GSB's Code of Ethics & Professional Conduct
Introduction
The Firm is committed to high standards of ethical and responsible conduct with the view of building long-term professional relations and sustainable business.
Being the Employee of the Firm, you are expected to comply with both the spirit and letter of the Code of Ethics. No reason, including the desire to meet business goals, is accepted for violating this Code. If you have any questions about proper conduct in any situation, please do not hesitate to contact the Compliance Officer.
A material breach of the Code of Ethics may result in disciplinary action up to and including termination of your employment.
Firm’s Values
Employees of the Firm are required to meet the standards detailed in this Code of Ethics which impose an obligation of Employees to act in a way beyond mere compliance and to support the underlying values of the Firm which are as follows.
Integrity
The Firm observes high standards of integrity and fair dealing. All Employees must act honestly and truthfully. Any misleading or deceptive conduct, and false and misleading representations are prohibited.
Compliance
While it goes without saying, the Firm strictly abides the local and applicable international laws and regulations, including those of DIFC & DFSA, UAE (Federal) and international legislation. Employees are required to contact the Compliance Officer whenever in doubt and to actively study and raise awareness of the applicable legislation, including attendance of the trainings and updates as organized by the Compliance Officer and Money Laundering Reporting Officer.
Dedication
The Firm aims to provide financial services with due dedication aiming at the best possible result for the Investors, whether in respect to Fund Management, Advisory or Arranging Deals.
Trust and Confidence
Long-term relationships are based on trust and confidence. The Firm is keen on building and maintaining its high professional reputation by treating with equally close attention each transaction and abiding to the legal and professional requirements and best practices.
Initial & Annual Declaration
Employees will be required to confirm that they have read and understood this Code within 7 days of joining the Firm and on an annual basis thereafter.
The Code of Ethics
The following are the principles of the Firm’s Code of Ethics:
- To act honestly and fairly at all times when dealing with Clients and to place the interests of the Client first and avoid serving personal interests. To treat Clients fairly and equally keeping in mind the potential conflict of interests between one Client and another. Refer to Conflicts of Interests Policy and the Compliance Officer when in doubt.
- To observe the applicable law, regulations and procedures when carrying out the duties, and to interpret and apply them based on the principles of trust, honesty and integrity.
- To act with integrity in fulfilling your responsibilities and to seek to avoid any acts, omissions or business practices which damage the reputation of the Firm. In particular, not to advise any Client to transact with a frequency or in amounts that might be deemed to be excessive.
- To be alert to and manage any relevant conflict of interest according to the Firm’s procedures, including conducting personal investing activities in a manner such as to avoid even the appearance of a conflict of interest with the Firm or its Clients as detailed in the Firm’s Compliance procedures.
- To attain and actively manage a level of professional competence appropriate to the level of responsibilities, to commit to continuing learning to ensure the currency of knowledge, skills and expertise and to promote the development of others.
- To decline to act in any matter about which the competence is insufficient unless with access to such advice and assistance which would enable carrying out the work in a professional manner.
- To not use improper means to influence another’s business judgement, including providing bribes or other improper benefits, financial or otherwise, to another person in order to obtain or retain business, bring about the improper performance of a relevant function or activity or an unfair advantage in any business interaction that involves Employees, Clients or Business Partners.
- To observe the standards of market integrity, good practice and conduct required or expected of any professional engaging in any form of market dealing. In particular, to not engage in any form of market misconduct which includes, but is not limited to, misleading or untrue statements, misleading or deceptive conduct, inducing another person to deal, providing inside information or insider dealing.
- To ensure the timely execution of Client instructions (as may be applicable), by ensuring that any relevant Client documentation is forwarded to Business Partners and/or the Client’s custodian bank as soon as reasonably practical and in line with the Operations Manual.
- To respect confidentiality and comply with all non-disclosure agreements concerning confidential or proprietary information about or provided by customers, Employees, suppliers or the Firm. To never compromise a client’s trust by disclosing private information other than to those with a legitimate business need to know. Exception to be made only in respect to the mandatory disclosures to the authorities, internal reporting to the MLRO etc. – reference to be made to the AML Policy of the Firm.