We will:

  • Act with integrity, competence, diligence, respect and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the investment profession, and other participants in global capital markets.

  • Place the integrity of the company and the interests of clients above their own personal interests.

  • Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and in engaging in other professional activities.

  • Practice, and encourage others to practice, in a professional manner that will reflect credit on themselves and the company.

  • Promote the integrity of, and uphold the rules governing, capital markets.

  • Maintain and improve their professional competence and strive to maintain and improve the competence of other investment professionals.

STANDARDS OF PROFESSIONAL CONDUCT
We apply the following standards:

Professionalism

  • Knowledge of the Law: Understand and comply with all applicable laws, rules and regulations. Comply with the stricter laws in the event of conflict. Avoid knowingly violating any laws, rules, and regulations.

  • Independence and Objectivity: Use reasonable care and judgment to maintain independence. Management and employees may not accept any gift, benefit, or compensation that would compromise independence and objectivity.

  • Misrepresentation: Avoid misrepresentation of investment analysis and recommendations.

  • Misconduct: Not act dishonestly, fraudulently, deceitfully, or commit any act reflecting adversely on their professional reputation, integrity or competence.

Integrity of Capital Markets

  • Material Nonpublic Information: Not act or cause others to act on material nonpublic information.

  • Market Manipulation: Not engage in any practice which could distort or inflate prices and volumes artificially.

Duties to Clients

  • Loyalty Prudence and Care: Act with reasonable care and exercise prudent judgment. Act for the benefit of clients and place their interests above those of their own.

  • Fair Dealing: Act fairly with all clients in investment analysis, recommendations and actions.

  • Suitability: Make reasonable enquiries into a client’s investment experience, knowledge, risk and return circumstances and constraints. Determine that an investment is suitable to the client’s situation. Judge the suitability of investments in the context of the total portfolio.

  • Performance Presentation: Ensure information is fair, accurate and complete.

  • Preservation of Confidentiality: Preserve confidentiality except if illegal activity, or by permission, or if required by any law.

Investment Analysis, Recommendation, and Actions

  • Diligence and Reasonable Basis: Act with diligence and reasonable basis in analysis, recommendation and actions. Have a reasonable and adequate basis supported by research.

  • Communication with Clients and Prospective Clients: Disclose the investment process for analysis and portfolio construction. Use judgment to identify and communicate important factors. Distinguish between fact and opinion in analysis and recommendations.

  • Record Retention: Maintain records to support analysis, recommendations and actions.

Conflicts of Interest

  • Disclosure of Conflicts: Make full and fair disclosure of all matters likely to impair their independence. Use plain language and effective communication.

  • Priority of Transactions: Transactions for clients and employers must take priority over those in which there is a beneficial ownership of management and employees.

  • Referral Fees: Disclosure to employer, clients and prospective clients of any benefit.

If you believe we have not lived up to our Code of Conduct please send a complaint in writing to Walter Grindrod PO Box 650602, Benmore, 2010. Alternatively contact the FAIS Ombud at PO Box 74571, Lynnwood Ridge, 0040.