Code of Business Conduct

Our staff follow the highest levels of protocol for integrity, honesty, and transparency. We pride ourselves on a rich diverse culture and strong core values. We are committed to operating within a framework of ethical and professional standards, laws, regulations, internal policies, and the following core values-

1

Working well with each other

2

Working well with clients and others

3

Re-imagining the possible

4

Managing our objectivity and independence

5

Protecting data, information and intellectual capital

6

Care

Working well with each other

We Build

relationships with each other based on a shared trust and confidence that each of us has a personal and professional commitment to do the right thing. We collaborate and share relationships, ideas and knowledge to achieve successful outcomes. We seek and integrate a diverse range of perspectives, people and ideas. We give and ask for feedback to improve ourselves and others.

We Leverage

our differences to create an inclusive environment where all people feel, and are valued, for who they are, have a sense of belonging, and are inspired to contribute their best in every encounter.

We Are Committed

to building diverse teams and maximizing the power of different perspectives and backgrounds in our teams.

We Consult

with each other and value the perspectives of those who are different from us, and those who challenge our own point of view.

We Expect and Deliver

feedback regularly, candidly, and constructively, and positively recognize success.

Working well with clients and others

We Are Committed

to delivering quality services that reflect our professional capabilities, which are appropriate to the specific issues and needs of clients, and in accordance with the terms and conditions in our engagement agreements.

We Are Robust and Courageous

in our interaction with our clients in order to deliver appropriate, timely, specific and measured advice to achieve successful outcomes for our clients and in some cases, this may involve assisting the client to re-assess objectives in ever changing environments and circumstances.

We Consider

not only whether we can perform an engagement, but whether we should perform that engagement.

We Uphold

the professional standards and rules applicable to us, and our member firms actively work with the regulators who oversee our professional conduct to ensure that these rules and standards meet the continuously changing needs of the market.

Maintaining our objectivity and independence

We Maintain and Affirm

our objectivity and independence, recognizing that these are critical to our professional responsibilities.

We Employ

appropriate professional scepticism.

We Reject

inappropriate pressure.

We Are Alert

for personal and professional conflicts of interest and take immediate and appropriate steps to resolve or manage any that may arise.

Protecting data, information, and intellectual capital

We Respect and Protect

confidential data and information obtained from, or relating to, clients or third parties, as well as personal data and information about the Firm’s employees. We only share information when there is a business purpose, and then do so in accordance with Loeb Smith’s policies, applicable laws, and professional standards.

We Take Proactive Measures

to safeguard our documents, computers and other data devices that contain personal or confidential data and information, including following Loeb Smith’s policies on information security and technology. All employees must keep all confidential and personal data secure using the Firm’s channel to safeguard information.

We Use Social Media and Technology

in a responsible way and respect the confidentiality of everybody we work with.

Care

We Make Effort

to understand every individual and what matters to them. We recognise the value that each person contributes, support others to grow and work in the way that brings out their best and recognise the value that each person contributes.

Reimagining the possible

We are always curious and questioning

to innovate, test and learn from failure. We have an open mind to the possibilities in every idea.

Maintaining Compliance

We ensure that Loeb Smith acts in accordance with all laws and regulations applicable to our business.

Training

Compliance training is required for all employees. The training covers this Code of Conduct and gives information about the laws and regulations applicable to us conducting our business. The general training is performed for all employees of Loeb Smith on a regular and frequent basis.

Support

If you face a situation that could give rise to compliance concerns, we encourage you to contact our Compliance Department.

Monitoring, Auditing & Investigations

Loeb Smith monitors and audits its business activities to confirm that we adhere to the law and the Firm’s policies and guidelines. When potential compliance violations are brought to our attention, we will take appropriate action to investigate all such reports and ensure that our business is conducted in compliance with all applicable laws.

Voicing out and Whistleblowing

Creating a work environment in which we can be confident that everyone will be able to voice their concerns, opinions, contribute ideas and views. We are committed to making everyone feel comfortable and to challenge bad behaviour without fear of retaliation wherever it originates from. Our Whistleblowing Policy further provides an avenue for employees (both permanent and short-term) and external parties to raise concerns about any illegal, unethical or otherwise inappropriate behaviour observed in the course of our business. The policy contains strong assurance that whistleblowers will be protected from reprisals or victimisation if reports are made in good faith or are not malicious and it further provides guidance in its enforcement by listing examples of reportable behaviour. The direct reporting channels that have been set apart and handled with confidential safeguards is: Managing Partner. For queries or to make a report, please write to info@loebsmith.com. The Whistleblower Policy is available to all employees in each of our offices and to the public.

Tasks & Responsibilities

Act with Honesty, Professional Integrity and Competitive Approach

We conduct business with honesty, integrity and in a manner that protects Loeb Smith’s public image and reputation. Our competitive advantage is achieved through the excellence of our professional advice, and the quality of our products, solutions and service delivery.

Act Responsibly

We approach each interaction and relationship with the degree of professionalism that one would reasonably expect of an international professional service firm.

Follow the rules

We follow the law and our internal policies and guidelines when conducting business for Loeb Smith.

Respect others

We respect our fellow staff members, public officials, clients, and business partners. We strive for an inclusive environment free from discrimination, intimidation, and harassment.

Report violations

We report promptly all known or suspected violations of law, this Code of Business Conduct or Loeb Smith’s policies and guidelines through the appropriate channels. If someone asks or pressures us to do something that might be a violation, we report that as well.

Healthy and safe work Environment

Safety is first. The Firm is committed to ensure a safe ergonomic work environment in all offices.

Bribery, Corruption and Financial Crime

We have zero tolerance policy against corruption, money laundering, bribery and financing of terrorism. We are committed to comply with all applicable laws and regulations, our staff receives the strictest training for anti-money laundering and compliance training, as well as ensuring we follow our internal Anti-Money Laundering & Compliance manual.

Non-Retaliation

Retaliation against any employee or other persons, who seek advice, raises a concern, reports misconduct or provides information in an investigation is strictly prohibited.

Anti-Corruption

Loeb Smith is fully committed to complying with anticorruption laws of the many jurisdictions in which it undertakes business.

Conflicts of Interests

Employees are to report actual or potential personal conflicts of interest in house as soon as they are aware of conflicts. Any new client is verified to avoid any conflicts of interest across the offices and departments.