Preamble

At Lowndes Partners Group, our commitment to ethical excellence is the cornerstone of our business. Our Code of Ethics and Standards of Professional Conduct reflect our unwavering dedication to the highest ethical practices and professional standards. These principles are vital in preserving the trust and confidence of our clients and are fundamental in executing our mission to set the benchmark for integrity and ethical conduct in the financial advisory sector. Our Code is the foundation upon which our reputation and professional practices are built, driving us to act responsibly and conscientiously in the global market.

 

The Code of Ethics

Lowndes Partners Group and its affiliates, including management, board of directors and staff, are committed to:

 

• Upholding integrity, competence, diligence, and respect in all dealings with the public, clients, and colleagues within the financial markets.

• Prioritizing the integrity of the financial profession and the interests of our clients above personal gains.

• Applying careful judgment and independent professional decision-making in investment analysis, recommendations, and actions across all areas of professional engagement.

 

Standards of Professional Conduct

 

I. Professionalism

A. Knowledge of the Law

Staff must have a comprehensive understanding of and comply with all applicable laws, regulations, and professional standards. In cases of conflict, the stricter law or regulation must be followed. Staff should actively avoid any involvement in violations of these laws and regulations.

 

B. Independence and Objectivity

Staff must maintain independence and objectivity in their professional activities. They must not accept any offers that could compromise their professional judgment or the integrity of their work.

 

C. Misrepresentation

There must be no deliberate misrepresentation of professional qualifications or services in any dealings or communications.

 

D. Misconduct:

Professional conduct involving dishonesty, fraud, or deceit is strictly prohibited, and staff must uphold a reputation for integrity and competence.

 

II. Integrity of Capital Markets

A. Material Nonpublic Information

Staff with insider information must not act on or influence others with this information.

 

B. Market Manipulation

Staff are prohibited from engaging in practices that mislead market participants or manipulate market prices or trading volume.

 

III. Duties to Clients

A. Loyalty, Prudence, and Care

Staff owe a duty of loyalty, must act with care, and exercise prudent judgment in all dealings with clients.

 

B. Fair Dealing

Staff must treat all clients fairly and objectively.

 

C. Suitability

Staff must ensure investment recommendations are suitable for the client's financial situation and consistent with their objectives.

 

D. Performance Presentation

Investment performance must be communicated honestly and accurately.

 

E. Preservation of Confidentiality

Client confidentiality must be protected except in specific circumstances as outlined by law or client consent.

 

IV. Duties to Lowndes Partners Group

A. Loyalty

Staff should prioritize the interests of Lowndes Partners Group in professional activities.

 

B. Additional Compensation Arrangements

Any potential conflicts of interest from additional compensation must be disclosed and written consent obtained.

 

C. Responsibilities of Supervisors

Supervisors must ensure compliance with these standards within their teams.

 

V. Investment Analysis, Recommendations, and Actions

A. Diligence and Reasonable Basis

Staff must conduct diligent and thorough investment analysis and actions based on sound research.

 

B. Communication with Clients and Prospective Clients

Clients must be kept informed of the investment process, risks, and limitations.

 

C. Record Retention

Proper records must be maintained to support investment decisions and communications.

 

VI. Conflicts of Interest

A. Disclosure of Conflicts

Conflicts of interest must be disclosed to clients and managed appropriately.

 

B. Priority of Transactions

Client and employer transactions take precedence over personal transactions.

 

C. Referral Fees

Any referral fees or compensation received must be disclosed to clients and the firm.