Our employee code of conduct, which covers standard of conduct and professional ethics issues, requires employees to conduct their business in an honest and ethical manner. Employees are required to uphold a high level of business ethics and personal integrity and adhere to relevant local laws in their transactions and interactions.
Our personal account dealing and insider trading policies are designed to prevent staff members from trading in securities, either personally or on behalf of others, on material non-public information or communicating any material non-public information to others in violation of the law.
Our Anti-Money Laundering (“AML”) policy protects Affinity and the funds managed or advised by it (“Affinity Funds”) from potentially dealing with money launderers and others engaged in criminal activities and to fulfil Affinity’s regulatory obligations. It assures Affinity and the Affinity Funds that they can make the appropriate representations to counterparties with respect to its policies and procedures designed to prevent money laundering. Our AML policy helps Affinity avoid significant reputational harm that can come from being involved with money laundering and other illicit activities.
Our whistleblowing policy sets out a channel for employees and external parties to bring to the attention of the managing partners any misdeeds or improprieties committed by the management or staff of Affinity. The policy also aims to give employees the assurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.