Ethics Policy

Our ethics policy is built on five pillars – Transparency, Client First Decisions, Competence, Confidentiality and Professional Behavior. Underpinning these five pillars is Integrity, which we define as being consistent in our application of the above principles, and holding not only ourselves but everyone in our company to the same high standards.

Our ethics policy will be reviewed at least once annually.

Transparency

Our definition: We will be transparent in all our dealings with our clients.

Examples:

Any conflicts of interest, whether real or perceived will be communicated openly to clients.
If we have made an error that has affected the client, even if it is rectified later, the client will be informed.
All fees we charge and commissions we earn will be communicated openly to clients.
Public access of our policies and business practices

Threats	Safeguards
Employees not disclosing errors that have affected clients, in fear of retribution from management.	The culture of the company should be to accept human errors as long as they are disclosed early and rectified as per policy, and the error has not been due to blatant disregard of policies and law.
Management enticed to keep policies and business practices private due to embedded conflicts of interest, high fees and commissions.	Policies and business practices that put the client first.

Client First Desicions

Our definition: All decisions we make will put the client first.

Examples:

If there is a choice between a product that pays a higher commission vs one that suits the client better, we will choose the latter.
If a decision we take leads to a loss for us, but better outcomes for our clients as a whole – we will make that decision.

Threats	Safeguards
Human nature will lead to justifying non Client First decisions.	Our policy of transparency of our business practices and processes will help mitigate that risk.
Remuneration policies that reward revenue over clients first.	Policies and business practices that put the client first.

Competence

Our definition: Before providing a service, we must have the competence, knowledge, and skills to provide that service.

Examples:

If we do not have the competence, we will not take on a client.
We will spend time increasing our competence, knowledge and skills by continued learning and professional development.
Stay informed and comply with relevant laws and regulations.

Threats	Safeguards
Trying to grow too fast will lead to us starting service lines which we do not have competence for.	Create a growth plan with required competencies listed.
Hiring staff based on cost, rather than competence.	Hiring processes will require certain minimum levels of competency for every position.

Confidentiality

Our definition: We will keep all Client information 100% confidential.

Examples:

Client situations will not be discussed for non-business purposes.
If client situations are discussed for business purposes, then only relevant personal info should be shared, in accordance with the privacy policy.
If a client is someone in your personal circle, you will not share their info with common acquaintances.
We will not share client info with third parties for profit unless the client has specifically agreed to do so.

Threats	Safeguards
Perception of clients as impersonal entities, rather than real people.	Enable a culture of respect for clients, seeing them as real people. One way of doing this would be to have events that bring together clients and the business.
Ambiguity about what info can be shared for business purposes.	Privacy policy.

Professional Behavior

Our definition: The client is the reason the business exists; we will keep that in mind during all our interactions with clients.

Examples:

Never keep a client waiting.
Never be late.
Go the extra mile.
Treat the client the way you would want to be treated if you were a client of another business.
Take extra care that communication & interaction with clients brings you across as a professional.

Threats	Safeguards
Overworked employees.	Automation of client interaction tasks that do not need custom client interaction.
Uncaring employees.	Form culture of respect for clients.

Integrity

Our definition: Integrity is being consistent in our application of the above principles, and holding not only ourselves but everyone in our company to the same high standards.

Examples:

Making sure we uphold our ethics principles at all times and not pick and choose.
If we feel others in our company are not upholding our principles, we will take appropriate steps to change; even if the other person is a ‘higher’ position or not in our team.

Threats	Safeguards
Lack of information about ethics.	Ethics is one of the first things explained to new hires.
Ethics is not seen as important.	Regular ethics training for all employees.
Not knowing what to do if we come across an ethics violation by another person.	Whistle-blower policy.
Ethics policy not being implemented.	Annual review of Ethics policy and its implementation.