Equality & Diversity Policy

Amma Group recognises that diversity and inclusion help to support creativity and innovation: they are an essential ingredient in any successful company. We are committed to encouraging diversity and inclusion and ensuring there is no discrimination in our company. We want our workforce to be truly representative of all sections of society. We want our company to be one in which every employee and freelancer feels respected and able to give their best.

To that end, this policy provides a framework of equality and fairness for all in our employment. It expresses our commitment not to discriminate on the grounds of age, disability, gender, gender reassignment, marital status (including civil partnerships), race, ethnic origin, colour, nationality, national origin, religion or belief, or sexual orientation.

This policy applies to employed and freelance staff.

All freelancers and employees, whether part-time, full-time or temporary, will be treated fairly and with respect. Selection for employment, whether as a member of staff or on a freelance basis, will be on the basis of aptitude and ability. Access to opportunities for promotion, training or any other benefit will also be on the basis of aptitude and ability. All employees will be encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the creativity and success of the company.

We will:

• Review all our formal and informal employment/hiring practices and procedures to ensure they are fair and help us to identify the best talent.

• Identify and take opportunities to increase the diversity

• Ensure reasonable adjustments are made to enable disabled people to work in or with our company.

• Actively seek to increase the diversity of our talent networks.

• Create an environment in which individual differences and the contributions of all our staff and freelancers are recognised and valued.

• Ensure every employee and freelancer is able to work in an environment that promotes dignity and respect for all. We will not tolerate any form of intimidation, bullying or harassment.

• Ensure training, development and progression opportunities are available to all staff.

This policy is fully supported by the senior management of the company. Breaches of the policy may be regarded as misconduct and could lead to disciplinary proceedings.

Code of Ethics & Professional Conduct

Our Code of Ethics and Professional Conduct clearly and explicitly outlines how all employees should behave in order to prevent transgressions of the law, damage in the confidence of financial markets, and maintain generally accepted standards of behaviour to handle client issues/complaints.

 Code of Ethics

•       Act with integrity, competence, diligence, respect and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets.

•       Place the integrity of the investment profession and the interests of clients above their own personal interests.

•       Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities.

•       Practice and encourage others to practice in a professional and ethical manner that will reflect credit on themselves and the profession.

•       Promote the integrity and viability of the global capital markets for the ultimate benefit of society.

•       Maintain and improve their professional competence and strive to maintain and improve the competence of other investment professionals.

Code of Professional Conduct

PROFESSIONALISM

1. Knowledge of the Law. AMMA Asset Management B.V. employees must understand and comply with all applicable laws, rules, and regulations of any government, regulatory organisation, licensing agency, or professional association governing its professional activities. In the event of conflict, AMMA will comply with the more strict law, rule, or regulation. Employees must not knowingly participate or assist in, and must report any violation of such laws, rules, or regulations.

2. Independence and Objectivity. Principals, employees and third party service providers must use reasonable care and judgment to achieve and maintain independence and objectivity in their professional activities. Principals and employees must not offer, solicit, or accept any gift, benefit, compensation, or consideration that reasonably could be expected to compromise their own or another’s independence and objectivity

3. Misrepresentation. Principals and employees must not knowingly make any misrepresentations relating to investment analysis, recommendations, actions, or other professional activities.

4. Misconduct. Principals and employees must not engage in any professional conduct involving dishonesty, fraud, or deceit or commit any act that reflects adversely on their professional reputation, integrity, or competence.

INTEGRITY OF CAPITAL MARKETS

1. Material Nonpublic Information. Representatives of AMMA who possess material nonpublic information that could affect the value of an investment must not act or cause others to act on the information.

2. Market Manipulation. Representatives of AMMA must not engage in practices that distort prices or artificially inflate trading volume with the intent to mislead market participants.

DUTIES TO CLIENTS AND ULTIMATE INVESTORS

1. Loyalty, Prudence, and Care. Representatives of AMMA have a duty of loyalty to clients and investors and must act with reasonable care and exercise prudent judgment. They must act for the benefit of their clients and investors by placing their clients’ interests before their employer’s or their own interests.

2. Fair Dealing. Representatives of AMMA must deal fairly and objectively with all clients and investors when providing investment analysis, making investment recommendations, taking investment action, or engaging in other professional activities.

3. Suitability. When AMMA representatives communicate with clients and investors, they must:

   1. Make a reasonable inquiry into an investor’s or prospective investor’s investment experience, risk and return objectives, and financial constraints prior to providing an investment fund’s private placement memorandum, making any investment recommendation or taking investment action.

   2. Possess or gain an understanding of the regulatory requirements of fund clients to ensure that participation of prospective investors are consistent with exemptions from securities regulation in the investors jurisdiction.  Exemptions will usually limit participation in investment funds managed by AMMA Asset Management to “sophisticated” and/or “high net worth” individuals or entities.

4. Performance Presentation. When communicating investment performance information, representatives must make reasonable efforts to ensure that it is fair, accurate, and complete.

5. Preservation of Confidentiality. Representatives must keep information about current, former, and prospective clients confidential unless:

   1. The information concerns illegal activities on the part of the client or prospective client,

   2. Disclosure is required by law, or

   3. The client or prospective client permits disclosure of the information.

DUTIES TO EMPLOYERS

1. Loyalty. In matters related to their work relationship representatives must act for the benefit of the firm and not deprive it of the advantage of their skills and abilities, divulge confidential information, or otherwise cause harm to AMMA.

2. Additional Compensation Arrangements. Representatives must not accept gifts, benefits, compensation, or consideration that competes with or might reasonably be expected to create a conflict of interest unless they obtain written consent from all parties involved.

3. Responsibilities of Supervisors. Representatives must make reasonable efforts to ensure that anyone subject to their supervision or authority complies with applicable laws, rules, regulations, and this code.

INVESTMENT ANALYSIS, RECOMMENDATIONS, AND ACTIONS

1. Diligence and Reasonable Basis. Principals and employees must:

1. Exercise diligence, independence, and thoroughness in analysing investments, making investment recommendations, and taking investment actions.

2. Have a reasonable and adequate basis, supported by appropriate research and investigation, for any investment analysis, recommendation, or action.

2. Communication with Clients and Prospective Clients. Principals and employees must:

1. Disclose to clients and prospective clients the general principles of the investment processes they use to analyse investments, select securities, and construct portfolios and must promptly disclose any changes that might materially affect those processes.

2. Disclose to clients and prospective clients significant limitations and risks associated with the investment process.

3. Use reasonable judgment in identifying which factors are important to their investment analyses, recommendations, or actions and include those factors in communications with clients and prospective clients.

4. Distinguish between fact and opinion in the presentation of investment analysis and recommendations.

3. Record Retention.  Principals and employees must develop and maintain appropriate records to support their investment analyses, recommendations, actions, and other investment-related communications with clients and prospective clients.

CONFLICTS OF INTEREST

1. Disclosure of Conflicts. Principals and employees must make full and fair disclosure of all matters that could reasonably be expected to impair their independence and objectivity or interfere with respective duties to their clients, prospective clients, and employer. Representatives must ensure that such disclosures are prominent, are delivered in plain language, and communicate the relevant information effectively.

2. Priority of Transactions. Investment transactions for clients and employers must have priority over investment transactions in which a principal or employee is the beneficial owner.

3. Referral Fees. Principals and employees must disclose to the firm, clients, and prospective clients, as appropriate, any compensation, consideration, or benefit received from or paid to others for the recommendation of products or services.