By adopting and enforcing a code of conduct for SHUAA, our employees demonstrate commitment to ethical behavior and the protection of investors’ interests.
Fair Business Conduct
Employees should always endeavor to deal fairly and in good faith with clients, service providers, regulators and fellow employees. It is our approach not to take unfair advantage of others through manipulation, concealment or abuse of privileged information, misrepresentation of material facts or any other unfair business practice.
Confidential and Proprietary Information
All employees are responsible for the safeguarding of confidential and proprietary information, whether it is information disclosed to us by clients, information regarding the Firm’s businesses and activities, or information about employees themselves including information about remuneration levels. Employees should maintain all confidential and proprietary information in strict confidence except where disclosure is authorized by the Firm or required by law or regulation.
Confidential information in this context is information that is not generally known to the public about the Firm, its clients, its employees and Directors, or other parties with whom the firm has a relationship and who have an expectation of confidentiality from the Firm.
Proprietary information includes all non-public information that might be useful or of commercial value to competitors or that could be detrimental to the Firm or its clients if disclosed.
Buying or selling securities and other financial instruments while in possession of inside information is prohibited by law as is the communicating of that information to others unless for a valid business reason and in a controlled manner.
Inside information is material, non-public, price sensitive information about a publicly listed company. Information is generally considered material if it could have an impact on the market price of a listed entity or if it is likely that a reasonable investor would consider the information important when deciding to trade in a security. Information should be considered non-public until it has been formally released to the general public.
Our Firm’s reputation is one of our key assets. Therefore it is crucial that we help maintain our good reputation by ensuring that the release to the public of all information that relates to the Firm is accurate, timely and is not misleading. Information which is provided to the public, particularly to the media, must be authorized by the Firm’s Disclosure Committee.
Employees should exercise any authority relevant to their respective positions appropriately and proactively and must also assume the responsibility for the results of exercising or failing to exercise their authority. Employees may not sign any documents or otherwise represent or exercise authority on behalf of the Firm unless they are specifically authorized to do so. Employees should clearly understand the limits of their respective authority and due care should be taken not to take any action that exceeds those limits.
Policies, Manuals and Procedures
The Firm’s policies set the strategic rules of the Firm and determine the manner in which we conduct our business. Manuals detail the way in which the goals, limits, objectives and adopted regulatory interpretations set out in the policies are to be implemented. Procedures address day to day operational processes and requirements and should be available for reference within each business unit and department.
The Firm has established an AML Manual designed to ensure compliance with applicable rules and regulations regarding money laundering. Employees should become familiar with and ensure compliance with this manual.
Complaints and Breaches
Any complaint received by the Firm from a third party should be viewed as a potential opportunity for improvement. For this reason, and to ensure we identify possible breaches of regulation, it is important that employees report all complaints in an accurate and timely manner and that they be resolved as soon as possible.
Employees are required to conduct themselves and their business in a professional manner at all times. Professionalism extends to standards of dress, language and the treatment of colleagues and clients, inside and outside the office.
Conflicts of Interest
All employees must be alert to potential conflicts of interest between employees and the Firm, employees and clients, the Firm and clients or between clients. Employees should seek to manage any real or perceived conflicts in line with the Firm’s policies on the subject. Further, employees may not have any financial or other business relationships with clients, service providers or competitors that might impair or give the appearance of impairing, the independence of any decision or action they may need to make in the best interests of the Firm.
Outside Business Interests and Employment
During working hours, employees are expected to dedicate themselves to their duties within the Firm and therefore should not unduly engage in personal affairs or other business activity except with permission of senior management. Employees may hold honorary positions in clubs, charitable organisations or other similar associations provided that the performance of their Firm duties is not adversely affected in any way and that there is no conflict created with the Firm’s interests.
Personal Account Dealing
Employees are entitled to deal on their own behalf. However, they must follow the Firm’s Personal Account Dealing Policy when they do so. The policy only applies to trading in Arab Region companies and includes the provision that all such trading must be executed through SHUAA and orders must be routed through Workflow.
Gifts, Entertainment and Inducements
As a general rule employees should not accept gifts from, or give gifts to, clients, potential clients or service providers. However it is recognized that there will inevitably be occasions where an employee is offered a gift. In these cases it is important that the employee observes the highest standards of integrity and honesty to avoid situations that could adversely affect their decisions. Personal judgment must always play a part in distinguishing between what is an acceptable gift and what is not.
The Firm’s Assets
In order for the Firm to manage costs, protect its assets and reputation and to help maximize shareholder value, the Firm’s assets are only to be used for legitimate business purposes and only by authorized persons or their designees.
SHUAA recognizes that employees may from time to time incur expense while conducting business on behalf of the Firm. Employees must hold themselves to the highest standards of integrity with regards to incurring costs and claiming them back from the Firm.
SHUAA is a strong supporter of the development and training of its employees and will strive to ensure that employees are provided with opportunities to improve the skills and knowledge required for them to successfully perform their roles within the Firm.
However, employees must also take some responsibility for their own development and should ensure that they are proactive about seeking relevant opportunities to further their knowledge base.
Safe Working Environment
SHUAA is committed to providing and maintaining a work environment that is safe and healthy for all employees and visitors to our offices. It is important that all employees be aware of and adhere to security and health and safety procedures.