The obligations outlined by this Code of Ethics are a supplement to, and do not replace Employee responsibilities and obligations listed in the firm’s Code of Conduct. Adherence to this Code of Ethics is a term and condition of employment for Finance Professionals. The firm will take all necessary actions to enforce it, up to and including immediate dismissal. Violations of this Policy may also constitute violations of law, which may expose both Employees and the firm to criminal or civil penalties.
The Code of Ethics applies to the conduct and reporting requirements of the Chief Executive Officer, Chairman, Chief Financial Officer and Principal Accounting Officer of Octalas (Finance Officers) and to all other professionals of the firm worldwide serving in a finance, accounting, line of business Treasury, tax or investor relations role (Finance Professionals).
Finance Officers and Finance Professionals must act honestly, promote ethical conduct and comply with the law, particularly as related to the maintenance of the firm’s financial books and records and the preparation of its financial statements.
Carry out their responsibilities honestly, in good faith and with integrity, due care and diligence, exercising at all times their best independent judgment. Comply with applicable government laws, rules and regulations of federal, state and local governments and other appropriate regulatory agencies.
Address actual or apparent conflicts of interest between personal and professional relationships by disclosing to their appropriate Legal or Compliance officer any material transaction or relationship that reasonably could be expected to give rise to such a conflict and Promptly report (anonymously, if they wish to do so) any known or suspected violation of the Code of Ethics or any other matters that would compromise the integrity of the firm’s financial statements Reports may be made anonymously to the Code Reporting Hotline or in any of the ways set forth in the Code of Conduct.
The reporting requirements do not prevent employees from reporting to the government or regulators conduct that the employee believes to be in violation of law, and it does not require employees notifying the firm prior to reporting to the government or regulators.
