In accordance with CFA Institute standards
Introduction
“Ethical code and standards of professional behaviour” (“Code and Standards”) – is a major document that reflects companies’ and individual professionals values in the area of financial markets and investment activities, regardless of occupied position, cultural features or specifics of local legislative standards or normative acts.
Aston Financial services thoroughly follows professional standards of “Code and standards” and commits itself to inform all of our existing and potential clients about our professional position.
Ethics Code
To act in accordance with principals of good faith, competence and respect, following ethical norms towards our existing and potential clients, employers and employees, colleagues in the investment area and other participants of global asset markets.
To act professionally and accordingly to ethical norms, as well as to encourage others to act that way, support our own professional reputation and trust towards profession.
To put compliance with the norms of good faith and honesty in investment profession and clients interests above personal interests.
To act with due attention and to make independent professional decisions while performing an investment analysis, making investment recommendations, committing investment activity and performing other professional activities.
Promote the integrity and viability of the world’s asset markets with the greatest benefit to the community.
Sustain and improve personal professional level and make an effort to sustain and improve professional level of other specialists of the investment craft.
PROFESSIONALISM
Knowledge of legislation. Professional representatives must understand and comply with applicable laws, regulations and norms (including the Code of Ethics and Standards of Professional Behaviour of the CFA institute) of any government, regulatory authority, licensing authority or professional association regulating their professional activities. In the event of disagreement between provisions, professional representatives must comply with more stringent provisions of the law, rules or norms. Professional representatives should not knowingly participate in or contribute to any violation of these laws, rules or norms and should also be separated from such actions.
Independency and objectivity. Professional representatives must exercise due diligence and prudence to achieve and maintain their independence and objectivity in their professional activities. Professional representatives are prohibited from offering, requiring or accepting any gifts, profits, fees, or fees that, according to reasonable expectations, may compromise the independence and objectivity of decisions taken by them or the others.
Intentional distortion of facts. Professional representatives are not allowed to distort any facts, regarding investment analysis, recommendations, actions or other professional activities.
Misconduct behaviour. Professional representatives are prohibited from resorting to any professional actions that are dishonest, fraudulent or fraudful, and to engage in any activity that has a negative impact on their professional reputation, integrity or competence.
To act professionally and accordingly to ethical norms, as well as to encourage others to act that way, support our own professional reputation and trust towards profession.
To put compliance with the norms of good faith and honesty in investment profession and clients interests above personal interests.
To act with due attention and to make independent professional decisions while performing an investment analysis, making investment recommendations, committing investment activity and performing other professional activities.
Promote the integrity and viability of the world’s asset markets with the greatest benefit to the community.
Sustain and improve personal professional level and make an effort to sustain and improve professional level of other specialists of the investment craft.
I.PROFESSIONALISM
A. Knowledge of legislation. Professional representatives must understand and comply with applicable laws, regulations and norms (including the Code of Ethics and Standards of Professional Behaviour of the CFA institute) of any government, regulatory authority, licensing authority or professional association regulating their professional activities. In the event of disagreement between provisions, professional representatives must comply with more stringent provisions of the law, rules or norms. Professional representatives should not knowingly participate in or contribute to any violation of these laws, rules or norms and should also be separated from such actions.
B. Independency and objectivity. Professional representatives must exercise due diligence and prudence to achieve and maintain their independence and objectivity in their professional activities. Professional representatives are prohibited from offering, requiring or accepting any gifts, profits, fees, or fees that, according to reasonable expectations, may compromise the independence and objectivity of decisions taken by them or the others.
C. Intentional distortion of facts. Professional representatives are not allowed to distort any facts, regarding investment analysis, recommendations, actions or other professional activities.
D. Misconduct behaviour. Professional representatives are prohibited from resorting to any professional actions that are dishonest, fraudulent or fraudful, and to engage in any activity that has a negative impact on their professional reputation, integrity or competence.
II. CAPITAL MARKETS INTEGRITY
A. Material non-disclosed information. Professional representatives who do not have material information that is not disclosed and may affect the evaluation of the investment, must withhold from any actions and prevent any actions of the others that may use this information.
B. Manipulation of the market. Professional representatives are prohibited from participating in actions that result in the distortion of pricing information or the artificial increase in the volume of trading in order to mislead market participants.
III. OBLIGATIONS BEFORE THE CLIENTS
A. Loyalty, prudence and due attention. Professional representatives should be loyal to their clients, act with due regard and make prudent decisions. Professional representatives are obliged to act in the interests of their clients and to put the interests of clients over the interests of the employer or their own interests.
B. Ensuring integrity. Professional representatives should act honestly and objectively with all clients while conducting an investment analysis, giving recommendations on investing, conducting investment or other professional activities.
C. Ensuring Compliance.
1. When acting as clients’ advisor, professional representatives are obliged to:
a. Before giving any recommendations on investing or conducting investment actions, find evidence of investment experience, financial constraints, the level of risk, and the profitability of an existing or potential client, as well as the obligation to regularly review and update such information.
b. Before giving any recommendations on investing or conducting investment operations, make sure that the investment corresponds to the financial condition of the client and is consistent with the investment objectives, powers and restrictions of the client, expressed in writing form.
c. Evaluate the eligibility of investments in the context of the client’s total investment portfolio.
2. If Professional representatives are responsible for the management of an investment portfolio in accordance with certain powers, strategies or style, they shall provide only those investment recommendations and only those investment actions that meet specified goals and investment portfolio constraints.
d. Presentation of the results of the investment. By providing information about the results of the investment, the professional representative should take all appropriate measures to ensure the reliability, accuracy and completeness of such information.
e. Confidentiality. Professional representatives are obliged to keep the confidentiality of information about current, former and potential clients, except in the following cases:
1. This information relates to unlawful actions of a client or potential client;
2. Disclosure of such information is required by law, or
3. The client or potential client has given permission to disclose this information.
IV. OBLIGATIONS BEFORE THE EMPLOYERS.
A. Loyalty. Professional representatives should act according to the interests of their employer by using their professional skills and abilities, refrain from disclosing confidential information and cause the employer of any other kind of harm.
B. Agreements on additional rewards. Professional representatives are not allowed to accept gifts, surcharges, fees for their services or any reward that conflicts with the interests of employer or, based on routine expectations, may lead to conflicts of interests with their employer, if there is no written consent for this of all the involved parties.
C. Managers’ responsibilities. Professional representatives must take all the appropriate measures to ensure that all persons under their supervision or direction comply with the relevant laws, rules, norms and the Code and Standards.
V. INVESTMENT ANALYSIS, RECOMMENDATIONS AND ACTIONS.
A. Diligence and feasibility. Professional representatives are obliged:
1. Adhering to the principles of diligence, independence and carefulness in the processes of: investment analysis, providing investment recommendations and investing activities.
2. To conduct any investment analysis, recommendations or action on the basis of proper and adequate grounding, confirmed by appropriate research.
B. Communication with clients and potential clients. Professional representatives are obliged:
1. To provide existing and potential clients with the basic information and general principles of investment processes used for the analysis of investments, selection of securities and creation of investment portfolios and to inform about all changes that can have a significant influence on such processes.
2. To inform clients and potential clients about significant constraints and risks associated with the investment process.
3. To apply due diligence when defining factors that are important for the investment analysis, recommendations or actions, and inform existing and potential clients about these factors.
4. To distinguish between facts and judgments in investment analysis presentations and recommendations
С. Documentation management. Professional representatives should develop and maintain appropriate documentation that reflects their investment analysis, recommendations and actions, as well as other exchanges of information on investments with existing and potential clients.
VI. CONFLICT OF INTERESTS
A. Notifying of conflicts. Professional representatives should provide complete and reliable information about facts that, based on solid groundings, may negatively affect the independence and objectivity of their decisions, as well as interfere with the fulfilment of their respective obligations to clients, potential clients and the employer. Professional representatives should ensure the accuracy and comprehensibility of such information and to report such information in due course.
B. Priority of operations. Investment operations carried out in the interests of clients and the employer have a priority over investment operations, in which the professional representative is interested.
C. Rewards for the recommendation. Professional representatives must notify their employer, clients or potential clients of any service fee, gratification on or occasional income received from others or paid elsewhere for product or service recommendations.