Code of Conduct

1. Purpose

This Code sets out the standards of behaviour expected from every employee, contractor and board member of the firm. It applies in all jurisdictions in which the firm operates and takes precedence over local practice where local practice is less strict.

2. Conflicts of interest

Employees must disclose any personal, family or financial interest that could influence, or appear to influence, a business decision. Disclosure is made through the Conflict of Interest Declaration before the activity begins, and again whenever the circumstances change.

3. Gifts and hospitality

Gifts and entertainment with a value above USD 300 must be declared and pre-approved by Compliance. Cash and cash equivalents, including vouchers, may never be accepted or offered regardless of value.

4. Personal account dealing

All trades in covered securities require pre-clearance and are subject to a minimum holding period of 30 days. Instruments on the restricted list may not be traded at any time.

5. Outside activities

Outside directorships, employment and paid speaking engagements require the written approval of the Compliance Officer before the commitment is accepted.

6. Reporting concerns

Any suspected breach of this Code must be reported to Compliance or through the confidential whistleblowing channel. The firm prohibits retaliation against anyone who reports a concern in good faith.