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Code of Conduct

Last updated 8 February 2023

1. THE COMMITMENT TO HONEST AND ETHICAL CONDUCT

Why the Code matters

The Code is important because it outlines how TASConnect makes sure that the decisions TASConnect makes are the right ones.

Act responsibly and within the authority

TASConnect must be disciplined, responsible and take accountability for the risks the Company takes. When taking risks, they must be within the delegated authority and must be appropriate to the business area or activity. TASConnect’s policies are in place to help understand what limits and safeguards are in place.

Use good judgment

TASConnect recognise that employees may face complex situations which don’t have simple, clear-cut solutions. Use the Code’s decision-making framework to help make decisions well, appropriately and with care.

2. WORKPLACE CONDUCT

As an organisation, managing risk is a central part of TASConnect’s daily activities. TASConnect creates value for clients and produce long-term returns for shareholders by taking and managing risks in line with TASConnect’s strategy and within TASConnect’s risk appetite. Risk management is the set of end-to-end activities through which the Company makes risk-taking decisions and control and optimise the risk-return profile of TASConnect. It is a vital part of all activities across the Company, starting from the front line. Because of this, all TASConnect employees must make sure they manage risks effectively as part of their organisational responsibilities.

So, it is important that every aspect of TASConnect’s business is carried out within a framework of the delegated authority. Delegated authority is designed to protect employees as well as the Company. Understanding which limits and policies apply to the employees and to not take more risks than appropriate individuals’ role or seniority.

Employees must:

      • Understand the limits and policies that applies, and keep to them

      • Make sure they have appropriate authority before committing TASConnect to any transaction or contractual commitment

      • Be disciplined and take responsibility and accountability for the risks taken, making sure they are appropriate to the business or activity

      • Make sure that decisions made do not create reputational risk

      • Exercise strong financial control by acting within one’s financial authority and ensuring accurate record keeping

      • Use care, skill and diligence when carrying out any responsibilities or delegating to others

Use good judgement

Good judgment is used when facing situations which are challenging and unfamiliar, while staying within the delegated authority.

One should feel comfortable that they can support the decisions or action they take in light of the difficult situations faced. Being methodical and informed when considering solutions will help to deliver a positive outcome. Acting hastily, without involving manager in line and any other relevant colleagues, exposes one to poor decision-making and negative consequences.

Comply with laws, regulations and standards

It is vital that TASConnect complies with relevant laws, regulations and the Company standards in everything the Company does. Making sure that the Company operates within these laws, regulations and standards is the personal responsibility of every employee.

Always:

      • Act ethically, honestly, professionally and with integrity at all times
      • Comply with all relevant legal and regulatory requirements. Make sure all TASConnect
        employees know and understand them, and act in a way which follows their instructions and the spirit in which these rules are intended. Failing to do so, the consequences can be severe, including damage to the TASConnect brand, loss of clients, loss of confidence from the regulators and the public, suspension or withdrawal of the licences (if applicable) TASConnect holds and fines or other penalties
      • Comply with TASConnect’s standards unless local laws or regulations are either stricter than, or do not allow TASConnect’s standards – in which case local laws or regulations apply
      • Some countries have requirements for people, organisations or particular activities to be licensed, registered, or certified. These are regulatory requirements, and TASConnect must comply with them. It is TASConnect’s responsibility to make sure that the Company have the relevant licences, registrations and certificates that the employees need
      • Understand the legal and regulatory requirements involved in cross-border activities and keep to these requirements

Treat colleagues fairly and with respect

At TASConnect, the Company believes it is important that everyone can work in a fair, safe, inclusive and enjoyable place that encourages creativity, collaboration and continuous improvement. These things are essential to TASConnect’s core valued behaviours.

Trust and fairness are also a central part of TASConnect’s approach to managing and developing people. By building on the strengths and abilities, the Company can help the employees to achieve their full potential. And if TASConnect is better as a team, the Company will be able to better serve all clients.

TASConnect expect all employees to treat colleagues fairly and with respect as all employees are entitled to a safe working environment that is free from discrimination, exploitation, bullying, harassment or inappropriate language.

Particular areas to take account of are shown below:

      • TASConnect values diversity and work together as a team. The Company is committed to providing equal opportunities and fair treatment in employment. TASConnect do not accept unlawful discrimination in the Company’s recruitment and employment on the grounds of race; colour; nationality; national or ethnic origins; gender; parental status; marital or civil partner status; sexual orientation; gender identity, expression or reassignment; HIV or AIDS status; employment status; flexibility of working arrangements; disability; age; religion; or belief

      • TASConnect appoints, trains, develops, rewards and promotes based on merit and ability

      • TASConnect may take action to deal with disadvantage or under-representation among specific groups, with the aim of making sure the employment decisions are free from bias

      • TASConnect do not tolerate any exploitation or any bullying, harassment, discrimination against, or victimisation of any colleagues, clients, or visitors – whether spoken, written, physical or psychological

      • TASConnect all have a duty to treat the people the Company come into contact with through work with dignity and respect

      • When using the Company’s tools and systems such as Outlook, Sharepoint or etc

      • TASConnect must make sure that the communications are appropriate. Employees should never use these in a way that breaches any of TASConnect’s policies, including those relating to communications and equal opportunities. All employees should not post or pass on any content that would affect any person’s rights or break the law and all communications are factual and do not contain offensive or abusive language

TASConnect is committed to dealing with any issues that are brought to the Company’s attention. TASConnect will thoroughly investigate complaints of harassment, exploitation, discrimination or victimisation and may take formal disciplinary action where misconduct has taken place.

Be open and honest with regulators – give them your full co-operation

To serve TASConnect’s clients and continue to operate, the Company must maintain strong and effective relationships with regulators and governments to keep the business licences and gain new ones. If TASConnect fails to meet any commitments, regulators may lose confidence in the Company and take action against the Company. This action could include substantial financial penalties and removing the business licences, which will damage TASConnect’s brand, reputation and ability to serve the clients.

3. SECURITY OVER INFORMATION AND ASSETS

As part of delivering or supporting the financial services, TASConnect may receive confidential information which may be about organisations, markets and the Company, as well as personal data of clients, colleagues, and other individuals. It is critical that how TASConnect use confidential information, including personal data, instils trust and confidence, not only in those directly affected, but in the broader community in which the Company operates. TASConnect is committed to handling confidential information, including personal data, respectfully and appropriately in line with TASConnect’s responsibilities in terms of bank secrecy and confidentiality, as well as privacy law.

All information and personal data gathered and dealings with TASConnect is confidential unless clearly said to be otherwise. TASConnect will only share confidential information on the Company’s internal platforms with those allowed to receive it. Confidential information, including personal data, must only be used to carry out work, in line with all laws, regulations, contracts and policies and procedures which apply, including relating to information security and information walls.

All employees must use skill, care and diligence in securing and handling confidential information, including personal data. This includes:

      • Not accessing any confidential information, including personal data, unless authorised to do so in line with their role
      • Accessing, storing and getting rid of confidential information
      • Protecting and handling confidential information including personal data to meet privacy requirements
      • Transferring it securely to others or within the Company
      • Not viewing it in public
      • Respecting information walls that may apply to it
      • Not using or disclosing confidential information, including personal data, on any social
        networking sites
      • Being vigilant for any signs of threats, including social engineering practices

TASConnect may also collect personal data for specified and legitimate work purposes only, and the Company respects individuals’ rights and regulatory requirements when handling it.

More generally, communications made about TASConnect must be accurate and reflect the Company’s views. Employees must not release confidential information or personal data or make representations about TASConnect to the media or on any public forum, including social media, without express authorisation. Only authorised staff may make comments to the media subject to clearance from Branding & Marketing, Legal, Risk and Compliance.

4. BUSINESS CONDUCT

Ensure fair outcomes for clients

TASConnect must always do the very best to deliver fair outcomes for clients. Clients are at the heart of everything that TASConnect does, and TASConnect is committed to providing clear and honest advice to them, and to making sure that the products offered are right for them. As well as being the right thing to do, providing fair outcomes for clients helps TASConnect to build and foster long-term relationships with them. This helps to improve the Company’s reputation and attract new business.

When dealing with all clients, the following minimum standards must be kept:

      • Make sure that products and services are designed with the clients’ needs in mind, including fair and reasonable pricing which has been clearly disclosed

      • Make sure all communications with clients are fair and not misleading

      • Make sure approval for new products and services (including features, strategic-partnership or significant variation to the existing products) have been obtained from internal key stakeholders (such as Legal, Risk and Compliance, Finance, Tax, etc, prior to launching

      • Give clients clear and concise information before they enter into products and services, so they understand the risks. This must be done for all clients, regardless of how experienced they might be or their usual risk tolerances

      • Follow applicable sales processes. Only market and sell the products and services which have been approved for sale

      • Make sure that products and services are appropriate and suitable, meet clients’ needs, and take into account their financial situation, objectives, risk tolerance and risk profile. Even if TASConnect may know the client well, but must never guess likely decisions on their behalf

      • Handle complaints in a friendly, fast, fair and effective way. Keep to all procedures for handling complaints and use client feedback to identify the root causes of issues. If TASConnect has all the facts and can identify a root cause, the Company will be able to improve the products and services and create better outcomes for clients

Compete fairly in the market place

TASConnect is committed to competing fairly. The risk relating to competition law is increasing including where the Company operates, as well as changing regulations. Most states and countries worldwide have developed competition-law regimes and all employees must comply with competition law at all times and in all countries where TASConnect operates. TASConnect is also responsible for complying with the Competition / Anti-Trust Policy.

Breaching competition law is extremely serious. Most competition authorities across the world can impose substantial fines for competition law (or antitrust) breaches, which can be up to 10% of TASConnect’s yearly turnover. And, competition investigations are extensive, disruptive to the business and ability to focus on the clients, and may result in criminal sanctions and imprisonment for the people involved.

Manage conflicts of interest

Managing conflicts of interest effectively allows TASConnect to act fairly, avoid legal and regulatory risks, and protect the Company’s brand, reputation, and own personal integrity.

Conflicts of interest fall into two broad categories – business and personal. When any actual or potential conflicts of interest is identified, TASConnect must act immediately to deal with them openly, honestly and effectively.

Business conflicts of interest can arise in the following situations:

      • Between TASConnect and the clients, suppliers or other third parties including general users of the markets in which TASConnect operates

      • Between clients and other third parties

      • Between different businesses within TASConnect

Personal conflicts of interest may arise when employees put personal interests ahead of those of a client, supplier, other third party or TASConnect. This would include instances where one have an interest or association (eg. an outside business interest) that may interfere with the Company’s interests or the interests of the clients. They may also arise where one have close personal relationships or close financial relationships with other colleagues.

      • Always act with independence and with integrity in all of the dealings

      • Think carefully and anticipate and properly identify all possible conflicts of interest

      • When changing the structure or make-up of any business activities, consider how these changes may create new conflict situations or change conflicts that have already been identified

      • Report any actual or possible conflict identified, immediately to the relevant Senior Management and Risk and Compliance

      • Conflicts of interest should be escalated, recorded and managed in a clear and effective manner in accordance with relevant policies and procedures

      • Make sure any conflict is dealt with in a clear, open and effective way

      • Get approval before one take part in outside business interests and close personal or financial relationship

      • Be familiar with the Conflicts of Interest Policy and comply with the conditions in them

Reject bribery and corruption

There is no room in this organisation for acts of bribery or corruption. Bribery and corruption are illegal, dishonest, and extremely damaging to the countries and communities where they take place. TASConnect must actively reject bribery and corruption in all its forms.

When someone gives a benefit to someone else in order to influence that person’s behaviour, that is a bribe. When someone takes improper advantage of their position to make a gain for themselves, they are acting corruptly.

TASConnect must not give or accept bribes or take part in, or enable, any forms of corruption. It’s vital for employees to stay vigilant because the risk of bribery can arise in any of the operations, at any time where the Company is dealing with a third party. Bribery and corruption can take many forms – through procurement decisions, expenses, gifts and entertainment, hiring decisions, sponsorships, donations, the actions of the customers and so on.

TASConnect must take the time to consider how the day-to-day business activities might encounter or create the risk of bribery and corruption. This will help TASConnect to be better positioned to identify possible bribery and corruption. TASConnect must make sure that the transactions and activities the Company takes part in are not, and cannot be perceived as, an improper inducement for business.

Some important points to highlight:

      • Take particular care if the work involves interactions with Public Officials – including anyone working for government departments, regulators and state-owned enterprises. The rules in this area are more complicated, and the risk can be higher. If this applies to employee’s role, contact Risk and Compliance for more guidance

      • TASConnect can be held legally responsible for the actions of intermediaries and third parties who act on behalf the Company anywhere in the world. When dealing with third parties, TASConnect must make sure that the bribery and corruption risk has been assessed and controlled. This is why TASConnect has robust procurement policies in place

      • Some practices that may be considered normal where the work may actually be illegal under the UK Bribery Act or US Foreign Corrupt Practices Act, or create the perception of bribery or corruption somewhere else. As a result, this can have a negative effect on TASConnect. Employees must take this into account when deciding on the right thing to do, and get advice if necessary

      • If it genuinely feels that personal safety might be at risk when not taking part in bribery or a corrupt arrangement, report it to Risk and Compliance. This should also report the incident to the relevant authorities, where appropriate

      • Get to know the clients. If there is a meaningful and deep relationship with the clients, employees will be better placed to identify and detect potentially inappropriate behaviour

      • TASConnect’s policies explains the rules around giving and receiving gifts and entertainment to make sure they are allowed, properly approved, and recorded. These rules will help to protect the employees and employees are to be familiar with them

The guidance set out in TASConnect’s Anti-Bribery Policy and Procedures must be followed, and other policies which may govern bribery and corruption risk for specific activities. When making decisions to deal with any bribery and corruption risk, TASConnect must make sure these are properly and honestly documented.

Fight financial crime

Financial crime has an enormous global impact. When it is allowed to take place, it negatively affects society at all levels – from ruining the lives of people to threatening the global economy. Financial crime allows drug and human trafficking to take place, supports the smuggling and counterfeiting of goods, underpins illegal gambling and financing terrorist activity and tax evasion, among other criminal acts. TASConnect has a duty to protect the communities that the Company serves from the damaging effects of financial crime.

TASConnect is committed to preventing the laundered proceeds of crime (including those from tax evasion) and financing terrorism from being a part of the overall economy and financial system. TASConnect is committed to preventing the Company, the staff (and other associated people) from the criminal facilitation of tax evasion by the clients. Bribery and corruption cannot be tolerated. TASConnect is also committed to keeping to all legally binding sanctions, including measures against people and organisations and measures against specific countries (or nationals or residents of those countries).

TASConnect must play a strong and effective role in the fight against financial crime. The Company owes this to the customers as well as to the global financial system in which TASConnect operates.

TASConnect must cooperate fully with governments, regulators and other financial services providers to protect client accounts from fraud and to help tackle organised financial crime. TASConnect also must act with skill, care and diligence in the ongoing development of financial crime compliance programmes. All of the employees must apply TASConnect’s standards on financial crime compliance as well as any local anti-money laundering laws and regulations.

Some measures taken:

      • Thoroughly check the identity of the clients from reliable evidence as part of the Customer / Client Due Diligence (“CDD”) procedures, and get to know clients so as to recognise transactions which are inconsistent with their business or do not match the normal pattern of activity for which the account was set up

      • Report suspicious activity immediately (if it is about or suspected to be money laundering, Risk and Compliance must be contacted)

      • Understand and follow the sanctions restrictions

      • Report any suspicion of fraud immediately to line manager and contact Risk and Compliance

      • Employees to not get in the way of any reporting or investigation of any suspected financial crime

      • Complete financial crime compliance training

      • At all times, all employees to follow TASConnect’s anti-money laundering / counter terrorist financing, sanctions, anti-bribery and corruption policies and procedures

Do not engage in or support insider dealing

Insider dealing1 is a criminal offence in most states and countries and may lead to fines or prison if convicted. Insider dealing creates an unfair advantage and undermines the financial system. The nature of TASConnect’s work at times and/or potentially means that the Company is trusted to handle inside information in an appropriate way (if applicable). And TASConnect is all responsible for living the valued behaviours and demonstrating the Company’s commitment to being trustworthy.

Insider dealing includes dealing on own account or encouraging someone else to deal, based on the inside information held. Insider dealing may also take place if one reveals the information to anyone else, other than in the proper performance of work.

The Conflict of Interest standards and any other specific business procedures governing related personal account dealing activities (if any) must be abided by. This applies to transactions carried out by one’s own account or if one has influence over the investment decisions on the accounts of others (if applicable). TASConnect may treat this as a serious disciplinary matter when in breach of the Conflict of Interest rules.

Do not deal or cause someone else to deal:

      • When in possession of any inside information
        If employees have, or have access to, inside information or possible inside information:

      • Escalate this in line with Conflicts and Information Walls standards and/ or the management of Inside Information standards (if applicable); and

      • Make sure that inside information is not shared with or revealed to any other people, other than in the proper performance of work

As a designated employee (if applicable), any potential dealing account intention must be informed or disclosed to Risk and Compliance.

5. SOCIAL RESPONSIBILITY

Respect the communities and the environment

TASConnect has the ability and responsibility to make positive change in the communities. TASConnect wants to make sure that the product and services that are provided supports sustainable economic and social development in the communities in which the Company operates.

The upcoming position statements and internal Environmental, Social and Governance risk management (ESG) framework will guide the business activities. They set out the environmental and social standards TASConnect expects of the clients, and the positive behaviours the Company encourages.

TASConnect has a duty to respect the human rights of others who may be affected by they Company’s actions and decisions, whether in the sourcing decisions, through providing products and services, or in how the employees work with each other including supporting the communities.

TASConnect is also establishing targets to manage the Company’s energy, paper and water usage. The Company’s commitment to meeting these targets means TASConnect is managing the resources responsibly.

TASConnect is also strictly non-political and do not get involved in political activities, support political parties or have any political links.

What TASConnect can do:

      • Identify opportunities to make a positive contribution to the communities and the environment

      • Making sure that providing products and services matches the ESG risk management framework

      • Being aware of how the day-to-day decisions made might affect the human rights of others, and acting within the policies to avoid negative outcomes (Reputational Risk)

      • Keeping to the policies on political activities, including the Sponsorship and Donations Policy

6. REPORTING CONCERNS

Speaking Up

TASConnect must maintain a culture of strong ethics, integrity, transparency, and openness. By Speaking Up employees help the Company to identify issues and deal with them.

Misconduct is damaging for everyone. It exposes TASConnect to significant risks and can damage the Company’s financial performance, reputation, and the trust of everyone who has an interest in the business.

The Company and employees all have an important role to play in protecting TASConnect ‘s reputation and the industry at large.

There may be a time when something at work that does not feel right. Speaking Up is a safe, confidential way to let the Company know of it. Some examples of when one should speak up:

      • Failing to comply with laws or legal obligations, including committing fraud or other criminal acts

      • Putting the health and safety of a person in danger

      • Damaging the environment

      • Breaching rules or regulatory requirements

      • Failing to comply with codes of conduct, business or country policies and procedures

      • Doing anything which has or is likely to have a negative effect on TASConnect’s reputation or financial well-being

      • Confidential information, including personal data, is lost or stolen

      • Deliberately concealing any of the above

It is enough to have a reasonable belief that any of the above situations has taken place, is taking place, or could take place. However, when Speaking Up, one must do so honestly and in good faith. Knowingly reporting untrue information is not acceptable.

There are a number of ways to raise a concern:

      • Speak to someone in one’s management chain or outside of one’s management chain, for example (a member of the Senior Management or Risk and Compliance)
      • Use the designated Speaking Up channel: email to Speakup [speakup@tasconnect.com]
 
1Inside information is information of a precise nature, which has not been made public, relating directly or indirectly to issuers or financial instruments, which, if it were made public, would likely have a significant effect (either positive or negative) on the price of those financial instruments or the price of related derivative financial instruments to which it relates. Inside information can be information about the Company or information given about others.
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