Standards of Professional Conduct

I. PROFESSIONALISM

A. Knowledge of the Law

Team Members and all associates must comply with all applicable laws, rules, and regulations of any governmental, regulatory organization, licensing agency, or professional association governing their professional activities. In the event of conflict, Team Members and all associates must defer to legal counsel and comply with any applicable law, rule, or regulation. Team Members and all associates must not knowingly participate in anv violation of such laws, rules, or regulations, and must dissociate from any violating party. Moreover, Team Members and all associates pledge to always uphold and fully abide by The Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act 2010 in all business activities.

B. Independence and Objectivity

Team Members and all associates must use reasonable care and judgment to achieve and maintain independence and objectivity in their professional activities. Team Members and all associates must not offer, solicit, or accept any gift, benefit, compensation, or consideration that reasonably could be expected to compromise their or another’s independence and objectivity.

C. Misconduct

Team Members and all associates must not engage in any professional conduct involving dishonesty, fraud, or deceit or commit any act that reflects adversely on their professional reputation, integrity, or competence. Noncompliance will be dealt with according to appropriate legal governance.

II. DUTIES TO CLIENT

A. Loyalty, Prudence, and Care
Team Members have a fiduciary responsibility regarding clients and must act with reasonable care and exercise prudent judgment. Team Members prioritize client benefit and place clients’ interests before those of a personal nature.

B. Fair Dealing
Team Members must deal fairly and objectively with all clients, when providing investment relations, government relations, communication, or any other services.

C. Suitability
When Team Members are in an advisory relationship with a client, they must:

  • Make a reasonable inquiry into a client’s or prospective client’s experience, risk and objectives, and financial constraints, prior to making any investment relations, government relations, or communications recommendations. Team Members are additionally required to regularly reassess and update this information.
  • Determine the suitability of propositions to the client’s financial situation and ensure consistency with the client’s written objectives, mandates, and constraints, before making any investment relations, government relations, or communications recommendations.
D. Preservation of Confidentiality.
Team Members must respect privacy of information concerning current, former, and prospective clients unless:
  • The information concerns illegal activities on the part of the client or prospective client,
  • Disclosure is required by law, or
  • The client or prospective client permits disclosure of the information.
III. ANALYSIS, RECOMMENDATIONS, AND ACTIONS

A. Diligence and Reasonable Basis.

Team Members must:

  1. Exercise diligence, independence, and thoroughness in analyzing, making recommendations, and taking actions.
  2. Have a reasonable and adequate basis, supported by appropriate research and investigation, for any analysis, recommendation, or action.
B. Communication with Clients and Prospective Clients.
Team Members must:
  1. Disclose to clients and prospective clients the basic format and general principles of any changes that might materially affect the implementation process of recommendations.
  2. Disclose to clients and prospective clients significant limitations and risks associated with the implementation process of recommendations.
  3. Use reasonable judgment in identifying important factors to their analyses, recommendations, or actions and include those factors in communications with clients and prospective clients.
  4. Distinguish between fact and opinion in the presentation of analysis and recommendations.