Code Of Conduct

Our purpose

Our purpose at Zetafunds is to help people achieve a lifetime of financial security. In order to fulfil our purpose, we need to be a trusted, long-term partner for our customers, offering them financial solutions that are transparent, relevant, and rewarding at every stage of their lives.

Our core values

Zetafunds continually strives to meet the evolving needs of our customers, business partners, shareholders, employees and the wider communities in which we operate. Our ambition is for Zetafunds to be a trusted partner to our customers at every stage of life.

Working Together

Operating as a team makes us stronger, smarter and better. We build relationships as we work together with respect across disciplines, across borders, and with partners across the value chain. We welcome new perspectives and fully leverage the considerable knowledge and professional expertise that exists across Zetafunds

Bringing Clarity

By ensuring that we offer products and services that meet our customers’ needs, and by communicating clearly and transparently, we not only demonstrate our integrity but can also build long-term relationships founded upon trust. We are open, transparent, and customer-focused.

Exceeding Expectations

We care for our customers and are committed to providing them with exceptional products and service. We constantly strive to ensure that we not only meet the needs of our customers but do so in such a way that we consistently exceed their expectations. Every day, we aim for excellence, and hold ourselves accountable to the highest standards in everything we do.

Zetafunds is committed to maintaining high ethical standards. Our Code of Conduct embodies our values, and applies to all Zetafunds employees worldwide. It prescribes a mandatory set of conditions for how Zetafunds employees should conduct business, comply with all applicable laws and regulations, and exercise sound judgment in reaching ethical business decisions in the long-term interests of our stakeholders.

1. Complying with laws and regulations

What does this mean? Complying with all applicable laws and regulations is not only a legal requirement, but also vital if we are to fulfil our purpose and remain a trusted long-term partner to our customers.

2. Recording financial transactions

What does this mean? The trust of all our stakeholders – customers, shareholders, employees, and the wider community – is based on our reputation for integrity and transparency. Employees must not use secret accounts nor issue documents that do not properly or fairly reflect the transactions to which they relate

3. Inside information and insider dealing

What does this mean? Insider dealing and unlawful disclosure of inside information undermine the integrity of financial markets and destroy investor confidence, as well as harming the reputation of our company and employees. All our stakeholders should have access to the same information at the same time, without having to fear that someone with inside information will gain an unfair advantage at their expense.

4. Communicating on behalf of Zetafunds

What does this mean? Stories in the media (including social media) may have a significant effect on our reputation or our share price. It is essential therefore that only authorized employees communicate with the media or general public on behalf of Zetafunds. All communication on behalf of Zetafunds must be consistent with Zetafunds’s values, strategy, and objectives.

1. Treating our stakeholders fairly

What does this mean? As one of the world’s leading providers of long-term financial products and services, Zetafunds makes long-term promises to our customers, shareholders, employees and the wider community. By treating our stakeholders fairly, and conducting our business activities responsibly and with integrity, we can ensure that we continue to keep our promise to help people achieve a lifetime of financial security.

2. Providing clear products and services

What does this mean? By offering products and services that meet our customers’ long-term needs, and by communicating clearly and transparently, we not only demonstrate our integrity but can also build enduring customer relationships founded upon mutual benefit and trust.

3. Dealing with business partners

What does this mean? Zetafunds builds long-term relationships with business partners who share our values. Our partners include agents, brokers, suppliers and joint-venture partners. Zetafunds expects its employees to act with integrity and to exercise sound judgment.

4. Respecting confidentiality and third-party property rights

What does this mean? In this context, information includes company, customer, business partner and personal employee data. Proprietary or other confidential information may only be disclosed as permitted or required by law. Access to confidential information within the company is restricted to those who have a legitimate business need to know. Confidentiality is an essential requirement in order to maintain the trust and confidence of our customers, business partners and employees.

5. Preventing bribery and corruption

What does this mean? Š Zetafunds employees are strictly forbidden from offering any bribe (consisting of money or anything of value) to any private persons or public officials, irrespective of the worth, its results, local customs, the tolerance of such payments by local authorities, or the alleged necessity of the payment in order to obtain or retain business, or any other advantage;

• All commissions and other fees paid or accrued to insurance sales agents, business agents or other representatives of Zetafunds companies must be compliant with local regulatory requirements and in accordance with sound business practice, for legitimate commercial reasons, and represent an appropriate remuneration for services rendered;
• Employees are forbidden from seeking to obtain new business or any other improper commercial advantage by allowing undue payments to be made to clients either through agents or through any other Zetafunds company representatives;
• Employees must not accept or solicit any undue payment or any other improper advantage.
• Employees are allowed to accept corporate hospitality and gifts, provided these advantages are reasonable and in accordance with the relevant Zetafunds company policy. Such advantages should be properly disclosed in accordance with the established procedures. Hospitality or gifts that might appear to place employee

6. Avoiding conflicts of interest

What does this mean? Employees have an obligation to promote Zetafunds’s best interests at all times and should actively address any actual or potential conflicts of interest.

Examples of potential conflicts of interest are:

• An outside interest that prevents an employee from devoting full attention to his or her duties;
• Employees or their immediate family members, having a material interest in Zetafunds’s suppliers, agents, customers or competitors that might impair their ability to make impartial decisions on behalf of Zetafunds companies;
• Representing Zetafunds companies in a transaction in which an employee or an immediate family member has a material personal interest;
• Disclosing or using confidential Zetafunds company information for personal profit or advantage

Employees are required to identify and report any actual or perceived conflict of interest in a timely fashion through the appropriate reporting channels.

7. Refraining from anti-competitive behavior

What does this mean? Zetafunds employees shall not be involved in conduct that has a negative effect on competition. Employees must understand competition law rules and be fully committed to acting in complete compliance with them. If an employee is aware of any potential breaches of competition law, they should immediately report it using the appropriate reporting channels.

8. Preventing money laundering and the financing of terrorism

What does this mean? Employees must not participate in any activity aimed at laundering money or financing terrorism. In addition, they must not provide assistance to any person or organization trying to benefit from the proceeds of a criminal act or illegal activity or controlling funds invested for the benefit of a terrorist organization.

9. Complying with sanctions

What does this mean? Employees are strictly forbidden from engaging in any kind of transaction or agreement that violates sanctions. Employees must follow the relevant internal company rules and regulations governing international and local sanctions.

1. Preventing discrimination and other inappropriate behavior

What does this mean? Zetafunds is committed to providing all employees with a safe and fulfilling work environment where people treat each other with respect and dignity. Providing equal opportunity means that employees are selected solely on the basis of their ability to do the job, and that there is no distinction, exclusion or preference made on other grounds, either during the recruitment process or after. Employees experiencing or witnessing unfair treatment or other inappropriate behavior are encouraged to report it through the appropriate channels.

2. Protecting personal information

• Employees must identify the privacy risks before collecting, using, retaining or disclosing personal information, for example when introducing a new IT system, process, project or marketing initiative;
• Employees must only process personal information for specific, clearly defined, and legitimate business purposes;
• If personal information is processed or shared, the individuals concerned must have been advised of the possible use of their personal information. In some cases, their prior consent must also be obtained;
• Employees must seek to protect personal information if it is shared (with a third party)
• Employees must, to the extent their job duties allow, ensure that personal information that they have access to is accurate, its use is related to legitimate business purposes, and is kept up-todate;
• Employees must either securely dispose of personal information when there is no longer a legitimate business purpose for retaining such personal information, or if disposal is not reasonably viable, continue to protect such personal information consistent with this Code of Conduct until such time as it is securely disposed.

Employees who are not sure whether they need,for example, to obtain consent before sharing or processing personal information, or, who do not know how to protect personal information when sharing with a third party should seek advice from their Data Protection Officer, Legal or Regulatory & Compliance teams.

3. Proper use of Zetafunds assets and equipment

What does this mean? Zetafunds is committed to providing our customers with high quality products and services. Employees are expected to act at all times according to our values and in the interests of our company, customers and stakeholders when using company assets and communication tools.

4. Cooperating with internal and external investigations

What does this mean? Zetafunds is committed to maintaining the trust and respect of all our stakeholders. For this reason, we strive always to be open, honest and straightforward. This is particularly important in the case of investigations, either internal or external. All employees are required to cooperate with all such investigations and to avoid misrepresentations.

5. Reporting unethical or illegal behavior

What does this mean? Zetafunds is committed to creating and maintaining an open and supportive culture in which employees feel safe to raise concerns or report suspected or actual violations. Employees are often the first people to witness any wrongdoing within the company. It is important that such incidents are quickly identified and resolved to prevent or reduce any adverse effects, such as financial loss and reputational harm.

1. Community activity

What does this mean? What does this mean? Zetafunds encourages our employees to take part in activities that benefit their local communities. This includes political activity, providing it does not interfere with their obligations and responsibilities as an Zetafunds employee. Zetafunds fully supports the free right of association.

2. Investing Responsibly

What does this mean? Employees involved in managing assets must follow the agreed mandates and investment instructions, and operate according to customers’ investment requirements. This includes managing each portfolio according to the agreed risk profile. Zetafunds further seeks to incorporate Environmental, Social and Governance factors into our investment activities.

3. Supporting and protecting human rights

What does this mean? Zetafunds expects our employees to abide by these standards and principles during their business dealings and work for the company.