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P.2

 

"Training –maintain staff training to include education on slavery and human trafficking"

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raining and

Code of

Ethics and

Conduct

All

our

employees are required to act with integrity and to a high ethical standard.

T

hrough clear

ly drafted

policy and

procedure documents and training

,

our employees have the support

they need

to

help them to meet the standards of

ethics and conduct set by us and overarching rules and regulations.

Our

employees are required to ensure that all

relationships in the

workplace are respectful, free of harassment, bias, bullying and violence. We have no

tolerance

for such harassment or discrimination in the workplace or among our Employees.

The code of ethics and conduct

policy is reviewed annually and employees are required to confirm, on an annual basis, that they have read and

understood it.

The five

guiding principles

our c

ode of ethics and conduct

polic

y

are:

i.

act ethically and with integrity

;

ii.

put clients’ interests first

;

iii.

prevent and manage conflicts of interest

;

iv.

retain and disclose information appropriately

; and

v.

o

bserve high standards of market

conduct

.1