINESS PARTNERS Table of Contents 1. Subject Matter and Objective... 2 2. Principles of Conduct... 2 2.1 General Law Abidance... 2 2.2 Bribery and Corruption... 2 2.2.1

More information

AMETEK, Inc. Code of Ethics and Business Conduct

AMETEK, Inc. Code of Ethics and Business Conduct AMETEK, Inc. Code of Ethics and Business Conduct Code of Ethics and Business Conduct A Message from the Chairman of the Board and Chief Executive Officer Dear AMETEK Colleague: AMETEK has been in business

More information

OUR CODE OF BUSINESS CONDUCT AND ETHICS

OUR CODE OF BUSINESS CONDUCT AND ETHICS OUR CODE OF BUSINESS CONDUCT AND ETHICS Introduction This Code of Business Conduct and Ethics covers a wide range of business practices and procedures. It does not cover every issue that may arise, but

More information

IMPACT AND IMPORTANCE OF INTERNAL AUDIT IN SUCCESSFUL MANAGEMENT OF THE ENTERPRISE

IMPACT AND IMPORTANCE OF INTERNAL AUDIT IN SUCCESSFUL MANAGEMENT OF THE ENTERPRISE 832 IMPACT AND IMPORTANCE OF INTERNAL AUDIT IN SUCCESSFUL MANAGEMENT OF THE ENTERPRISE Fatmir Mehmeti¹ 1 Audit Company ETIKA Kosovo, fatmir_mehmeti@yahoo.com Abstract Internal audit is an independent activity

More information

THE TIMBERLAND COMPANY CODE OF ETHICS

THE TIMBERLAND COMPANY CODE OF ETHICS THE TIMBERLAND COMPANY CODE OF ETHICS Code of Ethics MISSION AND VALUES STATEMENT We believe the honest and ethical conduct of our employees is an essential prerequisite to our success as a company. There

More information

CONFLICT OF INTEREST POLICY

CONFLICT OF INTEREST POLICY CONFLICT OF INTEREST POLICY Compliance & Ethics Version 3.1 January 5, 2018 CONFLICT OF INTEREST POLICY Compliance & Ethics Policy Owner: Emily Grymes, Director, Global Compliance & Ethics Policy Approver:

More information

CDM Smith Code of Ethics

CDM Smith Code of Ethics CDM Smith Inc. and all of its subsidiaries are committed to ethical conduct in our business practices. Since the firm s founding in 1947, we have always upheld a policy to conduct all business in a lawful

More information

Intel s Ethical Expectations for Suppliers and their Employees Supplier Ethical Expectations

Intel s Ethical Expectations for Suppliers and their Employees Supplier Ethical Expectations Intel s for s and their Employees 1 Agenda Business Principles Intel s Code of Conduct EICC and Key Policies Bribes, Kickbacks and Commissions Gifts and Gratuities Conflicts of Interest Use of Intel s

More information

LIVING OUR CORE VALUES. Supplier Code of Conduct

LIVING OUR CORE VALUES. Supplier Code of Conduct LIVING OUR CORE VALUES Supplier Code of Conduct Introduction to Our Supplier Code of Conduct Chesapeake Energy is committed to living our core values of integrity and trust, respect, transparency and open

More information

Linea Light Group Code of Ethics

Linea Light Group Code of Ethics Linea Light Group Code of Ethics SUMMARY COMPANY CODE OF ETHICS INTEGRITY AND RESPECT Compliance with laws Respect for individual differences Respect for the corporate image Respect for corporate assets

More information

Global Privacy Policy

Global Privacy Policy Global Privacy Policy Table of Contents Introduction... 2 Policy Overview Scope Application of Local Laws Definitions.... 3 Data Protection Principles... 4 Security and Access... 5 Special Circumstances....

More information

CODE OF ETHICS AND BUSINESS CONDUCT OF JUMBO S.A. (Approved by the BoD as of )

CODE OF ETHICS AND BUSINESS CONDUCT OF JUMBO S.A. (Approved by the BoD as of ) CODE OF ETHICS AND BUSINESS CONDUCT OF JUMBO S.A. (Approved by the BoD as of 1.2.2013) TABLE OF CONTENTS Page Article 1. General 3 Article 2. Compliance with Laws 3 Article 3. Protecting the Assets 3 Article

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

Sogefi Group Code of Ethics

Sogefi Group Code of Ethics June 13, 2016 1 Contents 1 INTRODUCTION... 3 2 MISSION AND ETHICAL VISION... 3 3 SCOPE OF APPLICATION... 3 4 REFERENCE PRINCIPLES AND PROVISIONS... 5 4.1 Fair business practices... 5 4.1.1 Compliance with

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

3.6.2 Internal Audit Charter Adopted by the Board: November 12, 2013

3.6.2 Internal Audit Charter Adopted by the Board: November 12, 2013 3.6.2 Internal Audit Charter Adopted by the Board: November 12, 2013 I. PURPOSE The purpose of this Charter is to formally define LACERS internal audit function s purpose, authority, and responsibility.

More information

CODE OF ETHICS AND CONDUCT (OCME Supplier

CODE OF ETHICS AND CONDUCT (OCME Supplier Page 1 of 5 UCT (OCME Supplier Code) Date Amendment records 03/12/2012 1st version Page 2 of 5 INDICE Introduction... 3 1. Application scope and addressees... 4 2.1 Business integrity... 4 2.2 Health and

More information

Ethical Corporate Management Best Practice Principles of ASPEED Technology

Ethical Corporate Management Best Practice Principles of ASPEED Technology Ethical Corporate Management Best Practice Principles of ASPEED Technology Date:2015.06.03 ( Amended ) Article 1 These Principles are adopted to assist the Company and its affiliated companies to foster

More information

SANCTIONS COMPLIANCE POLICY OF MIKRO KAPITAL GROUP

SANCTIONS COMPLIANCE POLICY OF MIKRO KAPITAL GROUP SANCTIONS COMPLIANCE POLICY OF MIKRO KAPITAL GROUP MIKRO KAPITAL MANAGEMENT S.A. 10, Rue C.M. Spoo- 2546 LUXEMBOURG G.-D. of Luxembourg APPROVED ON 12 OCTOBER 2018 Vincenzo Trani, Director Pape Sliou Ndao,

More information

CODE OF ETHICS AND CONDUCT OF THE TELECOM ITALIA GROUP

CODE OF ETHICS AND CONDUCT OF THE TELECOM ITALIA GROUP CODE OF ETHICS AND CONDUCT OF THE TELECOM ITALIA GROUP 6 December 2012 CONTENTS Article 1 - Premise 2 Article 2 - Founding values 2 Article 3 - Internal control and risk management system 3 Article 4 -

More information

III. STATEMENT OF CREDITBANK SAL APPROACH TO APPLICATION OF THE CORPORATE GOVERNANCE PRINCIPLES

III. STATEMENT OF CREDITBANK SAL APPROACH TO APPLICATION OF THE CORPORATE GOVERNANCE PRINCIPLES I. ORGANIZATION CHART II. SUBSIDIARIES CHART III. STATEMENT OF CREDITBANK SAL APPROACH TO APPLICATION OF THE CORPORATE GOVERNANCE PRINCIPLES Creditbank S.A.L. believes in and is committed to good corporate

More information

Contents. General Principles

Contents. General Principles CODE OF ETHICS Contents General Principles Relations with Third Parties Human Resources Customers Suppliers Landlords Public Authorities Shareholders and the Financial Community Competition and the Market

More information

Finance Code of Conduct

Finance Code of Conduct Finance Code of Conduct Finance Code of Conduct Purpose and Scope of Code Conduent Finance personnel are relied upon by Company management to: Develop honest and accurate financial statements; Safeguard

More information

NATIONAL BANK OF THE REPUBLIC OF MACEDONIA

NATIONAL BANK OF THE REPUBLIC OF MACEDONIA NATIONAL BANK OF THE REPUBLIC OF MACEDONIA Pursuant to Article 64 item 22 of the Law on the National Bank of the Republic of Macedonia ("Official Gazette of the Republic of Macedonia" No. 3/2002, 51/2003,

More information

HUMAN SERVICES DEPARTMENT INCOMPATIBLE ACTIVITIES POLICY

HUMAN SERVICES DEPARTMENT INCOMPATIBLE ACTIVITIES POLICY HUMAN SERVICES DEPARTMENT INCOMPATIBLE ACTIVITIES POLICY I. Purpose To establish a uniform department policy governing outside employment, activities, or enterprises for compensation which may be incompatible,

More information

Report on Compliance and Ethics

Report on Compliance and Ethics AVANGRID, Inc. CORPORATE COMPLIANCE 14 / February / 2018 Report on Compliance and Ethics I. Introduction This report describes actions taken by Avangrid and subsidiary management in connection with the

More information

We Maintain Accurate Financial Books and Records. We Strive to Comply with All Laws and Regulations. We Maintain the Confidences Entrusted to Us

We Maintain Accurate Financial Books and Records. We Strive to Comply with All Laws and Regulations. We Maintain the Confidences Entrusted to Us Code of Business Conduct and Ethics Contents: 1. Introduction: Philosophy Underlying This Code 2. 10 Principles: principles that establish a framework and provide guidance to all employees on how to ensure

More information

HUBER+SUHNER Business and Ethics Code

HUBER+SUHNER Business and Ethics Code HUBER+SUHNER Business and Ethics Code Message from the CEO and the Head Corporate HR HUBER+SUHNER is committed to conducting its business in accordance with high ethical standards, integrity and compliance

More information

China Airlines Ltd. Ethical Corporate Management Best Practice Principles

China Airlines Ltd. Ethical Corporate Management Best Practice Principles China Airlines Ltd. Ethical Corporate Management Best Practice Principles Amended and approved by the Shareholders Meeting on March 25, 2016 Article 1 These Principles are adopted to assist the Company

More information

SANTANDER GROUP GENERAL POLICY HUMAN RIGHTS POLICY

SANTANDER GROUP GENERAL POLICY HUMAN RIGHTS POLICY SANTANDER GROUP GENERAL POLICY HUMAN RIGHTS POLICY February 2018 Santander Group General policy Human Rights Policy I. Introduction This policy contains commitment of Banco Santander, S.A and its Group

More information

Schaeffler Group Corporate Supplier Code of Conduct. Transparency, Trust and Teamwork

Schaeffler Group Corporate Supplier Code of Conduct. Transparency, Trust and Teamwork Schaeffler Group Corporate Supplier Code of Conduct Transparency, Trust and Teamwork Area Of Application 1 AREA OF APPLICATION This code applies to all natural or legal persons, who sell or provide goods

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

SUPPLIER CODE OF CONDUCT

SUPPLIER CODE OF CONDUCT SUPPLIER CODE OF CONDUCT FOREWORD AND SUPPLIER CERTIFICATION CTS Corporation ( CTS ), founded in 1896, has built its reputation by producing quality products as well as by adhering to the highest ethical,

More information

Code of Conduct SAMSUNG SDI Co., Ltd.

Code of Conduct SAMSUNG SDI Co., Ltd. Code of Conduct 2010. 12. SAMSUNG SDI Co., Ltd. 1 IMPORTANT NOTICE SAMSUNG SDI RECOGNIZES THAT VARIOUS COUNTRIES MAY HAVE LAWS AND REGULATIONS THAT ESTABLISH DIFFERENT REQUIREMENTS FOR CORPORATE INTERGRITY.

More information

Best Buy Political Activity &

Best Buy Political Activity & Page 1 of 7 A. Policy Overview Purpose: This policy seeks to educate employees on political activity as it pertains to employment with Best Buy as a U.S.-domiciled company. Best Buy encourages employees

More information

CODE OF CONDUCT GUIDELINES AND STANDARDS OF INTEGRITY AND TRANSPARENCY

CODE OF CONDUCT GUIDELINES AND STANDARDS OF INTEGRITY AND TRANSPARENCY CODE OF CONDUCT GUIDELINES AND STANDARDS OF INTEGRITY AND TRANSPARENCY APRIL 2016 CONTENTS 1. INTRODUCTION 3 2. APPLICATION OF THE CODE OF CONDUCT 4 3. COMPLIANCE WITH THE CODE OF CONDUCT 4 4. REPORTING

More information

METHANEX CORPORATE MANUAL

METHANEX CORPORATE MANUAL SUB- 1.0 Scope All directors, officers and employees of Methanex Corporation and its subsidiaries ( Employee(s) ). 2.0 Purpose To provide Methanex Employees with: a) a set of standards meant to assist

More information

CORPORATE GOVERNANCE CODE

CORPORATE GOVERNANCE CODE CORPORATE GOVERNANCE CODE 2014 1 Contents Foreword Chapter 1.Basis for corporate governance Chapter 2.Shareholders rights Chapter 3.Professional investors Chapter 4.Shareholders meeting Chapter 5.Board

More information

International Rescue Committee, UK Modern Slavery Statement

International Rescue Committee, UK Modern Slavery Statement International Rescue Committee, UK Modern Slavery Statement Last Updated: 20/03/2018 Introduction International Rescue Committee UK ( IRC-UK ) recognises its responsibility and is committed to preventing

More information

Global Supplier Code of Business Conduct & Ethics

Global Supplier Code of Business Conduct & Ethics Global Supplier Code of Business Conduct & Ethics Version 2.0 2/15/2017 Contents Document Statement... 3 Scope... 3 1.0 Related or Referenced Policies... 3 2.0 Compliance with Laws, Regulations and the

More information

Defining and promoting excellence in the provision of mobile money services

Defining and promoting excellence in the provision of mobile money services SAFEGUARDING OF FUNDS DATA PRIVACY AML/CFT/FRAUD PREVENTION STAFF AND PARTNER MANAGEMENT CUSTOMER SERVICE TRANSPARENCY QUALITY OF OPERATIONS SECURITY OF SYSTEMS Defining and promoting excellence in the

More information

Acknowledgement of Aramco Overseas Company BV. Supplier Code of Conduct

Acknowledgement of Aramco Overseas Company BV. Supplier Code of Conduct IMPORTANT DOCUMENT PLEASE RETURN SIGNED ACKNOWLEDGEMENT Acknowledgement of Aramco Overseas Company BV Supplier Code of Conduct (Applicable to Vendors, Manufacturers, Contractors and Sub-Contractors) Aramco

More information

Corporate Social Responsibility Best Practice Principles

Corporate Social Responsibility Best Practice Principles Corporate Social Responsibility Best Practice Principles This document is copyrighted by the and may not be reproduced, stored, used, disseminated, or transmitted in any form or by any means, including,

More information

CODE OF CONDUCT ACS DOBFAR SPA GROUP. Acs Dobfar S.p.A Facta Farmaceutici S.p.A. Dphar S.p.A.

CODE OF CONDUCT ACS DOBFAR SPA GROUP. Acs Dobfar S.p.A Facta Farmaceutici S.p.A. Dphar S.p.A. CODE OF CONDUCT ACS DOBFAR SPA GROUP Acs Dobfar S.p.A Facta Farmaceutici S.p.A. Dphar S.p.A. 1 Foreword The success of the ACS DOBFAR S.p.A. Group (hereinafter ACSD) is based on values of transparency,

More information

- 2 - Report on the implementation by the Russian Federation of articles 5, 7, 8, 10, 12 and 13 of the United Nations Convention against Corruption

- 2 - Report on the implementation by the Russian Federation of articles 5, 7, 8, 10, 12 and 13 of the United Nations Convention against Corruption - 2 - Report on the implementation by the Russian Federation of articles 5, 7, 8, 10, 12 and 13 of the United Nations Convention against Corruption The Russian Federation signed the United Nations Convention

More information

Committed to the SDGs PEACE, JUSTICE AND STRONG INSTITUTIONS BUSINESS ETHICS

Committed to the SDGs PEACE, JUSTICE AND STRONG INSTITUTIONS BUSINESS ETHICS Committed to the SDGs PEACE, JUSTICE AND STRONG INSTITUTIONS BUSINESS ETHICS STRUCTURE Business Ethics System Evaluations Challenges Gloria María Úsuga Yepes Corporate Auditor "Our commitment and work

More information

PGE Group Code of Conduct for Business Partners

PGE Group Code of Conduct for Business Partners PGE Group Code of Conduct for Business Partners Dear Partners, At PGE Group, we operate in accordance with legislation in force and our internal ethical standards. PGE Group s Code of Ethics, Code of Conduct

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

Director s Draft Report

Director s Draft Report Office of Audit and Evaluation March 2, 2017 Director s Draft Report Protected B Table of contents Executive summary... i Introduction... 1 Focus of the audit... 2 Statement of conformance... 2 Observations...

More information

Contents. Code of Conduct

Contents. Code of Conduct Code of Conduct Contents 1 Introduction 3 2 Business ethics Applying responsible business practices 3 2.1 Compliance with laws and regulation 3 2.2 Accuracy of records and reports 3 2.3 Conflicts of interests

More information

VOYA Financial CODE OF BUSINESS CONDUCT AND ETHICS

VOYA Financial CODE OF BUSINESS CONDUCT AND ETHICS VOYA Financial CODE OF BUSINESS CONDUCT AND ETHICS Version 2.0 April 2014 Information Sheet ISSUED BY Voya Financial Compliance TARGET AUDIENCE All Voya Financial Directors and Employees OWNED AND APPROVED

More information

BIG LOTS, INC. CODE OF BUSINESS CONDUCT AND ETHICS

BIG LOTS, INC. CODE OF BUSINESS CONDUCT AND ETHICS September 2003 BIG LOTS, INC. CODE OF BUSINESS CONDUCT AND ETHICS Introduction This Code of Business Conduct and Ethics covers a wide range of business principles to guide all directors, officers and associates

More information

ETHICS AND BUSINESS INTEGRITY POLICY

ETHICS AND BUSINESS INTEGRITY POLICY ETHICS AND BUSINESS INTEGRITY POLICY 1.0 Chief Executive s Introduction: Behaving ethically is essential to working with Carillion. Our values of We care, We achieve together, We improve and we deliver

More information

CITY OF CORPUS CHRISTI

CITY OF CORPUS CHRISTI CITY OF CORPUS CHRISTI CITY AUDITOR S OFFICE Audit of Purchasing Program Project No. AU12-004 September 20, 2012 City Auditor Celia Gaona, CIA CISA CFE Auditor Nora Lozano, CIA CISA Executive Summary In

More information

716 West Ave Austin, TX USA

716 West Ave Austin, TX USA FRAUD-RELATED INTERNAL CONTROLS GLOBAL Headquarters the gregor building 716 West Ave Austin, TX 78701-2727 USA Figure 2.1 COSO defines an internal control as a process, effected by an entity s board of

More information

npliance IN 2008, MICROSOFT CORP. WAS FINED 899 MILLION Auditing for

npliance IN 2008, MICROSOFT CORP. WAS FINED 899 MILLION Auditing for IN 2008, MICROSOFT CORP. WAS FINED 899 MILLION EUROS (US $1.15 BILLION) BY EUROPEAN UNION REGULATORS for failing to comply with a 2004 antitrust order. The previous year, DaimlerChrysler paid a US $30

More information

TERMS OF REFERENCE OF THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS

TERMS OF REFERENCE OF THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS TERMS OF REFERENCE OF THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS 1. Purpose An Audit Committee (hereinafter called the Committee ) of the Board of Directors (hereinafter called the Board ) of the Business

More information

ANTI-BRIBERY GUIDELINES

ANTI-BRIBERY GUIDELINES ANTI-BRIBERY GUIDELINES FIND THE RIGHT SOLUTION IN respecting THE RULES FROM the GROUP viewpoint Approved by RINA S.p.A. Board of Directors on 22 nd July 2015. INDEX FOREWORD SCOPE FIELD OF APPLICATION

More information

Developing an Integrated Anti-Fraud, Compliance, and Ethics Program

Developing an Integrated Anti-Fraud, Compliance, and Ethics Program Developing an Integrated Anti-Fraud, Compliance, and Ethics Program Introduction Eric Feldman, CFE, CIG Affiliated Monitors, Inc. 2018 Association of Certified Fraud Examiners, Inc. CPE Information 2018

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

Code of Conduct as of june 2016

Code of Conduct as of june 2016 Code of Conduct as of june 2016 1. General Principles The undersigned company bases its business activities and decisions on universally held ethical values, in particular those of integrity, credibility

More information

Supplier Code of Business Conduct and Ethics

Supplier Code of Business Conduct and Ethics Supplier Code of Business Conduct and Ethics Table of Contents 1. Definitions 2. Purpose 3. Policy Statement 4. Workplace Standards and Practices and Compliance with the Law 5. Health, Safety and Environmental

More information

AKME STAR HOUSING FINANCE LIMITED

AKME STAR HOUSING FINANCE LIMITED AKME STAR HOUSING FINANCE LIMITED CODE OF CONDUCT FOR DIRECTORS AND SENIOR MANAGEMENT 1 CONTENTS I Purpose of the Code 3 II Definition & Interpretation 3 III Values of the Code 4 IV Philosophy of the Code..

More information