Code of Ethics

1. Dealing with Clients

Our belief is that long-term shareholder value is derived from meeting the on-going needs of Clients. Consequently our Clients and the Customers of our Clients are central to our thinking in all the actions and decisions that we make.

At all times we will:

- Deal with all our Clients fairly, openly and honestly.
- Provide high standards of service.
- Provide a range of services that meet Client needs and are readily understandable.
- Maintain the confidentiality of Client information.
- Operate effective complaints processes to deal with situations where these standards are challenged.

2. Dealing with all Employees

Our belief is that meeting the on-going needs of all Employees can only be achieved by developing a working environment and culture that allows us to build a competitive and sustainable advantage in the market.

We will seek to achieve this through:

- Open and honest communication.
- Employing good people who are focused on getting the job done and done well.
- Providing clear leadership on what the business is seeking to achieve and why.
- Making decisions quickly whilst being able to demonstrate why decisions have been made and their intended consequence.
- Providing opportunities for existing Employees to challenge themselves and grow their experience and skill sets.
- Support employees who are prepared to take risks with their own careers and goals.
- Providing, where at all possible, the opportunity to align personal objectives with business ones.

3. Dealing with Shareholders

Our belief is that long-term shareholder value is an outcome of getting it right for Clients and Employees, whilst not losing sight of the need to grow the business.

At all times we will:

- Seek to engender the trust and support of all our Shareholders through our actions and in decisions that we make.
- Communicate business policies, achievements and prospects honestly.
- Agree all future strategic direction of the business.
- Ensure transparency of information on the Group's financial performance.
- Comply with all applicable laws, rules and regulations that govern our business.
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4. Dealing with Suppliers of Goods and Services

Our belief is that any supplier of services is integral to the success of our business and the working relationships we have with them will reflect this.

At all times we will seek to:

- Maintain the highest possible standards of integrity in our business relationships.
- Use where possible /practicable those suppliers who operate with values and standards equivalent to ours.
- Work together with suppliers to improve all aspects of performance.
- Ensure orders for goods and services are placed and paid in accordance with agreed terms.

5. Dealing with Competitors

Our belief is that our reputation in the market and with our Clients is one of our most important assets and we will seek to protect this for the long term value of our business

Consequently:

- We will conduct ourselves professionally in the market and not provide an opportunity for any of our competitors to call into question the integrity of our business.
- We will compete honestly, vigorously and with respect in the market but not unfairly.
- We will not disclose proprietary or confidential information in any contact with competitors.

6. Dealing with our Regulators

Our belief is that any Government body or our Regulators establish the minimum standards that we must adhere to in the conduct of our business and that they are integral to the on going success of our business.

We will therefore seek to:

- Maintain a constructive and open relationship with governments and regulators to foster mutual trust, respect and understanding of our business and the issues that we, and our Clients face.

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