Corporate Governance

Conflict of Interest

• Business Activities; Ownership of Securities
• Transactions with Related Persons

Corporate Opportunities

Confidentiality Obligations

• Nonpublic Information
• Media, Publishing and Public Appearances
• Client Information Privacy

Fair Dealing

• Providing Suitable Products and Services to Clients
• Unethical Behavior; Relationships with Competitors, Clients and Partners
• Gifts, Gratuities and Other Payments Related to the Group’s Business
• Customer Complaints

Respect for the Individual

Safeguarding the Group’s Information, Assets and Property

• Business Use
• Proprietary Information and Intellectual Property
• Compliance with Internal Controls

The Group’s Written and Electronic Communications

• Access to the Internet
• Written and E-Mail Communications
• Communications Monitoring

Compliance with Law

• Cooperation with Investigations
• Specific Policies and Regulations Affecting the Group

Commitment to Promoting Ethical Conduct