Greenstone Asset Management Code of Conduct

1. Introduction

Greenstone Asset Management is committed to conducting its business in an ethical, responsible, and compliant manner. This Code of Conduct outlines our commitment to uphold the highest standards of integrity and professionalism in our operations.

2. Compliance with Laws and Regulations

Greenstone Asset Management shall comply with all relevant laws, regulations, and industry standards applicable to the asset management sector in Europe. This includes but is not limited to MiFID II, AIFMD, UCITS, and GDPR.

3. Client Interests

We shall always act in the best interests of our clients and diligently protect their assets.

4. Conflicts of Interest

We will identify and manage potential conflicts of interest that may arise in our business operations to ensure that client interests are not compromised.

5. Transparency

We are committed to providing clients with clear and accurate information regarding our services, fees, and potential risks.

6. Risk Management

Greenstone Asset Management will maintain robust risk management procedures and controls to protect clients’ assets.

7. Personal Conduct

Our employees shall maintain the highest standards of personal conduct and professionalism.

8. Confidentiality

We shall maintain the confidentiality of client information and other sensitive data in accordance with applicable data protection laws.

9. Insider Trading

We prohibit insider trading and will ensure our employees are aware of the regulations governing it.

10. Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF)

Greenstone Asset Management is committed to AML and CTF compliance and will implement appropriate procedures to detect and report suspicious activities.

11. Gifts and Entertainment

We will establish guidelines for gifts and entertainment to prevent any undue influence on our employees.

12. Social and Environmental Responsibility

Greenstone Asset Management is committed to considering environmental, social, and governance (ESG) factors in our investment decision-making processes.

13. Reporting Violations

We encourage employees and stakeholders to report any violations or concerns regarding this code of conduct to info@greenstoneam.com, through established channels, and we guarantee protection from retaliation for those who report in good faith.

14. Enforcement

Violations of this code of conduct may result in disciplinary actions, including termination of employment or legal action, as appropriate.

15. Review and Update

Greenstone Asset Management will regularly review and update this code of conduct to ensure its continued relevance and effectiveness.

16. Conclusion

This Code of Conduct represents our commitment to maintaining the highest standards of ethical and professional conduct. All employees and stakeholders of Greenstone Asset Management are expected to adhere to these principles and help create a culture of integrity within our organization.