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Code of Conduct

Code of Conduct

  1. Commercial success is fundamental to the future of our firm but commercial issues must never be the sole consideration governing our conduct.
  2. We respect all our colleagues, clients, the markets, regulatory authorities and our regulatory environment.
  3. At all times, communications with staff, clients, regulatory authorities and the public are to be complete, accurate, concise, clear and effective.
  4. Subject to our duties of confidentiality and regulatory requirements, our services are to be transparent, with any material conflicts disclosed. If we identify material conflicts, we should decline to provide service in those circumstances.
  5. Our services must demonstrate the utmost professionalism and competence and comply with relevant regulatory requirements.
  6. Client’s interests come before our own. All the information we have about clients is absolutely confidential (unless regulations require otherwise) and only accessibly to those who have a ‘need-to-know’. When there is a material conflict between clients, fairness and transparency must prevail. At one extreme, we may need to decline to provide services to one client. At the other extreme, disclosure that we are ‘conflicted’ may be sufficient. Both clients must be treated fairly and, if practicable, separate representatives should act for each client.
  7. Records must accurately reflect our financial position, each client’s financial position, our operations and our services.
  8. Fees and charges must take into account our costs and intellectual property must be fair and appropriate.
  9. Compliance is everyone’s responsibility, not just the responsibility of the Compliance Department. Compliance is never someone else’s problem and we are never to aid-and-abet non-compliance by clients or others.
  10. We are not to misuse information obtained as a consequence of client relationships, whether for personal gain or for the benefits of others.
  11. We are to protect our intellectual property and protect/attribute the intellectual property of others. We do not pass off somebody else’s work (whether the person is internal or external) as our own.

Everyone within BBY is subject to this Code of Conduct.