Code of Ethics
for
Employees, Consultants and Associate Consultants

Golding Consulting Limited (the ‘Consultancy’), its members of Staff, Directors, Consultants and Associate Consultants have adopted the following Code of Conduct for their business practice. This Code of Conduct was formulated jointly by the Securities and Investment Institute and Guild of International Bankers in London and is supported by the financial institutions listed at the end of this page.

Principles

  1. To act honestly and fairly at all times when dealing with clients, customers and counterparties and to be a good steward of their interests, taking into account the nature of the business relationship with each of them, the nature of the service to be provided to them and the individual mandates given by them.

  2. To act with integrity in fulfilling the responsibilities of your appointment and seek to avoid any acts, omissions or business practices which damage the reputation of your organisation or which are deceitful, oppressive or improper and to promote high standards of conduct throughout your organisation.

  3. To observe applicable law, regulations and professional conduct standards when carrying out financial service activities and to interpret and apply them to the best of your ability, according to principles rooted in trust, honesty and integrity.

  4. When executing transactions or engaging in any form of market dealings, to observe the standards of market integrity, good practice and conduct required by, or expected of, participants in that market.

  5. To manage fairly and effectively, and to the best of your ability, any relevant conflict of interest, including making any disclosure of its existence where disclosure is required by law or regulation or by your employing organisation*.

  6. To attain and actively maintain a level of professional competence appropriate to your responsibilities and to commit to continuing learning and the development of others.

  7. To strive to uphold the highest personal standards, including rejecting short-term profits which may jeopardise your reputation and that of your employer, the Consultancy and the industry.

* On some occasions, when acting in connection with the business of the Consultancy, if there is a conflict of interest, the members listed above may choose not to act.

Supporting Institutions

The following financial institutions that are Corporate Members of the Securities and Investment Institute fully support its Code of Conduct:
  • Aberdeen
  • AIG Global Investment Group
  • Barclays Wealth
  • BNP Paribas
  • Brewin Dolphin Securities
  • Charles Stanley
  • Citi
  • Corporate Business Angels
  • Credit Suisse
  • Deutsche Bank
  • Direct Sharedeal
  • Dresdner Kleinwort
  • Edward Jones
  • Equity Trust
  • HSBC
  • ING
  • Killik & Co
  • Kotak
  • Morgan Stanley
  • Norwich Union
  • Oriel
  • Rathbones
  • Renaissance Capital
  • Rensburg Sheppards
  • Saint Paul Capital
  • Tri Alpha

The Securities & Investment Institute
Centurion House
24 Monument Street
London EC3R 8AQ
Tel: +44 (0) 7645 0600

Jon Golding, BSc(Hons), FSI, FCIB, is a practicing member and Fellow of the Securities and Investment Institute, Fellow of the Chartered Institute of Bankers and a member of the Guild of International Bankers in London. Golding Consulting Limited is not a member of any of these bodies but has adopted the Code of Conduct as the basis of its own business practice.

Updated: July 2007