Code of Conduct and FCA Regulation

At The Pallinghurst Group (the “Group”), responsible and lawful conduct is a prerequisite for all our business activities and relationships. Our internal policies, including the Group’s Equal Opportunities Policy, allow us to ensure that our shared values of commitment to equality are integrated throughout the Group.

Vital to the sustainable success of the Group is the responsible and appropriate treatment and support of all persons with whom the Group comes into contact. This applies universally whether it be our own employees, clients or shareholders; international governmental authorities or simply initial enquiries.

The Group’s Code of Conduct prioritises the building and maintaining of trust with all stakeholders, emphasises our commitment to compliance with applicable laws and provides our employees with guidelines to our expectations of responsible conduct. We also encourage our business partners to respect and adhere to these shared values.

Our various internal policies are distributed to all employees throughout the Group and form part of the on-boarding training provided to new employees. Mandatory online training for the employees of our UK regulated entity which is authorised and regulated by the Financial Conduct Authority (“FCA”), have been in place since 2009 and support is provided to all Group employees for individual development needs in their respective specialist subjects. Staff welfare is of high priority; Pallinghurst provides Employee Assistance Programs and 24/7 access to an array of medical advisors to ensure staff are holistically supported in their physical and mental wellbeing, both at work and at home.

Pallinghurst Advisors LLP, as Investment Advisor to the Group, is authorised and regulated by the UK’s Financial Conduct Authority (“FCA”) to provide advisory services. Due to its regulatory status, Pallinghurst Advisors LLP follows a recognised structure and fulfils a set of obligations varying from regulatory reporting to employee training on subjects such as anti-money laundering, identifying market abuse and conflicts of interest. Pallinghurst Advisors LLP’s regulatory status with the FCA provides the Group with advice from a trusted and recognised group company which adheres to one of the most reputable and trusted regulatory regimes worldwide.