StatPro Code of Conduct

 

1 Introduction

The StatPro Code of Conduct sets out the principles and practices by which the Board of Directors expect StatPro, and its people, to operate. The code applies to all employees and officers of the company (including any temporary and third-party employees) and is intended to be used as a guiding principle that encompasses everything that people at StatPro do. 

This Code of Conduct is not intended to replace good judgement and common sense but serves as a guide and minimum standard of conduct. The purpose of this Code of Conduct is to provide basic guidelines for situations in which ethical issues arise. 

If an employee becomes aware of any breach of the Code of Conduct, they are obligated to report it in accordance with the procedures set forth below. Failure to comply with any of the provisions of this Code of Conduct may lead to disciplinary measures up to and including termination. 

2 Key Principles

The following Key Principles apply: 

2.1. Overarching Integrity, Professional and Ethical Behavior

Everything we do is to high standards in the best interests of our clients, people or assets. We build trusted client relationships and we do what is always best for the client, ensuring we build their trust and respect. We put our client interests ahead of our own and never let our personal or corporate conflict of interests interfere or influence our dealings with our clients.

The following other areas are relevant: 

2.1.1. Equal Opportunity Employment

Employment at StatPro is based upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation or any other characteristics protected by law. 

2.1.2. Harassment, Discrimination, and Bullying

StatPro people have the right to work in an environment that is free from discrimination, harassment and bullying in any form. Harassment (i.e. unwanted behaviour of a sexual, physical, or verbal nature by one employee to another, and which violates dignity or creates and intimidating, hostile or offensive environment) will not be tolerated at StatPro. Any behavior of this manner may lead to disciplinary action being taken against an employee, which may include summary dismissal. It is also an offence to induce or encourage such behaviour in other employees. You are also reminded of our policies on the appropriate use of the email, internet, social media and telephone.

If you feel you are being harassed, you should raise the issue through the Grievance Procedure detailed in the employee handbook. 

2.1.3. Drugs and Alcohol

The consumption of alcohol is not banned at StatPro offices as there may be special occasions when this happens, and as such, when done so is subject to the use of good judgement. You are not to behave in a way that leads to impaired performance or inappropriate behaviour, endanger the safety of others, or violate the law. Illegal drugs in StatPro offices or at sponsored events are strictly prohibited. If it is reasonably suspected that an employee’s use of drugs and/or alcohol may adversely affect the employees’ job performance or the safety of the employee or others in the workplace, a senior manager may request an alcohol or drug screening (in accordance with the local law). A reasonable suspicion may be based on subjective symptoms such as the employees appearance, behavior, or speech.

2.1.4. Company Assets 

StatPro assets must not be used for personal benefit or the benefit of anyone other than the Company. Excessive personal calls or e-mail is a misuse of assets: at all times common sense must prevail. Please refer to the Acceptable Use Policy for more information.

2.1.5. Anti Bribery and Corruption

It is StatPro’s policy to conduct all our business in an honest and ethical manner. The company takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery. 

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both in the UK and abroad. 

2.1.6. Laws and Regulations

StatPro takes its responsibilities to comply with laws and regulations very seriously and each employee is expected to comply with applicable legal requirements and prohibitions. While it is impossible for anyone to know all aspects of every applicable law, you should understand the major laws and regulations that apply to your work. 

2.2. Conflicts of Interest

A conflict of interest may arise in any situation in which an employee’s loyalties are divided between personal interests that, to some degree, are incompatible with the interests of StatPro or its clients. At StatPro we want to encourage an environment that protects its clients, suppliers and employees from such conflicts. 

The following are areas of potential conflicts that should be considered: 

 2.2.1. Gifts and Hospitality/Entertainment

We avoid giving gifts of any material monetary value to clients or potential clients. Branded items related to marketing campaigns of minimal value are our only exception and must be executed through our marketing department. 

We should also avoid accepting gifts or hospitality/entertainment of any material monetary value greater than £100 from anyone seeking business of any kind from StatPro. An employee can attend or host a meal or event with a client or business contact, but even in that situation, expenses should be within reasonably expected limits. If in any doubt, please contact your Director or HR manager. 

All gifts with a monetary value greater than 100 or more should be notified to the Group Finance Director for inclusion on our register of gifts.

2.2.2. Outside Employment, Advisory Roles, Board Seats, and Starting Your Own Business

Priority should be given to the exercise of duties and functions to StatPro and other professional services – remunerated or otherwise – should not be performed for other competing companies or institutions, regardless of the relationship on which such services are based, unless expressly authorised by the Group CEO. 

Any other professional activity, including self-employment and/or for non-competing organisations or companies should be notified to Human Resources as soon as this activity arises. 

2.2.3. Non-public (sensitive) Information

If, in the ordinary course of business, you are privy to nonpublic or price sensitive information, do not disclose such information to anyone outside StatPro (including to family and friends), except when disclosure is required for business purposes. This is particularly relevant when it comes to client portfolio information. This is considered Confidential and should always be protected. 

Similarly, do not disclose nonpublic information to anyone inside StatPro unless they have a business reason (‘need to know’ principle applies), and communications have been classified accordingly. Refer to the StatPro information classification standards and ensure you understand them. 

Employees are always obliged to protect the Company’s nonpublic information, including outside the workplace and working hours, and even after employment ends. 

2.2.4. Personal Share dealing and dealing in StatPro shares

Trading in stocks or securities based on material nonpublic information or providing material nonpublic information to others so that they may trade is illegal and may result in criminal prosecution. 

StatPro is a publicly listed company and, as such, employees (and connected persons, i.e. spouse/partners/certain close family members) may not trade in StatPro shares without seeking prior approval from the Chairman. This control will ensure that no one inadvertently transacts within a closed period or breaches any of the principles above. 

If in any doubt on the two points above, please discuss with the Operations Director or Group Finance Director. 

2.2.5. Relationships in the Workplace 

Avoid participating in the management of and/or decision-making regarding potential or existing StatPro business relationships (clients or suppliers) that involve your relatives, spouse or significant other, or close friends. This includes being the hiring manager for a position for which your relative is being considered or being a client relationship manager for a company associated with your spouse or significant other. If in any doubt, please discuss the relationship with your Director and HR Manager. 

Romantic relationships between co-workers can, depending on the work roles and respective positions of the co-works involved, lead to an actual or apparent conflict of interest. If a romantic relationship does create an actual or apparent conflict, it may require changes to work arrangements. If in any doubt please discuss the relationship with your Director and HR Manager. 

2.2.6. Political Activity

StatPro encourages personal participation int he political process in a manner consistent with all relevant laws and Company guidelines. However, for such personal activity the following principles apply. 

  • StatPro will not reimburse employees for personal political activity. 
  • Your role will not be affected by your personal political views or your choice in political contributions. 
  • You should not sure the Company’s reputation or assets, including your time at work, to further your own political activities or interests.
  • If you plan to seek or accept any position in a political party or public office, you must inform a Board Director (subject to the requirements of local laws in certain jurisdictions)

2.2.7. Intellectual Property

StatPro staff should not post or do anything to jeopardise any of the Company’s confidential and sensitive information, trade secrets and intellectual property. This includes, but is not limited to, activities at work, business plans and financial performance. You should also avoid infringing on intellectual property rights of other companies and individuals which can create liability for the Company as well as the individual.

The StatPro logo, brand name, slogans or other trademarks should not be used without prior written permission from the Head of Marketing. Contact details of business contacts made during the course of employment are regarded as the Company’s confidential information and as such staff will be required to delete all such details from their personal social networking accounts on termination of their employment. 

Please refer to the Social Media Policy for specific requirements relating to the use of Social Media. 

2.3. Financial Integrity and Responsibility

Ensuring accurate and complete business and financial records is everyone’s responsibility, not just a role for accounting and finance personnel. Accurate recordkeeping and reporting reflect on the Company’s reputation and credibility and ensures that the Company meets its legal and regulatory obligations. 

2.3.1. Expense Approvals

When you submit and expense for reimbursement or spend money on StatPro’s behalf, please make sure that the cost is reasonable, directly related to the company business, and supported by appropriate documentation. Always record the business purpose and comply with other submission requirements. If you’re uncertain about whether you should spend money or submit and expense for reimbursement, check with your manager. Managers are responsible for all money spend and expenses incurred by their direct reports and should carefully review such spend and expenses before approving. 

2.3.2. Signing Contracts and Committing the Business

Each time you enter into a business transaction on StatPro’s behalf, there should be documentation recording that agreement, approved by the relevant manager. 

You should ensure that you are permitted by the StatPro Group’s delegated authority matrix to commit the company to any financial commitments prior to signing an agreements or approving any purchase orders. 

3 Policies and Guidelines

The Code of Conduct does not address all workplace conduct. Each StatPro employee is required to affirm they have read and understood this Code and other corporate mandatory policies. Furthermore, StatPro maintains additional policies and guidelines that may provide further guidance on matters in the Code or address conduct not covered by the Code. Please ensure you have read and understood all policies that are considered to be relevant for your role. If in doubt on any policy please contact your Director, HR or the Global Head of Governance, Compliance or Risk. 

4 Whistleblowing

It is important that any fraud, misconduct or wrongdoing by employees or officers of StatPro is reported and promptly dealt with. We therefore encourage all individuals to raise any concerns that they may have about the conduct of others in the business or the way in which he business is run to either Operations Director, Group Finance Director or HR. This will be treated with the utmost confidentiality. This includes but is not limited to: 

  • Questionable accounting, internal accounting controls and auditing practices;
  • Compliance with any legal and regulatory requirements. 
  • Business practices likely cause reputational damage or expose the business to unnecessary risk. 

5 Conclusion

StatPro is a financial technology business, but it takes the right people to drive our business forward. StatPro invests in a significant amount of time and effort to identify and hire the best people, with the potential to excel and ultimately become leaders. Ownership, responsibility and transparency are highly promoted values within the business. This attracts people with an entrepreneurial spirit and a “can-do” attitude, who can continue to push performance and quality levels higher.  Instead, we rely on one another’s good judgement to uphold a high standard of integrity for ourselves and our Company. 

It’s impossible to spell out every possible ethical scenario we might face. Instead, we rely on one another’s good judgement to uphold a high standard of integrity for ourselves and our Company. We expect all employees to be guided by both the letter and spirit of this Code. Sometimes, identifying the right thing to do isn’t always the easy thing to do. If you are unsure, don’t be afraid to ask questions of your manager, Director, HR or Global Head of Governance, Compliance or Risk.