This Code of Ethics (“Code”) for Alpha Capital Group Limited (“ACG”) is a recognition by the financial services industry (“FSI”) of the critical and privileged role that it plays in the society and the acceptance by the FSI of the responsibility upon individuals across ACG to consistently adhere to a high standard of professionalism and ethics in the conduct of its business and professional activities.
A high standard of professionalism and ethics requires individuals across ACG to serve the legitimate interest of their customers and clients in an open and transparent manner, with the highest standards of professional and ethical behavior, whilst upholding and promoting the interest of the industry as a whole for the benefit of society and the environment.
The FSI is interconnected, complex and increasingly globalized. Maintaining and strengthening a strong culture of professionalism and ethics that is anchored in a set of core ethical principles that apply across the industry will contribute towards stronger financial consumer protection and a more resilient financial system, thereby helping to secure the credibility and sustainability of the industry and through that, enhance the overall reputation of and reinforce public trust in the industry. This can be achieved through the universal adoption of an internationally acceptable code of ethics by organizations and individuals across the FSI and by organizations across the industry having an effective implementation system in place to enforce it.
This Code sets out the core ethical principles to which individuals across ACG shall adhere, both in letter and in spirit, and on which they can rely for guidance in decision-making and their conduct.
This Code applies to individuals across ACG. The industry comprises a wide spectrum of sectors, including banking, finance, insurance, capital markets and trust and serves a diverse range of customers and clients, including individuals, families, businesses, governments and civic organizations, who have varying degrees of sophistication in their financial literacy and skills.
This Code has been developed by the Board of Alpha Capital Group (“ACGB”). It does not replace any relevant laws and regulations. Instead, this Code complements a formal system of regulation and contributes towards public oversight of the FSI through a publicly available, voluntary, principles-based code of ethics developed “by the industry, for the industry, in the public interest.”
Code of Ethics for Alpha Capital Group
ACG shall continuously uphold and abide by the following ethical principles that are vital to the achievement of a high standard of professionalism and ethics across the industry:
Competence
ACG shall develop and maintain the relevant knowledge, skills and behavior to ensure that their activities are conducted professionally and proficiently. This includes acting with diligence, as well as obtaining, and regularly updating, the appropriate qualifications, training, expertise and practical experience.
Integrity
ACG shall be honest and open in all their dealings. This includes behaving in an accountable and trustworthy manner, and avoiding any acts that might damage the reputation of, or bring discredit to the industry at any time.
Fairness
ACG shall be honest and open in all their dealings. This includes behaving in an accountable and trustworthy manner, and avoiding any acts that might damage the reputation of, or bring discredit to the industry at any time.
Confidentiality
ACG shall protect the confidentiality and sensitivity of information provided to them. This includes using it for its intended purposes only and not divulging information to any unauthorized persons, including third parties, without the necessary consent from those involved unless disclosure is required according to relevant law or regulation.
Objectivity
ACG shall not allow any conflict of interest, bias or undue influence of others to override their business and professional judgment. They shall declare, to those concerned, all matters that could impair their objectivity.
Steps on The Adoption and Implementation for This Code
ACG shall adopt this Code in its entirety.
This Code, being a principles-based code of ethics, requires ACG to establish their own effective implementation system to fully integrate its principles throughout the organization.
ACG shall also establish its own system to monitor and demonstrate evidence of adherence to the spirit of this Code. An audit shall be conducted if deemed necessary.
The following are the steps on the adoption and implementation of this Code by ACG:
Adoption
The Board of Directors of ACG shall require its employees to adopt and uphold this Code in its entirety. Where an existing written code of ethics is not available, it shall produce one based on the principles in this Code and, where appropriate, enhance it accordingly for its purpose and environment. Where an existing written code of ethics is available, it shall review the code and, where appropriate, harmonize and enhance it to meet the principles in this Code.
Commitment
Leaders, beginning with the Board of Directors, and managers of ACG shall demonstrate sustained commitment towards the principles in this Code by continuously striving to uphold them and to communicate their importance to all concerned parties, including employees, agents and relevant third parties such as vendors, suppliers, contract workers or outsourced parties, on a regular basis.
Implementation
ACG shall embed the principles in this Code in their governance, policies and everyday conduct. This includes:
Requiring new and existing employees, agents and relevant third parties such as contract workers or outsourced parties who provide financial services to or on behalf of ACG to sign a commitment to uphold the principles in this Code. This requirement may be addressed in appropriate contracts of employment or engagement;
Providing or encouraging the provision of appropriate training and refresher programs on the principles of this Code for new and existing employees, agents and relevant third parties such as contract workers or outsourced parties who provide financial services to or on behalf of ACG;
Having policies and procedures that reinforce the adherence to the principles of this Code and that clearly outline and describe the implications and repercussions of any violation of the principles in this Code by an employee, agent and relevant third party such as a contract worker or outsourced party who provide financial services to or on behalf of the Group. This may be fulfilled through ACG’s disciplinary policy and procedure and/or other relevant policies and procedures such as internal policies and procedures that relate to third party arrangements and agreements;
Having an effective performance management system that encourages the adherence to the principles in this Code;
Appointing a designated senior level person or establishing a committee within ACG, to be charged with the handling of ethical issues, including the adoption and implementation of this Code. The designated person or committee shall report to the Board of Directors;
Ensuring a conducive environment for employees, agents and relevant third parties such as vendors, suppliers, contract workers or outsourced parties, to raise ethical concerns without fear of repercussions through the development of clear “speak-up” and “whistle-blowing” policies and procedures.
Publish And Publicize
ACG shall publicize this Code widely within the Group and externally, including to customers and clients as well as shareholders. This may entail:
Publishing this Code using a combination of methods, including publishing this Code in the Group’s annual, sustainability or other appropriate reports as well as on its websites;
Ensuring this Code is visible and easily accessible in the work place;
Translating this Code into other languages as appropriate.
Impact Measurement
ACG shall develop a set of indicators that enables the monitoring of the impact of this Code across their business operations. The impact measurement shall validate the degree of adherence to the Code and assist the Board of Directors and managers to identify and address any gaps. Where ACG use customer or employee satisfaction surveys, it shall gather feedback on whether the principles of this Code are being followed or practiced.
Publish Declaration
Organizations that have incorporated all the principles in this Code in their respective written codes of ethics shall publicly declare their code’s full alignment with this Code as well as their endorsement of and adherence to this Code. However, in the event of any non-adherence to this Code, the ACGB shall not be responsible for such non-adherence. In addition, the ACGB retains the right to withdraw or refute any form of endorsement or declaration by anyone who has failed to adhere to this Code.
Guidance on and Review of This Code
The ACGB will, from time to time, provide additional guidance on the application, adoption and implementation of this Code.
The ACGB will, from time to time, also review and revise this Code to address the evolving needs and expectations of the industry and the public.
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