Organization of business activities
The firm ensures to organize its business activities by:
- Erecting Chinese walls to avoid potential conflicts, both physical (segregation of investment teams, offices with restricted access, etc.) and IT (passwords, servers and folders with restricted access, etc.);
- Containing the flow of private information or non-public information;
- Ensuring a segregation of the main business units: investment teams, sales department, corporate functions and internal control ;
- Ensuring an efficient use of means of computer communication by employees;
- Keeping records of each operation.
Code of conduct
Employees of the firm are subject to integrity rules defined by the code of conduct which is signed by each employee upon arrival. This code aims to ensure respect for the principles concerning the primacy of clients' interests and the prevention of conflicts of interest. Thus, each employee of the firm has the obligation to behave with loyalty and act in a fair manner for the benefit of customers.
This code of conduct defines the following policies:
- Personal account dealing policy ;
- Policy on gifts ;
- Written communication policy