Code of Conduct

Our continued adherence to high international standards of corporate governance and maintaining ThomasLloyd's reputation for good corporate citizenship and integrity requires the ongoing support and commitment of all of its employees. The Code of Conduct of the ThomasLloyd Group describes the ethical policies and practices which we expect all directors and employees of the ThomasLloyd Group to follow with the fundamental purpose of reaffirming ThomasLloyd's commitment to the values of good corporate citizenship and integrity.

Introduction

The Code of Business Conduct and Ethics of the ThomasLloyd Group is founded on the shared values of the ThomasLloyd Group of companies and our employees. The values of integrity, teamwork, service, innovation and excellence, are the foundations of our company and culture. This Code of Business Conduct and Ethics – along with the policies on which they are based – act as a high standard for our professional conduct and our ethical behaviour.

Our most important value is integrity. We are committed to conducting our business with honesty and to the highest ethical standards. Just as our values direct our thinking, our policies drive our actions.

In keeping with the laws and regulations of every jurisdiction within which we operate  our staff adhere to our core values and policies These must be understood, followed and applied consistently so as to integrate the values that will help us promote the long-term success of ThomasLloyd.

The ThomasLloyd Group plc’s Board of Directors and the Group Executive Committee endorse this Code and its enforcement.

The Code of Conduct

1.  Ethical Behaviour and Business Integrity

1. We are committed to business conduct that is above reproach, demonstrating our desire for professionalism and our responsibility as corporate citizens.
2. We strive to adhere to high ethical standards in all decisions we make and in all actions we take. Appropriate course of action takes into account the following: compliance with laws, rules and regulations of the countries in which we operate, as well as consistency with ThomasLloyd’s values.
3. We owe a duty to ThomasLloyd to advance its legitimate interests. We must consult Legal and Compliance Officers, if our own interests could interfere with those of ThomasLloyd. Employees and Directors are prohibited from taking for themselves opportunities that are discovered through the use of Company property, information or position without the consent of the Board of Directors.
4. We do not provide or accept improper inducements in our business dealings with other parties.
5. All directors and employees work in the best interests of our clients and customers.

2.  Compliance with Laws, Rules and Regulations

1. We are committed to respecting and complying with the laws, rules and regulations of the countries in which we operate.
2. We are committed to adhering to the standards and restrictions imposed by our own internal policies, guidelines and procedures.
3. Compliance Manual

3.  Disclosure and Public Communications

1. We apply strict transparency, honesty and cooperation in our business relationships with regulatory authorities.
2. Within the guidelines prescribed by individual jurisdictions, we provide reports, documents and/or communications in a complete, accurate, comprehensible and timely manner.
3. We ensure that our financial disclosure is in line with industry standards. We keep accurate books and record and use generally accepted accounting principles. No undisclosed or unrecorded fund or asset of the company shall be maintained for any purpose.

4.  Public Relations and Corporate Communication

1. We strictly control contact with and provision of information about the Company to any outside person, including members of the news media and investment community. Any news released to organizations is subject to approval by the Board of Directors.
2. We refer any inquiries or contact with any media representative immediately to our pre-established PR or contact person, or else to Corporate Communications.
3. Media Policy

• Corporate Communication contacts (Inquiries, Contact & Crisis Management)
• Procedure for non sensitive issues (Trade and local media, general business and Financial Media)
• Procedure for sensitive issues (Crisis Communications)

5.  Client Relationships

1. We are committed to providing superior service to our clients, to continuously improving our service and to growing partner relationships that add value to our clients.
2. We treat our clients with integrity and fairness by identifying and acting in line with our legal and ethical responsibilities

6.  Client and Employee Confidentiality

1. We maintain the confidentiality of all information entrusted to us by our clients or our company, except when disclosure is authorized by our clients or legally mandated by applicable laws, rules or regulations.
2. We, as individuals, ensure proper internal release of such confidential information with appropriate discretion. Any requests for personal or employee related information is relayed to Human Resources Department.
3. We apply strict controls when receiving, handling and storing data, and adhere to predefined data security procedures, in line with our legal and ethical standards, designed to prevent any unauthorized access, sharing, modification or destruction.
4. The obligation to protect confidential information continues even after employment ends.

7.  Conflicts of Interest

1. We are mindful of conflicts of interest and commit to maintaining effective organisational and operational processes to identify and actively manage or avoiding potential conflicts in our business.
2. Any concerns are escalated promptly to management through our Legal Department and our Chief Risk Officer.

8.  Anti Money Laundering and Corruption

1. We are committed to assisting in the fight against money laundering and corruption.
2. The Company complies with the laws governing its operations in each country in which we do business. Compliance with the law means not only following the law, but conducting our business so that the Company will be recognized as a good citizen. Even where law is not applicable, the highest standards of business ethics shall be followed.
3. We undertake ongoing due diligence and monitoring to help us identify any suspicious activities which are escalated to management and control functions in a prompt manner.
4. We screen our clients prior to any business relationship and perform ongoing due diligence to ensure acceptability.

9.  Insider Dealing and Inside Information

1. We seek to establish whether or not the financial information we are receiving is available to the general public or can only be discovered from someone within a corporation (inside information).
2. We maintain a strict control of the sharing of inside information and only do so with external or internal parties in accordance with our internal procedures and applicable laws, rules and regulations.
3. Usage of inside information may lead to immediate termination of duties and the employee will be held personally accountable under all applicable laws, both civil and otherwise.

10.  Protection and Proper Use of Company Assets

1. We seek to preserve and not take improper advantage of the assets and proprietary information, including ThomasLloyd’s intellectual property, accessible to us in our professional roles.
2. We report incidents of theft or fraud immediately to management for investigation.
3. We treat ThomasLloyd infrastructure and equipment with care, avoiding carelessness and waste, and we do not use them inappropriately for non-ThomasLloyd business.

11.  Employees – Interaction and Workplace

1. ThomasLloyd Group is an equal opportunities employer.
2. We strive to be fair and objective in our advice and actions, and to avoid influence in our decisions, actions or recommendations by issues of gender, race, creed, colour, age or personal disability.
3. We seek to treat our colleagues with respect and collaborate in mutual trust and support. Any differences in opinion, background and expertise are respected.
4. We encourage communication, and where not in conflict with compliance and regulation, co-operation between all staff irrespective of division or location.
5. We prohibit all forms of harassment including sexual harassment (unwanted conduct on the grounds of your sex or unwanted physical, verbal or non-verbal conduct of a sexual nature). Any potential violation is to be reported to Human Resources or to any member of management. All complaints will be sensitively handled and investigated without bias, prejudice or retaliation.
6. We actively participate in health and safety training and emergency response procedures. We notify a supervisor and co-workers immediately of any health or safety hazard.

Adherence to the Code of Conduct

ThomasLloyd expects all employees as individuals as well as the Company as a whole, including the Board of Directors, to adhere in spirit and letter to this Code of Conduct. All new employees shall receive and read a copy of the Code of Conduct as well as all company policies. Employees having a question or concern about a possible violation of the letter or spirit of this Code should seek guidance from their supervisor, the Risk Management and Corporate Compliance officer, the General Counsel or from Human Resources.

Any potential waiver to this Code requires the most senior management consideration and documented approval. Waivers will only be granted in the most exceptional of circumstances, if at all, and may only be made by the Board of Directors and must be promptly disclosed in documentation.

From time to time, ThomasLloyd will issue more specific policies, principles and regulations, which may also include regional or local codes of conduct, in continued implementation of our values. All efforts will be undertaken to facilitate the application and enforcement of our Code of Conduct while reflecting specific requirements of particular Business Divisions or local jurisdictions.

This Code of Conduct will apply to all circumstances throughout the ThomasLloyd Group. Any violations of the standards as set forth in this Code will be subject to disciplinary proceedings, including potential dismissal. In the event of any observed violations of this Code or of other applicable laws, rules and regulations, whether internally or externally, the misconduct must be reported to the supervisor, Legal, Compliance or Human Resources. If an employee is uncertain how to handle a situation with regard to the Code, the supervisor or Human Resources should be consulted. In line with our Code of Conduct, ThomasLloyd does not allow any retaliation in any form for reports made in good faith of misconduct or violation of the Code of Conduct.

Download "Code of Conduct and Ethics of ThomasLloyd"
Documents for downloading		Type	Size
	Code of Conduct and Ethics of ThomasLloyd	PDF	1102K