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collection of ethical norms and behaviour standards that amspex global limited’s employees should follow
The code of conduct is a collection of ethical norms and behaviour standards that amspex global limited’s employees are expected to follow in the discharge of their business duties. The code of conduct determines amspex global limited’s main views on legitimate and ethical conduct in the banking industry, by means of which amspex global limited’s standards are established.
The foundations of business ethics are rooted in law-abiding behaviour. Such behaviour includes provision of accurate and transparent information, honest attitude towards competitors, employees and partners as well as focus on social responsibility and sustainable development. ”if a company does not follow ethical rules, it cannot be responsible; therefore, ethical conduct is a precondition for creating a socially responsible business environment”. Considerations and knowledge of business ethics help us deal better with ethical dilemmas we face on a daily basis. In critical situations, a good person can make a bad decision. Business ethics contributes to business success and supports personal development.
The purpose of the code of conduct is:
The code of conduct applies to all amspex global limited’s employees regardless of their respective levels of responsibility or positions. Its purpose is to provide guidance on ethical conduct and establish basic values in terms of legitimate and ethical business conduct and behaviour.
Amspex global limited wishes to create a positive business environment that enables team work and encourages the spirit of mutual support and co-operation. Employees must treat each other with decency and respect. Personal relations shall not be given priority over the interests of business, and solving common business tasks must be given primary attention by all employees.
Relations among employees at different levels of responsibility must be based on the principles of mutual loyalty, respect and secrecy. Within the framework of their powers, all employees shall act fairly and steadily, respecting the personal dignity of every employee.
Amspex global limited does not approve of the use of the position or powers within the organisation for the purpose of achieving any goals that lie beyond the scope of the duties. Employees are expected to co-operate with their superiors, act in accordance with operational guidelines received and avoid unprofessional conduct and behavior whether working off line or online.
Employees with special powers shall be responsible for all employees working in organisational units they are in charge of, whose trust they should gain by their own model behaviour, results, open-mindedness and social competence. Their task is to set clear, ambitious and realistic goals, while employees should have maximum possible responsibility and independence at work.
In performing their duties, they are obliged to abide by the principle of transparent criteria for employee assessment. Employees with special powers shall meet their organizational and surveillance obligations through:
At their jobs, employees shall create an atmosphere that corresponds to the above values and shall act as a responsible team with a permanent focus on the improvement of human relations. Impolite behaviour, harassment and discrimination on the grounds of age, gender, religion, political orientation, ethnic or national origins, language, race, social position, marital or family status, education, disability, sexual orientation or on any other grounds are strictly forbidden by law and represent a severe violation of the dignity of an individual.
When administering their private businesses, amspex global limited’s employees must not use amspex global limited’s official symbols or powers associated with employment at amspex global limited.
When making all kinds of public appearances and when representing amspex global limited or expressing amspex global limited’s points of view, employees shall act in accordance with regulations in force, powers granted to them, their professional knowledge, provisions of the code of conduct and the instructions on the manner of dealing with the representatives of the mass media.
When making a public appearance without representing amspex global limited on occasions that are thematically related to amspex global limited’s activities, employees are obliged to stress that they are expressing their own points of view. When expressing both amspex global limited’s and personal points of view and when discharging their duties, employees are also obliged to safeguard their own reputation and the reputation of amspex global limited.
In its operations, amspex global limited applies the following fundamental principles and values:
In its operations, amspex global limited will endeavour to achieve the highest standards possible in the following manners:
Amspex global limited is devoted to the permanent development of a culture of helpfulness orientated towards consistency in meeting clients’ expectations that are in compliance with law and amspex global limited’s rules and programmes.
Amspex global limited’s employees shall act professionally, impartially and respectfully towards clients. Amspex global limited shall always endeavour to understand the economic circumstances under which its clients operate and the needs of its clients in order to be able to offer them products and services that are as suitable for them as possible.
amspex global limited shall provide services and offer products only if it has adequate permits and knowledge as well as necessary auxiliary functions /capacities;
amspex global limited shall be obliged to render only those services that are in the best interest of its clients;
when providing advice to its clients, amspex global limited must provide expert, high-quality, understandable and applicable advice;
inaccurate or false promotion is unacceptable for amspex global limited.
Amspex global limited’s employees shall treat all people (clients, other amspex global limited’s employees and other interested parties) equally and without discrimination or favor on the grounds of age, nationality, ethnic or social origin, language, race, political orientation, religion, disability, education, social position, gender, marital or family status, sexual orientation or on any other grounds.
Amspex global limited’s employees shall treat disabled people and other people with special needs with utmost care.
Amspex global limited is obliged to respect the confidentiality of information on its clients. Each employee of amspex global limited must make the maximum possible efforts in order to respect the confidentiality of information on clients. Information relating to amspex global limited’s clients must not be revealed to third parties, except in cases when:
Beside the data relating to the clients themselves, all information relating to the staff records are deemed to be confidential, including salaries and total income of amspex global limited’s employees.
All data about the persons that apply for a job in amspex global limited, either by sending an open bid or by sending an application to an invitation for application, are strictly confidential and must not be used for other purposes except the selection.
Knowing the clients of amspex global limited is necessary in order to ensure quality providing of services. On the occasion of establishing business relations with its clients, amspex global limited must act with utmost dilligence in order to evade any participation in doubtful or illegal business purposes such as money laundering and terrorism financing, as well as all types of fraud and delusion attempts.
On the occasion of establishment of a business relation, amspex global limited must implement the following measures:
Privileged information are information that were not publicly available and that are directly or indirectly related with amspex global limited or one or more of its financial instruments or to amspex global limited’s clients that, as publicly available, would probably have significant impact on the costs of financial instruments or on the costs of associated derivative financial instruments. A reasonable investor would probably take into account such information as a part of foundation for making its investment decisions.
Amspex global limited controls the access to privileged information. The use and disclosure of privileged information, i.e. Inappropriate use of privileged information for personal benefit or for the benefit of third parties, is unacceptable.
Interests of amspex global limited’s employees must not be in conflict with obligations that they have with amspex global limited or that amspex global limited has towards its clients. The employees of amspex global limited are obliged to separate private interests from business interests when performing duties in amspex global limited.
Performance of an activity or a certain action, when there is a possible conflict of interest, must be approved by a prior written consent of the person responsible for the monitoring of compliance.
The following circumstances are subject to the approval:
Gifts, business entertainment or similar benefits are often accepted as legitimate and recognized part of business life. However, problems arise when their value causes a conflict of interest and in this way jeopardise the ethics of a business relation. Therefore, the general rule is that it is not permitted to employees to accept gifts or other benefits, except those of symbolic value.
Gifts are permitted if:
In case of doubt related to actions pursuant to the measures stated above, the employee of amspex global limited shall consult his/her manager to whom he/she is directly responsible or the person responsible for the monitoring of compliance.
The employees of amspex global limited, regardless of the amount, must not accept cash and cash equivalents.
The employees of amspex global limited are obliged to manage the property of amspex global limited with due diligence and pursuant to amspex global limited’s rules on business conduct and other internal documents. The employees are responsible for the property of amspex global limited that they are in charge of and for possible losses that they may cause intentionally or due to gross negligence in their work and related to work.
The employee of amspex global limited or any other person that may have a reason to believe that this code might have been violated or that this might happen, shall immediately report this to the person responsible for the monitoring of compliance. All such reporting will be treated as confidential.
The person responsible for the monitoring of compliance shall consider the reported default and, if on the basis of submitted and collected data he/she concludes that the reported default is justified, he/she shall be obliged to inform the managing board of amspex global limited about it in the shortest term possible.
Since a violation of ethical regulations and behaviour contrary to the standards of this code represent violation of obligations under the employment contract, the managing board shall make a decision on the severity of violation and sanctions for the person or organizational unit the reported default relates to, pursuant to the legal regulations and general documents of amspex global limited.
The person responsible for the monitoring of compliance shall submit a reply on the course of procedure not more than 30 days from the day when it has been submitted.
The person responsible for the monitoring of compliance shall once a year make a report on submitted reported defaults on the basis of the violation of this code and on initiated procedures regarding such reported defaults.
The report on submitted reported defaults for the calendar year to which it relates shall be made not later than 31st january next year.
The report shall be submitted to the amspex global limited bodies in charge.
Amspex global limited relies on the fact that each employee of amspex global limited shall judge carefully and reasonably what is good and appropriate in a certain situation. When in such an action there are difficulties regarding the determination whether a certain action is appropriate, the employee of amspex global limited has to ask himself/herself the following questions:
If the answer to any of the above questions is negative or if there are questions or doubts regarding the application of interpretation of the code of conduct, rules, procedures and standards in force, it is necessary to ask for an advice of the manager to whom he/she is directly responsible or the person responsible for the monitoring of compliance.
No action will be taken against any person who gives information about his/her doubts about the violation of this code or participates in an investigation relating to the violation of this code, except in case of providing untrue data or information.
Amspex global limited shall keep the maximum possible level of confidentiality of data. This code will be published on intra and internet pages of amspex global limited and on its billboard.
All new employees of amspex global limited will be made familiar with the contents of this code.
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