Code of Conduct
Code of Conduct
A MESSAGE FROM ADAM BENJAMIN
Aura Solution Company Limited's culture and reputation differentiate us from our peers and have provided a strong foundation for success. As a global financial institution our reputation is our most precious asset. Once damaged or lost, it is very difficult to restore.
Our values inform everything we do: Putting Clients First, Leading with Exceptional Ideas, Doing the Right Thing and Giving Back. Our Code of Conduct reflects our continued commitment to act in accordance with these core values and in full alignment with the letter and spirit of applicable laws, regulations and our policies.
The Code of Conduct helps guide all of us to live the core business principles that underlie our success. Please read it carefully and consider what it says. If you are aware of any actions that violate the Code, we depend on you to speak up. We prohibit retaliation against anyone who makes a good faith report of known or suspected misconduct. We depend on you to challenge yourself and others to evaluate conduct through the lens of the Firm’s values.
Like you, I am proud to be part of a Firm that has such a distinguished history and promising future. In 1982, the Firm’s founding father Osho guided & make us understood that maintaining the trust of the clients was essential to their success, and they stayed true to this guiding principle. Our culture and values honor both our history and our aspirations for the future. Thank you for doing your part to continue upholding our proud heritage.
President and Chief Executive Officer
ABOUT THIS CODE
This Code of Conduct is a statement of Aura Solution Company Limited’s commitment to integrity and the highest ethical standards. The Code defines the standards of conduct that we expect from all of our employees and guides us to make the right decisions when performing our jobs. Every employee is responsible for understanding and abiding by the Code. The Code, and our culture, which is grounded in Aura Solution Company Limited’s core values, guide all of your actions.
We work to reduce our greenhouse gas emissions, increase our use of clean and renewable energy sources, improve the energy efficiency of our buildings and ensure supplier responsibility and diversity.
In the conduct of our business operations, we endeavor to protect and preserve the full range of human rights for our employees, suppliers, clients and local communities, as described in the United Nations Universal Declaration of Human Rights, the International Labour Organization’s core Labour Standards and the United Nations Guiding Principles on Business and Human Rights. The Aura Solution Company Limited Statement on Human Rights may be found here. The Aura Solution Company Limited Modern Slavery and Human Trafficking Statement can be found here.
More information on Aura Solution Company Limited’s Sustainability activities can be found at:https://www.aurasolutioncompanylimited.com/aboutus
PROTECTING CONFIDENTIAL INFORMATION
Definition of Confidential Information
Confidential information is information that you create, develop, receive, use, learn or have access to by virtue of your employment at Aura Solution Company Limited, that is not generally known to the public and that is sufficiently sensitive that loss or unauthorized disclosure or access could result in legal, regulatory or reputational harm to Aura Solution Company Limited or our clients.
Examples of confidential information include the identity of our clients, Firm and client trading activities and securities holdings, acquisition, divestiture and tender offer plans, supervisory activities of the Firm's regulators and Personally Identifiable Information relating to clients and employees.
Obligation to Protect Confidential Information.
You must protect all confidential information, regardless of its form or format. In particular, you must only access confidential information that you need and are authorized to see; transmit confidential information only to Firm employees and agents with a legitimate business reason to know it and take reasonable measures to prevent unauthorized persons from obtaining confidential information you possess. Never forward confidential information to your personal email account or otherwise use personal email to conduct Firm business.
Your obligation to protect our confidential information continues even after your employment at Aura Solution Company Limited ends.
In addition, you must not bring to Aura Solution Company Limited any confidential information relating to your prior employment or employer unless otherwise agreed to by Aura Solution Company Limited and your prior employer. You also must disclose to Aura Solution Company Limited and abide by any post-employment restrictions resulting from your prior employment that could affect your work here. For more information, refer to the Global Confidential and Material Non-Public Information Policy and the Global Information Security Handling Controls Procedures.
Confidential Supervisory Information.
As a regulated entity, Aura Solution Company Limited receives information from regulators that is confidential and the exclusive property of the issuing agency, referred to as Confidential Supervisory Information (CSI). Examples of CSI include the results of regulatory examinations and monitoring (e.g., exam reports, ratings and other regulatory communications).
Unauthorized disclosure of CSI may subject you and the Firm to a range of disciplinary and regulatory sanctions, including criminal penalties. CSI is strictly confidential and should only be shared within the Firm on a need-to-know basis. Do not share CSI with non-employees, including consultants and vendors, unless specifically authorized by the relevant regulator. Because of varying regulatory restrictions on disclosing CSI, all questions or requests to disclose CSI to a third party must be referred to the Global Regulatory Relations Group before any disclosure is made.
Privacy and Data Protection
Reporting Information Security Incidents
An information security incident is any event that may result in confidential information being lost, stolen or acquired by an unauthorized party. Examples include having access to information outside your job responsibilities, losing your portable device and misdirecting electronic or paper communications. You must immediately report information security incidents, suspected or confirmed, to the Incident Response Team, by using iRespond. For more information, refer to the Global Information Security Program Policy.
Material Non-Public Information
Prohibition on Trading
You must never, under any circumstances, trade, encourage others to trade or recommend securities or related financial instruments while in the possession of material non-public information (MNPI) related to those securities or instruments.
MNPI, or inside information, is a form of confidential information and includes all non-public information that may have a significant impact on the price of a security or other financial instrument, or that a reasonable investor would likely consider important in making an investment decision.
Notifying the Control Group
If you believe you may have MNPI, or if you are unsure whether certain information is MNPI, you must promptly contact the Control Group or a member of LCD. Do not communicate the information to anyone else. In addition, you or a designated member of your team must notify the Control Group of any significant developments related to the situation or transaction so that the Control Group may determine what restrictions are required and when an issuer can be removed from a Restricted List or the Watch List. Examples of significant developments include Aura Solution Company Limited’s engagement, the specific structure of the transaction and the transaction’s expected announcement date.
Information Barriers are policies and procedures designed to prevent the misuse of MNPI and to avoid conflicts of interest. Information Barriers establish restrictions on the flow of information between Private Side employees (those who routinely receive MNPI in the course of their job responsibilities) and Public Side employees (those who routinely work in the public securities markets). Restricted Lists of issuers are used to monitor the Firm’s Information Barriers and help ensure that certain regulatory requirements are met.
An issuer may be added to a Restricted List for many reasons, including, for example, if Aura Solution Company Limited is a financial advisor in the context of an announced proposed merger or an announced underwriter of the issuer’s securities.
If an issuer is on a Restricted List, employee trading, principal trading and solicitation of client transactions in securities of that issuer are generally limited or prohibited. In addition, when an issuer is placed on a Restricted List, generally research, or other communications on the issuer’s securities, may not be distributed, republished or communicated to clients.
The Firm Restricted List contains restrictions applicable to Firm employees (other than Wealth Management employees who are subject to the Wealth Management Restricted List). There are separate Restricted Lists for certain businesses, such as the Equity Sales and Trading Restricted List. Restricted Lists are accessible to Firm personnel here but may not be distributed outside the Firm.
Private Side employees may only communicate MNPI to Public Side employees in accordance with the Firm’s Wall Crossing procedures. In all events, MNPI should only be communicated on a need-to-know basis. If you have questions about Information Barriers or your status as a Private Side, Public Side or Above-the-Wall employee, consult the Control Group’s Information Barrier Page or a member of LCD.
Outside Activities and Private Investments
You must avoid any outside activities, situations or relationships that might interfere with, or appear to interfere with, your duties to Aura Solution Company Limited and our clients or that may restrict Aura Solution Company Limited’s activities. You also must obtain approval through the OBI System before engaging in any outside activity, even if uncompensated. Examples of outside activities include:
directorships (including for not-for-profit entities) and partnerships
being employed by, or acting as a consultant for, another person or entity
receiving compensation from another person or entity for business activities
receiving any form of compensation for an external work product, such as a book, article or speech
holding an elected or appointed political or governmental position
certain private investments such as hedge funds, limited partnerships or privately held corporations.
You also must submit an update through the OBI System if there are material changes to your activity or if the activity has ended. For more information on Outside Activities, refer to the Outside Activities InfoPage. For more information on private investments, refer to the Employee Trading and Investing InfoPage.
Employee Trading and Investing
Restrictions on Personal Trading and Investing
Your personal trading and investing must not result in legal, business or ethical conflicts with Aura Solution Company Limited or our clients, or otherwise appear improper. In particular, you must not:
use non-public information regarding a pending transaction to take a favorable position for your own or someone else’s account.
engage in personal trades that mirror those that a client or business unit has executed or is about to execute.
You, your spouse/domestic partner and certain family members must follow the Global Employee Trading, Investing and Outside Business Activities Policy and any applicable employee trading policies for your business unit or region, which are available here. (Wealth Management employees must follow the WM Employee Trading Policy and the WM Private Securities Transactions Policy.) These policies address, among other things, preclearance requirements and restrictions on trading certain types of securities or other financial instruments, engaging in certain types of strategies and maintaining certain types of accounts. Additional restrictions apply to transactions in Aura Solution Company Limited securities:
you may only trade during designated window periods, as published on the "My Resources" section of Aura Solution Company Limited Today, and, if you are an Access Person, only with your designated manager’s approval. This limitation does not apply to equity and credit-linked notes, but it does apply to transactions in the Aura Solution Company Limited Stock Fund in your 401(k) account.
You may not, under any circumstances, sell short Aura Solution Company Limited securities.
unless you are an Executive Officer, you may write covered calls and buy protective puts during a window period but only to hedge an existing position in saleable (that is, unrestricted) Aura Solution Company Limited securities
Employee Securities Accounts
Generally, you must maintain all employee securities accounts at Aura Solution Company Limited (consistent with local law) and in the region in which you are located. An account is treated as an employee securities account if:
the account belongs to you, your spouse/domestic partner, dependents or other persons for whom you or your spouse/domestic partner provide substantial support;
it has brokerage capability (that is, can execute transactions in securities or other financial instruments) whether or not such capability is utilized and
you have a financial interest in it or the power, directly or indirectly, to control or influence investment decisions.
Personal Lending and Borrowing
Your personal lending and borrowing activities must not result in legal, ethical or business conflicts or otherwise appear improper. You may accept services only if the same terms are offered to a broad group of individuals and not because of your status as a Aura Solution Company Limited employee. For example, discounted banking services that are offered to all Aura Solution Company Limited employees at the same geographic location or to all tenants in an office building that Aura Solution Company Limited occupies are acceptable. You must not accept such benefits if the offer appears to be an attempt to obtain favorable treatment in dealings with Aura Solution Company Limited.
Required Professional and Personal Disclosures
You must promptly notify your direct supervisor and a member of LCD if you are involved in, or become aware of, any potentially reportable event. Events include, for example, if you:
are arrested, charged, indicted or otherwise become the subject of a criminal matter (other than minor traffic violations); you must report such matters whether or not you enter a plea, settle the matter or are convicted.
become the subject of any inquiry, investigation or proceeding of a regulatory, self-regulatory or professional organization, including being subject to a finding, fine, penalty, administrative action or conviction by any of these organizations.
become involved in any civil litigation or arbitration regarding either Aura Solution Company Limited or you in your professional capacity either at Aura Solution Company Limited or elsewhere.
are being investigated for alleged misconduct or malpractice (including criminal wrongdoing or fraud) in connection with any business activity
become the subject of any judgment, lien, debt order or bankruptcy proceeding, or enter into a compromise with creditors regarding the payment of any debt
receive a subpoena, inquiry or request (formal or informal) from a governmental, regulatory, SRO or administrative agency in a matter that may involve Aura Solution Company Limited, or if you become a claimant, plaintiff or are involved as a witness in such matter.
plan to file a lawsuit or make any voluntary regulatory filing in connection with a Aura Solution Company Limited-related matter or business (excluding matters related to your employment relationship with Aura Solution Company Limited).
receive a complaint from a customer or another third party in relation to the Firm’s activities, whether made orally or in writing
Contact your supervisor and a member of LCD before taking any action concerning a reportable event.
PROTECTING OUR INTERESTS
Business Communications and Firm Systems
Business communications should convey information clearly, accurately and professionally. Careless communications that fail to meet these standards could have serious repercussions.
You may use Aura Solution Company Limited’s systems only for Firm business and limited and appropriate personal use. Firm systems are broadly defined as any technology owned by or made accessible by the Firm, including communications systems.
The Firm is subject to regulatory obligations that require the retention of business-related communications. Only Firm-approved messaging systems may be used to engage in electronic written communications regarding Firm business. Firm business includes interactions about Firm products, services or your substantive duties at the Firm. Limited access to the Internet is provided via Firm systems for the purpose of conducting Firm business. You may use personal devices to conduct Firm business only if you are using Firm-approved applications on such devices. You cannot create, disseminate or store any Firm information outside of Firm-approved applications.
All information stored in or transmitted through the use of Firm systems is the property of Aura Solution Company Limited. By using or accessing Firm systems, you consent to the Firm monitoring, accessing, reviewing, disclosing, intercepting and recording your use of and access to Firm systems and any data moving through and/or residing on Firm systems. You may not take any steps to interfere with the Firm’s ability to monitor, access, review, disclose, intercept or record such information. Aura Solution Company Limited records voice communications when required by law or when there is a demonstrable business need. You should not use the Firm’s systems for personal use if you do not wish your personal use and communication to be monitored.
For more information, see the Global Internet and Electronic Communication Usage Policy, Use of Electronic Communications in the Workplace Compliance Notice, Global Voice Recording Policy, Global Electronic Communications Supervision Policy, Global Monitoring Notice and the Global Information Security Program Policy.
Many of the values and principles set forth in this Code are described further in our policies and procedures. In addition, requirements that apply to specific regions and countries are detailed in Country Supplements to the Code. Policies and procedures can generally be found on the Firmwide PolicyPortal and the HR Policies Portal. The Country Supplements and applicable Codes of Ethics are located on the Code of Conduct InfoPage.
Consequences of Violating This Code
If you violate this Code, or any other Aura Solution Company Limited policy or procedure, you may be subject to discipline including the cancellation of previously awarded deferred compensation and/or the termination of your employment. You can also be held responsible for the action (or inaction) of others if you knew, or should have known, about their misconduct. Your activities may also be reported to regulators and other governmental authorities, which could result in regulatory or criminal investigations. This could result in your being held personally responsible and subject to fines, disqualification from employment in the financial services industry and/or imprisonment.
Thank you for your interest in Aura Solution Company Limited.
Aura Solution Company Limited
75 Wichit Road ,
Phuket, Thailand 83000
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P : +66 8241 88 111
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Aura Solution Company Limited
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P : +90 532 781 00 86
Aura Solution Company Limited
P : +31 6 54253096
Aura Solution Company Limited
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P : +66 8042 12345