Ethical Standards and General Guidelines
Each employee of the company is required to be aware of and strictly adhere to ethical business practices and company operating guidelines outlined below:
1.
Staff Dealing Rules
Investment in Securities
Guidelines on investment in securities by employees require that employees disclose details of their investments to the company and this includes their investment in unit trusts that are managed by the company.
Staffs Trading Accounts
Employees can only maintain trading accounts with brokers which are designated by the company, in order to allow the company to supervise the staffs securities trading activities effectively.
Staffs Portfolio Holdings
Employees are required to disclose their portfolio holdings to the Compliance and Internal Audit officers annually. Furthermore, employees must obtain approval prior to any transaction of securities in accordance with guidelines set by the company and must report those transactions to the Compliance and Internal Audit officers for review each month.
Other general guidelines
Securities trading account applications require approval from the company
Short term trading of securities is prohibited
Trading of securities using inside information is prohibited
No front-running ahead of funds orders or making a purchase/sale transaction of securities countering those undertaken by funds.
Additional guidelines applicable to employees in line of duties exposed to investment-related job functions
Employees exposed to investment-related job functions refers to staff who have knowledge of the funds investment activities, which includes the Chief Executive Officer, staff in the Investment Management Department, Marketing Department, Fund Operations and Accounts, and the Compliance and Internal Audit.
Pre-clearance of Trade: Employees exposed to investment-related job functions are prohibited from trading securities in which funds managed by the company are currently transacting or during a period where these funds are buying or selling those securities.
Restricted Securities : Employees exposed to investment-related job functions are prohibited from transacted in these securities.
Securities on the Restricted List
Research Note : Employees exposed to investment-related job functions may trade in securities being analyzed by in-house research only after 3 days have passed after that research has been released.
Additional Guidelines Applicable to Portfolio Managers
Portfolio managers cannot transact trades for personal accounts during the period that is 7 days before and after trade dates (Blackout Period) in those securities by funds under the management of TMBAM.
2.
Other Rules and Regulations Covering Employees
Preserving the Confidentiality of Information
Employees must ensure information regarding investments, investment accounts, client details, are kept confidential and not revealed.
Reporting and Disclosures
Employees must refrain from providing information to outsiders on the companys behalf without receiving mandate by the company. Information disclosed must be based on factual information that is proper and justified.
Conflicts of Interests
Employees must be familiar with restrictions imposed by the company and avoid situations which may lead to a conflict of interest. Employees must follow company regulations and must report to the company any actions which may be construed as a conflict of interest.
Activities Undertaken by the Staff Outside the Company
The company does not encourage staff to engage in outside work additional to their regular job, including taking up positions in other companies such as serving as advisors. Staff planning to do so must obtain approval from the company.
Receiving of gifts or rebates
Company policy discourages receiving of gifts or rebates from business counterparts regardless of purpose. Employees are prohibited from receiving gifts whether in the form of cash, items, securities or any other benefits. This includes being entertained for meals by business counterparts. The aforementioned policy applies to offers exceeding 1,000 Baht in value. In unavoidable situations, the employee receiving the gift must file a report notifying the company; the gift will subsequently be distributed or turned into public poperty as the company deems appropriate.
Compliance and Internal Audit
The company requires its employees to strictly abide by rules and regulations. As such, the company has established a unit to supervise its operations referred to as the Compliance Unit. The Compliance Unit functions independently and reports directly to the Chairman of the Board of Directors. It is responsible to ensure that the company operates in compliance with the rules, regulations and ethical standards of the business as well as the companys own guidelines. In addition, this unit monitors and audits the operations of the various functions of the company to enhance efficiency and productivity.
If an employee is believed to have violated rules, regulations, or ethical standards, the company will set up a committee to consider reprisals against this employee. Members of this committee, which also includes the Compliance Unit, will conduct an investigation whereby the employee in question is also entitled to fully present facts and explanations in defence. Members of the committee will subsequently issue a judgement or verdict on the case, subject to the degree of violation and intentions behind it. Reprisals may take the form of warnings, suspension, freeze of salary, or termination.
