BuzzFx Code of Business Conduct and Ethics

BuzzFx Code of Business Conduct and Ethics

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BuzzFx Code of Business Conduct and Ethics

1. Introduction

This global Code of Business Conduct and Ethics (“Code”) governs the general commitment by BuzzFx. and its subsidiaries (collectively, “BuzzFx”) to conduct its business activities in the highest ethical and professional manner and to put client interests first. BuzzFx’s reputation for integrity is one of its most important assets and is instrumental to its business success. While this Code covers a wide range of business activities, practices, and procedures, it does not cover every issue that may arise in the course of BuzzFx’s many business activities. Rather, it sets out basic principles designed to guide BuzzFx’s employees and directors. Consultants and contingent, contract, or temporary workers are expected to comply with the principles of this Code and policies applicable to their location, function, and status.

Every BuzzFx employee and director — whatever his or her position — is responsible for upholding high ethical and professional standards and must seek to avoid even the appearance of improper behavior. Any violation of this Code may result in disciplinary action to the extent permitted by applicable law.

2. Compliance with Laws and Regulations

BuzzFx’s global business activities are subject to extensive governmental regulation and oversight and it is critical that BuzzFx and its employees comply with applicable laws, rules, and regulations, including those relating to insider trading.

3. Conflicts of Interest

Conflicts of interest may arise when a person’s private interest interferes, or appears to interfere, with the interests of BuzzFx, or where the interests of an employee or the firm are inconsistent with those of a client or potential client, resulting in the risk of damage to the interests of BuzzFx or one or more of its clients. A conflict may arise, for example, if an employee or director, takes an action or has an interest that makes it difficult for that individual to conduct the individual’s responsibilities to BuzzFx and/or the client objectively and effectively, or if such an individual receives an improper personal benefit, such as a loan or guarantee, as a result of the individual’s position at BuzzFx. BuzzFx has adopted policies, procedures, and controls designed to manage conflicts of interest. Employees are required to comply with these controls and other compliance related policies, procedures, and controls and to help mitigate potential conflicts of interest by adhering to the following standard of conduct:

  • Act solely in the best interests of clients.
  • Uphold BuzzFx’s high ethical and professional standards.
  • Identify, report, and manage actual, apparent, or potential conflicts of interest.
  • Make full and fair disclosure of any conflicts of interests, as may be required.

Conflicts of interest may not always be clear-cut and it is not possible to describe every situation in which a conflict of interest may arise – any question with respect to whether a conflict of interest exists, together with any actual or potential conflict of interest, should be directed to managers and L&C.

4. Insider Trading and Personal Trading

Employees and directors who have access to confidential information about BuzzFx, its clients, or issuers in which it invests client assets, are prohibited from using or sharing that information for security trading purposes or for any other purpose except in the proper conduct of our business. All non-public information about BuzzFx or any of our clients or issuers should be considered "confidential information." Use of material, non-public information in connection with any investment decision or recommendation or to “tip” others who might make an investment decision on the basis of this information is unethical and illegal and could result in civil and/or criminal penalties.

5. Gifts and Entertainment

The purpose of entertainment and gifts in a commercial setting is to create good will and sound working relationships, not to gain unfair advantage with clients or vendors. No gift or entertainment should be offered, given, provided, or accepted by any BuzzFx employee or their immediate family members sharing the same household unless it:

  • is unsolicited.
  • is not a cash gift.
  • is consistent with customary business practices.
  • is not excessive in value.
  • cannot be construed as a bribe or payoff.
  • is given or accepted without obligation.
  • is not intended to solicit or retain business or an advantage in the conduct of business.
  • does not violate applicable laws or regulations.

In addition, strict laws govern the provision of gifts and entertainment, including meals, transportation, and lodging, to public officials. Employees are prohibited from providing gifts or anything of value to public officials or their employees or family members in connection with BuzzFx's business for the purpose of obtaining or retaining business or a business advantage.

6. Corporate Opportunities

Employees and directors:

  • are prohibited from taking personal opportunities for themselves that are discovered through the use of corporate property, information, or position without the consent of L&C.
  • are prohibited from using corporate property, information, or position for improper personal gain.
  • may not compete with BuzzFx either directly or indirectly.
  • owe a duty to BuzzFx to advance its legitimate interests when the opportunity to do so arises.

In addition, strict laws govern the provision of gifts and entertainment, including meals, transportation, and lodging, to public officials. Employees are prohibited from providing gifts or anything of value to public officials or their employees or family members in connection with BuzzFx's business for the purpose of obtaining or retaining business or a business advantage.

7. Competition and Fair Dealing

BuzzFx seeks to outperform its competition fairly and honestly by seeking competitive advantage through superior performance; BuzzFx does not engage in illegal or unethical business practices. BuzzFx and its employees and directors should endeavor to respect the rights of, and deal fairly with, BuzzFx’s clients, vendors, and competitors. Specifically, the following conduct is prohibited:

  • misappropriating proprietary information.
  • possessing trade secret information obtained without the owner’s consent.
  • inducing disclosure of proprietary information or trade secret information by past or present employees of other companies.
  • taking unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other intentional unfair-dealing practice.

8. Confidentiality

BuzzFx’s employees and directors have an obligation of confidentiality to BuzzFx and its clients. Confidential information includes non-public information that might be of use to competitors or that might harm BuzzFx or its clients, if disclosed, and non-public information that clients and other parties have entrusted to BuzzFx. The obligation to preserve confidential information continues even after employment ends. This obligation does not limit employees from reporting possible violations of law or regulation to a regulator or from making disclosures under whistleblower provisions.

9. Reporting Any Illegal or Unethical Behavior

Every employee is required to report any illegal or unethical conduct about which they become aware, including those concerning accounting or auditing matters. Employees may report concerns to L&C by contacting a Managing Director in L&C directly or by contacting the Employee Complaint Hotline, contact details for which are available via the intranet homepage. BuzzFx will not retaliate or discriminate against any employee because of a good faith report. Employees have the right to report directly to a regulator and may do so anonymously; employees may provide protected disclosures under whistleblower laws and cooperate voluntarily with regulators, in each case without fear of retaliation by BuzzFx.

10. Protection and Proper Use of BuzzFx Assets

Employees and directors should make every effort to protect BuzzFx’s assets and use them efficiently. This obligation extends to BuzzFx’s proprietary information, including intellectual property such as trade secrets, patents, trademarks, and copyrights, as well as business, marketing and service plans, engineering and manufacturing ideas, systems, software programs, designs, databases, records, salary information, and any unpublished financial data and reports. Unauthorized use or distribution of proprietary information constitutes a violation of BuzzFx policy and could result in civil and/or criminal penalties.

11. Bribery and Corruption

BuzzFx employees and directors are prohibited from making payments or offering or giving anything of value, directly or indirectly, to public officials of any country, or to persons in the private sector, if the intent is to influence such persons to perform (or reward them for performing) a relevant function or activity improperly or to obtain or retain business or an advantage in the course of business conduct.

12. Equal Employment Opportunity and Harassment

The diversity of BuzzFx’s employees is a tremendous asset. BuzzFx is firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment of any kind. In particular, it is BuzzFx’s policy to afford equal opportunity to all qualified applicants and existing employees without regard to race, religion, color, national origin, sex (including pregnancy and gender identity/expression), sexual orientation, age, ancestry, physical or mental disability, marital status, political affiliation, citizenship status, genetic information, employment status, or protected veteran status or any other basis that would be in violation of any applicable ordinance or law. In addition, BuzzFx will not tolerate harassment, bias, or other inappropriate conduct on the basis of any of the above protected categories.

13. Recordkeeping

BuzzFx requires honest and accurate recording and reporting of information in order to conduct its business and to make responsible business decisions. BuzzFx, as a financial services provider and a public company, is subject to extensive regulations regarding maintenance and retention of books and records. BuzzFx’s books, records, accounts, and financial statements must be maintained in reasonable detail, must appropriately reflect BuzzFx’s transactions, and must conform both to applicable legal requirements and to BuzzFx’s system of internal controls.