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CODE OF CONDUCT

Our Code of Conduct defines the expectations on business ethics and conduct we have for all our colleagues and those we partner with to ensure we earn and maintain the trust of our clients.  

Our reason for being

As an independent, distinctive and specialised asset management firm, our purpose is to help clients meet their long-term financial objectives and aspirations by investing their assets in a responsible way, and delivering sustainable value to them.

We believe that our clients and their advisers rightly expect us to identify and maintain intelligent and repeatable ways in which to generate investment outcomes that meet their expectations.

We similarly believe that our clients, colleagues, owners and other stakeholders expect us to approach our work in a way that enables us to have a positive impact on society.

We are committed to developing as a business, and to remaining relevant to the needs and expectations of our clients.

 
Business Conduct Risk

MGI has defined business conduct risk as the risk that through our decisions, strategies and behaviours, the MGI business and its staff do not do the right thing, acting in a way which does not treat our customers fairly and/or fails to support the integrity of financial markets.

 
Our Values

As a business, we have high expectations on business ethics and conduct for our colleagues and those we partner with to ensure we earn and maintain the trust of our clients. We believe this is a core element of who we are and our culture, which we are proud of and we are all accountable for ensuring that is the case.

This code of conduct provides high level guidance for all at Merian Global Investors (“MGI”) on those expectations and what they mean in practice.

Our values below broadly outline the behaviours we expect those in our business to adhere to:

• Act with integrity, due skill, care and diligence
• Ensure customer outcomes are the focus of our business & we are respected by regulators
• Collaborate with peers across the organisation
• Share openly and be transparent
• Adopt a responsible approach
• Maintain our entrepreneurial culture
• Strive for continuous improvement
• Lead by example

 

This code of conduct cannot be prescriptive on every decision or situation you may find yourself in. Ask yourself the below questions when you find yourself uncertain about what your next steps should be:

• Who might your decision affect – your client, shareholders, community, counterparty, colleagues, team, family, or friends?
• What facts do you have and what assumptions have you made to form your decision?
• Are you doing what you said you would do?
• Are you being honest? Is it fair? How would you feel if you were in their position?
• Are you in compliance with the law, regulation or policy?
• How would you feel if you were held publicly accountable for your action?
• Weigh up any short term gain against the longer term implications for the business, your reputation and the trust of the people you deal with.

Speaking up

We seek to conduct our business honestly and with integrity at all times. However, we acknowledge that we face the risk of our activities going wrong from time to time, or of unknowingly harbouring malpractice or wrongdoings. MGI aims to provide you with support and encouragement to raise any matters of genuine concern without fear of reprisals, and where your concerns will be investigated with respect and taken seriously.

 

Dignity at work

We have a strong commitment to the principle of dignity at work, equal opportunities and maintaining a culture that respects and values each others’ differences, that promotes dignity, equality and diversity, and that encourages individuals to develop and maximise their true potential.

Our working relationships should be based on fairness, respect, honesty and collaboration. That means we have zero tolerance of any form of harassment, abuse, discrimination or bullying of colleagues, contractors, suppliers, or anyone we deal with. All colleagues should behave in a way that supports an inclusive culture, embracing all forms of diversity. This applies during our daily business activities and also when we are in the communities in which we work. We respect human rights and reject any form of modern slavery.

Please see our Modern Slavery Act Statement available on our website.

Treating customers fairly (“TCF”)

We are a customer-focused organisation and our TCF framework for treating our customers fairly enables us to assess how we view, measure how we treat and deliver and improve fair outcomes for our customers.

 

Managing conflicts of interest

MGI manages conflicts of interest fairly, both between itself and its customers and between a customer and another customer.

It is the responsibility of all at MGI to report conflicts of interest in writing to the compliance department. All have a direct obligation to consider any potential or actual conflicts of interest during the course of day-to-day business activities or ad-hoc project work.

Good market conduct

We conduct our business honestly, fairly and with integrity at all times. This includes all dealings with customers, advisers, suppliers, business partners and regulators. We believe in fair competition, and that commercial relationships should be developed with proper motives, without inducement or any anti-competitive practices or unfair advantage.

 
Managing the risk of financial crime

Financial crime incorporates bribery and corruption, moneylaundering, fraud, the facilitation of tax evasion, terrorism financing and sanctions. These activities seriously affect the global economy, depriving society, and may be detrimental to our customers and shareholders, damage our reputation and undermine our market integrity.

We take seriously any act of financial crime, undertaken by, or through its businesses, colleagues, customers, advisers, suppliers or other external parties. We implement and maintain appropriate systems and controls to prevent financial crime and reduce the potential for financial loss, regulatory fines and/or censure and damage to reputation. As a responsible business we recognise, endorse and support compliance with all our financial crime prevention obligations.

We have detailed policies in place to help manage the risk of financial crime to which all colleagues must adhere.

Regulatory expectations

We operate in a number of jurisdictions and must comply with local regulatory requirements. In the UK the Financial Conduct Authority has introduced the Senior Managers and Certification Regime (SMCR) to govern how people working in financial services are regulated. The aim of SMCR is to reduce the risk of harm to consumers and strengthen market integrity by making individuals more accountable for their conduct and competence.

The SMCR includes high-level standards of behaviour through the Conduct Rules. The core Conduct Rules apply to all employees, while additional rules apply to senior managers, set out below:

Individual Conduct Rules (apply to all employees)

• You must act with integrity.
• You must act with due care, skill and diligence.
• You must be open and cooperative with regulators (e.g. FCA, PRA).
• You must pay due regard to the interests of customers and treat them fairly.
• You must observe proper standards of market conduct.

Senior Manager Conduct Rules (apply to designated individuals)

• You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively.
• You must take reasonable steps to ensure that the business of the firm for which you are responsible complies with the relevant requirements and standards of the regulatory system.
• You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee the discharge of the delegated responsibility effectively.
• You must disclose appropriately any information of which the FCA or PRA would reasonably expect notice.

 

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