Principles of Conduct

The financial services sector plays an important role in the lives of millions of people. It is essential that the industry is held in high regard and considered trustworthy by those that rely upon it. This is achieved by following certain ethical principles and promoting ethical behavior. In this spirit, Newedge has endorsed its Governing Principles of Conduct.

1. We will always act fairly and with integrity and honesty when representing Newedge, and we will comply with the letter and spirit of all applicable laws and rules.

2. We will put our clients’ legitimate interests first and provide our clients superior services.

3. We will act to maintain the good reputation of our shareholders.

4. We will seek to minimize conflicts and potential conflicts of interest. If conflicts do arise, we will manage them fairly and in the best legitimate interest of our clients.

5. We will respect the confidential nature of the information we handle, and never divulge or use confidential information for personal benefit (for example, we will not trade on so-called “insider information”) or for the unauthorized use by others.

6. We will help ensure our organization is not utilized to conduct illegal or illegitimate activities.

7. We will interact with our colleagues professionally and courteously at all times; never contribute to a hostile work environment; and never discriminate on the basis of race, color, gender, age, disability, ethnic or national origin, marital status, religion, sexual orientation, or any other status protected by applicable law.

8. We will interact with our regulators and law enforcement agencies professionally, and in an open and cooperative manner, and we will deal with our competitors respectfully.

9. We will help create an energizing and supportive environment at Newedge by working together as a team and always seeking to advance our good reputation and standing. Among other things, we will be positive contributors to our industry’s good reputation and to our local communities.

10. As consistent with Principles of Conduct 1-9, we will work together to achieve our business objectives.