CODE OF CONDUCT

OUR CODE OF CONDUCT CONSISTS OF 3 PRINCIPLES: THE OPENNESS IN PROVIDING THE FACTS, INTEGRITY AND RESPECT TO OUR CUSTOMER – BIG AND SMALL. 

COMPANY’S ESSENTIAL PRACTICES (A PART OF OUR BROKER CONTRACT’s WARRANTY CLAUSE) 

ANTI-CORRUPION RULES OF THE COMPANY

We don’t support corruption in any form. We do neither give, nor take the bribes. We do not gift government entities or/and authorities.

INTERNATIONAL SANCTIONS AND BOYCOTT RULES

Our firm does not support the trade with countries and territories, companies and individuals that are listed into sanctions list of U.N., OECD, USA, UK, E.U, Switzerland, Ukraine and in regards to whom the boycott has been officially announced.

BROKER’S RIGHT TO CANCEL THE BUSINESS

Company leaves the right to cancel the business (potential business) if:
(a) client has not provided the brokers necessary level of transparency while entering into the business;
(b) brokers detect attempts of blackmailing, hacking or/and fraud from the part of the client(s);
(c) the client is detected insolvent or bankrupt and/or can not prove soundness of his current financial condition.

INFORMATION: ITS’ STORAGE AND USE

Company acts in frame of confidentiality and holds the data received from the third parties, whether they are clients, co-brokers, other market participants, privately and without disclosure with only exceptions as:

• if we are the witness of the business and are requested by lawyer of the plaintiff or claimant, to disclose the data to arbitration court in relation to this business or/and counter party involved;
• if the court order is received for disclosure of the information;
• if international and/or Ukrainian investigators request written statement(s) or/and documents describing certain business / contractual events;
• if clients insisted on disclosure or were not against of the disclosure the market or corporate information by the broker to the third parties;
• if we are to protect our interests in response to allegations or claims obtained from the client(s) and/or third partie(s) in relation to the business we conduct or compliance to the code of conduct and essential company’s practices as such.

 

IN RELATION TO BUSINESS TELEPHONE CONVERSATIONS

As the majority of the contracts we intervene as brokers are domiciled in England, we therefore, in accordance with Laws of England, may opt to record telephone and other verbal communications for sake of comfort and safety of the business.