Codes
of Conduct

Our Code of Conduct for Shareholders' Associations and their Members serves as a cornerstone for upholding ethical standards within the realm of public companies. To ensure adherence, associations must be duly registered, equipped with a constitution, and maintain transparency through audited accounts. Compliance with legal frameworks and regulations is paramount. Shareholders, under this code, hold the right to attend general meetings, fostering inclusivity. Associations are encouraged to champion good governance and refrain from any form of manipulation.

An essential requirement is that audit committee members must possess a profound understanding of accounting principles. It is important to note that Regulatory Authorities exclusively recognize associations that align with these standards.

Our Code of Conduct for Rating Agencies is designed to set high standards in the rating industry. This code encompasses guidelines for the entire rating process, focusing on independence, responsibilities, and disclosure. Rating agencies are expected to maintain independence by prohibiting analysts from suggesting design changes to entities being rated.

To ensure objective evaluations, agencies should employ knowledgeable rating committees and allocate resources for continuous monitoring. Transparency is key, with the code requiring agencies to disclose their revenue sources, review departing analysts' work, and implement objective remuneration policies. A critical point is that rating agencies should not rate an issuer that has ownership ties to the agency.

Furthermore, agencies are urged to publish historical performance data, differentiate ratings, provide comprehensive information about credit opinions and loss analysis, and transparently disclose their methodology. Our commitment to transparency extends to publishing our own code of conduct, methodologies, and historical performance data on our website.

Trustees play a pivotal role in maintaining the integrity of financial operations. Our Code of Conduct for Trustees outlines a spectrum of responsibilities, underscoring the importance of acting in accordance with governing documents and ensuring compliance with laws. Trustees must exercise fairness, impartiality, loyalty, and reasonable care in their actions.

Maintaining independence and avoiding conflicts of interest are non-negotiable principles. Trustees must diligently protect the interests of various parties involved, regularly review trust goals, and uphold confidentiality while maintaining transparent communication.

Acting in good faith and in the best interests of participants and beneficiaries is fundamental. This requires utilizing credible information and ensuring employees possess appropriate knowledge and experience. Safeguarding trust assets and effectively overseeing fund managers are also key aspects.

Furthermore, adhering to investment decision-making standards, avoiding co-mingling of funds, accurately reporting sinking fund balances, monitoring projects/investments, submitting accurate statements of affairs, and ensuring risk diversification in fund management are all essential components of this code.