Code of Business Conduct & Ethics

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1 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 June 2012 Approved by Board Last Reviewed Next Review Date March 2015 Recipients All Summary The Code of Business Conduct & Ethics (the Code ) establishes the standards that govern the way we deal with each other, our customers, shareholders, regulators, governments, suppliers, competitors, the media and the public at large. This Code is a roadmap to guide staff to make decisions that meet the highest standards of integrity and professionalism. Scope of Application Entities: This Code applies to and its relevant service entities including Tower Bridge International Services L.P. (collectively referred to as the Firm ). Jurisdictions: This Code is applicable to personnel acting on behalf of the Firm. Relevant Business Areas and Individuals: All Business areas.

2 Contents 1. Introduction 1.1. Overview 1.2. Objective 2. Core Values 2.1. Core Values 3. Guidelines on the Core Values 3.1. Integrity, Respect and Ethical Conduct 3.2. Compliance with Laws, Rules and Regulations 3.3. Enterprising 3.4. People 4. Responsibility / Accountability and Governance 4.1. Key Responsibilities 4.2. Governance 5. Training and Communication 5.1. Induction Training 5.2. On-going Training 6. Other Information 6.1. Additional Guidance 6.2. Related Documentation 6.3. Glossary Appendix Appendix A - Change Control 2 of 10

3 1. Introduction 1.1. Overview For any business, as for any person, reputation is a priceless asset. As a responsible business enterprise and corporate citizen, the Firm is committed to meeting the highest standards of ethics, integrity, honesty, fairness and professionalism in every respect, without exception, and at all times. While achieving the Firm s business goals is critical to our success, equally important is the way in which we achieve them. Every employee and director of the Firm is expected and required to assess every business decision and every action on behalf of the Firm in light of whether it is right, legal and fair. This applies to all levels of the Firm, from major decisions made by the Board of Directors to day-to-day business transactions. This Code is intended to assist employees and directors to make such assessments to meet these expectations Objective The objective of the Code is to focus directors and employees on areas of ethical risk; provide guidance to help directors and employees recognise and deal with ethical issues; provide mechanisms to report unethical conduct; and foster a culture of honesty and accountability. No code of conduct can replace the thoughtful behaviour of an ethical director or employee. Accordingly, dishonest or unethical conduct or conduct that is illegal will constitute a violation of this Code, regardless of whether this Code specifically addresses such conduct. Not every situation can be addressed specifically in the Code. Employees are expected to apply the principles and guidelines outlined in the Code in exercising their judgment when faced with questions or issues that do not present obviously correct answers or approaches. Any concerns should be discussed with your manager and, if you are still uncertain, please seek advice and direction from the Compliance Department or Human Resources Department (or in the case of a director, the General Counsel), so that all relevant interests are fully recognised and properly served. This Code may be altered or modified from time to time and such changes will be notified to you. 2. Core Values 2.1. Core Values Trust and confidence are fundamental to the Firm s business. They take a long time to build and can be lost in a moment. Irresponsible or unethical behaviour can undo years of good work. So everyone, at every level, has a responsibility to act and carry out business in the right way. This means living and breathing a core set of values that guide everything we act, how we work and how we do business with our customers. 3 of 10

4 The Firm s Core Values provide a sense of common direction for employees and guidelines to conduct their day-to-day activities. They shape the decisions we make as individuals, departments and as an organisation. The values also determine who we are and how we operate as a business therefore, employees must demonstrate the Firm s Values as an essential part of how we go about achieving our objectives. The Code is based on the following Core Values of the Firm: Integrity, Respect and Ethical Conduct we understand that only through establishing a reputation for integrity, will we succeed in ensuring our long-term success. We also understand colleagues should be treated respectfully and that all employees should made to feel they can speak out. Compliance with Laws, Rules and Regulations we are committed to operating within an exemplary compliance and control environment that respects both the letter and spirit of all applicable laws and regulations. Enterprising we pride ourselves on an entrepreneurial business model based on seizing the commercial opportunities that arise from regulatory, technological and other structural changes in the financial industry. In capturing business opportunities, we will seek to avoid actual and perceived conflicts of interest and provide full, fair, accurate and timely disclosure to the public and regulators. People we are committed to recruiting, retaining and developing highly qualified people across all aspects of our business. This includes providing our people with proper delegation, guidance and oversight, ensuring they promptly report violations of the Code, and are accountable for complying with the Code. 3. Guidelines on the Core Values 3.1. Integrity, Respect and Ethical Conduct The Firm exercises the highest degree of ethical corporate conduct and recognises that customers, counterparties, regulators and the public have a right to openness and honesty in all their dealings with the Firm. As such, employees must conduct themselves in a manner that demonstrates commitment to the highest standards of personal integrity, and in ways that respect the reputation of the Firm. Respect in the workplace can be defined as consideration of others and for self. This includes treating people with courtesy and politeness; consideration for other people s privacy, their physical space and belongings; and respect for different viewpoints, physical ability, beliefs and personality. The Firm considers its trust and confidence in you to be essential to sustain a working relationship. Therefore, you must do the right thing and be aware of behaviours that lead to gross misconduct or gross negligence that can damage your and the Firm s reputation. The following is a non-exhaustive list of examples applying to personal integrity and respect: 4 of 10

5 Committing a criminal offence employees must inform the Human Resources Department or their Manager if charged with a criminal offence (e.g. physical violence or assault). Certain employees subject to licensing requirements may also be required to report the situation to the Financial Conduct Authority through guidance from the Compliance Department. Harassment, discrimination and equal opportunity in the workplace the Firm has a positive commitment to the promotion of equal opportunity and strives to provide a positive work environment. Employees have a responsibility to ensure equality of opportunity and not subject others to unwanted conduct which is offensive and intimidating such as bullying. Alcohol and substance abuse the Firm is committed to providing a working environment that is free from alcohol and drug abuse. Employees must not conduct their duties under the influence of alcohol or drugs, or deal in or abuse controlled drugs. All staff of the Firm are required to comply with the Substance Misuse Policy contained in the Firm's Staff Handbook and available on the Firm's Intranet. Gifts, entertainment and expenses employees must maintain an arm s length and professional relationship with clients and service providers and avoid the giving or receiving of excessive or lavish gifts or events that give the appearance of undue influence. Employees should also avoid personal financial transactions with clients and suppliers that may influence the employee s ability to perform his or her job. Use of internet, , electronic communication and social media employees must not download, access, store or forward inappropriate material. Also, employees must protect and not share login id and passwords. For further information, please refer to the Employee Handbook, Financial Crime Policy, Anti-Bribery Policy, Travel, Entertainment and Expenses Policy and Computer Security Policy amongst other policies. If in doubt, please contact the Human Resources Department or the Compliance Department Compliance with Laws, Rules and Regulations Concern for what is right should be the first consideration in all business decisions and actions and that includes compliance with the law. A variety of laws and regulations apply to the Firm and its operations and employees need to be familiar with, and observe, all laws and regulations relating to the Firm in the region in which they work and in other regions in which they may do business. As the violation of some laws carries criminal penalties, employees must avoid performing any task that could reasonably be considered legally suspect, even if it might be common practice in the country or region. Examples of criminal violations of the law include, among others: Making false or misleading disclosures in documents filed with the Regulators the Firm is committed to provide timely and accurate disclosures of all material information and, is also committed to transparency in its reporting. Employees involved in the preparation of the 5 of 10

6 financial and other disclosures of the Firm must comply with all applicable laws, rules and regulations. Trading on inside information employees or directors who either possess or have access to material, non-public information are prohibited by law from trading in securities related to that information. Theft and fraud employees must not engage in stealing, embezzling or misapplying the Firm s or customers funds or other assets. It is the responsibility of each director and employee to comply with the laws, rules and regulations applicable to the Firm and/or to him or her personally. No director or employee may delegate that responsibility to another person or to the Firm. For further information, please refer to the Compliance Manual, Personal Account Dealing Policy, Financial Crime Policy, Fraud Policy and Market Conduct Policy amongst other policies. If in doubt, please contact the Compliance Department Enterprising In pursuing business opportunities, the Firm needs to ensure that its entrepreneurial business model does not involve any irregular business conduct (which includes any criminal, fraudulent or illegal conduct, any impropriety, lack of professional responsibility or dishonesty). Such conduct will not be tolerated under any circumstances. Some of the most serious types of violations are described below: Anti-competitive behaviour generally, an agreement with a competitor to engage in activity that may unduly lessen competition (e.g. to set brokerage fees, commissions, prices etc.). Bribery and corruption the Firm will not enter into a business relationship or engage in an activity if it knows or has reasonable grounds to suspect that it is connected with or facilitates bribery or corruption. It is the responsibility of each director and employee to comply with applicable anti-bribery and corruption laws. Employees are required to report any suspicions of bribery or corruption. Money laundering making proceeds derived from criminal activity appear as if they came from legitimate business activity is a criminal offence, and so is knowingly failing to report a suspected money laundering scheme. The Firm must not knowingly initiate or be party to a money laundering scheme which could include any assistance in the scheme where we know or ought to have known that the transactions were improper. Suspicious money laundering situations must be reported to the MLRO. Conflicts of interest where there is a division of loyalty between the Firm s best interests and the interests of the employee or director that could possibly affect the employee s or director s judgement or actions relating to the Firm, a potential conflict of interest exists. Conflicts of interest will be permitted only after they are reported, reviewed and addressed to ensure that employees or directors will always act in the best interest of the Firm. Confidentiality of Information information received by employees about the Firm, its clients and about related third parties will be confidential and must be treated with care. Employees must act in a professional and ethical manner to ensure that confidentiality is maintained at all times. 6 of 10

7 For further information, please refer to the Compliance Manual, Anti-Money Laundering Policy, Financial Crime Policy, Anti-Bribery Policy and Conflicts of Interest Policy amongst other policies. If in doubt, please contact the Compliance Department People The Firm wishes to ensure that it selects, recruits and promotes people based solely on their suitability for the job and also ensure that opportunities for development and progress are afforded to all employees to achieve their potential. In return, the Firm expects that directors and employees will be courteous and respectful in all dealings with the public; other employees; and in all business relationships. Employees who are dealing with customers should: Act with skill, care and diligence in providing services to customers; Give clear, transparent, fair and balanced information and communicate clearly to the customer; Act with integrity and not do or say anything to mislead customers; If giving advice, do so competently and recommend only those transactions which are within their authority to do so and which are suitable for the customer; and Keep the customer's information confidential in line with the Firm s policies. Employees should behave in a professional, responsible, objective and appropriate manner towards other employees in the organisation. Employees should also behave in a professional, responsible, objective and appropriate manner to any other person they come into contact with or deal with by telephone, by or any other means. Employees are required to behave in an appropriate manner at work-related events whether within or outside of office hours (and whether formal or informal) e.g. marketing events, office parties, drinks with employees or customers. 4. Responsibility/Accountability and Governance 4.1. Key Responsibilities Safeguarding the reputation of the Firm in general and complying with this Code in particular, is the responsibility of every employee and director of the Firm, in every location, at every level, and at all times. A. Accountability The Firm and the Board recognise the importance of ensuring that senior management are primarily accountable for ensuring that employees live up to the Core Values. As a result, a series of measures are noted below to assess compliance with these Core Values: Compliance Management Information provision of a report to the Board containing statistics on training conducted (including attendance and completion); suspicious activities reporting; client complaints; and regulatory correspondence. Human Resources Management Information provision of a report to the Board summarising data on disciplinary issues; staff turnover; exit interviews; employee grievances; whistleblowing; and compensation reviews. 7 of 10

8 Legal Management Information provision of a report to the Board detailing employee litigation; and client litigation. Governance Management Information provision of a report of attendance at Board and Committee meetings. B. Delegation of Authority Each employee, and particularly those carrying out a Significant Influence Function, must exercise due care to ensure that any delegation of authority is reasonable and appropriate in scope, and includes appropriate guidance and continuous oversight and monitoring Governance A. Prompt Internal Reporting of Violations of the Code If an employee becomes aware of, or suspects any violation of the Code (or related policies, Compliance Manual, etc.), they have a responsibility immediately to report it to their Manager, the Compliance Department or Human Resources Department as the circumstances require. Failure to report any violation of the Code may have serious consequences for the individuals involved. The Firm is committed to protecting any employee, customer or supplier who, in good faith, reports a possible violation of the Code from any form of retaliation or reprisal. Reported violations of the Code will be investigated, addressed promptly and treated confidentially to the fullest extent possible. B. Failure to Comply with the Code It is an employee s responsibility to be aware of and understand the provisions of the Code as well as other applicable Firm policies, including those identified in the Code. Directors are also required to comply with the Code. The failure of a director to comply with the Code will be dealt with in accordance with the procedures of the Firm s Board of Directors. The Firm will strive to impose discipline for each Code violation that fits the nature and particular facts of the violation. The Firm uses a system of progressive discipline and generally will issue warnings for less significant, first-time violations. Violations of a more serious nature may result in other measures, such as suspension without pay, demotion, temporary or permanent change in duties or responsibilities, loss or reduction of bonus or option awards, or any combination of these or other such disciplinary actions, such as termination of employment. Notifications of breaches of the Code will be made to the FCA where required by relevant regulatory notification requirements. C. Annual Attestation Subject to any exemptions approved by the General Counsel, all employees and directors are required as a condition of employment to complete an attestation on an annual basis stating that they have complied with the obligations set out in the Code. The annual attestation of the Code will be a part of the Compliance declarations. 8 of 10

9 D. Requests for Waivers of Any Provision of the Code Employees must submit any requests for a waiver of a provision of the Code in writing to the Compliance Department in a reasonable period in advance of the proposed conduct for appropriate review. The Compliance Department will consider the waiver in consultation with the General Counsel and Human Resources Department. Any waiver with respect to a director must be approved by the Board. Requests for permission subsequent to a given action may be approved in exceptional circumstances if, for example, the failure to request in advance was inadvertent or for good cause. 5. Training and Communication 5.1. Induction Training A copy of the Code of Business Conduct and Ethics will be provided to all employees upon commencement of employment. Training on the Code for all new employees will be conducted and covered as part of the Firm s induction training sessions On-going Training The Compliance Department conducts refresher training covering regulatory requirements and obligations on an annual basis. The Code will be covered as part of this annual training Communication The Code will be available on the Firm s intranet sites. 6. Other Information 6.1. Additional Guidance Not every situation can be addressed specifically in the Code. Employees are expected to apply the principles outlined in the Code in exercising their judgment when facing questions or issues that do not present obviously correct answers or approaches. If you have any questions or need guidance or advice about any aspect of the Code, your first point of contact is your Manager. If you need to escalate your concern, or require additional assistance, please contact one of the sources listed below. Human Resources Department Compliance Department General Counsel 9 of 10

10 6.2. Related Documentation There are a number of supporting policies which should be read in conjunction with the Code which provide detailed guidelines. Listed below are some of these policies but this is not an exhaustive list: Anti-Money Laundering Policy Financial Crime Policy Anti-Bribery Policy Fraud Policy Sanctions Policy Travel, Entertainment & Expenses Policy Breach Resolution Policy Client Communication & Product Marketing Policy Complaint Handling Policy Compliance Manual Conflicts of Interest Policy Employee Handbook Market Conduct Policy Order Execution Policy Personal Account Dealing Policy Appendix A - Change Control This section should be completed for all changes to this Policy and supported by evidence of Policy Owner sign off. New Version number Author Summary of changes Approval date Approved by 2.0 Head of HR Enhanced section on Alcohol and Substance Abuse section Removed references to CIL 28 March 2014 General Counsel Changed references from FSA to FCA 10 of 10

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