Table of Contents

  1. Purpose. 3
  2. Scope. 3

III.       Definitions 3

  1. Statements 4

4.1 Prohibitions 4

4.2 Rules of Conduct 5

  1. Getting help. 7

I.              Purpose

Gatsby & White Agency S.A. (herewith after denominated “GWA” or as the “Company”) has been incorporated on 9 August 2018 as an insurance agency in Luxembourg.

This Code of Ethics and of Business Conduct (hereafter as the “Code”) is established by the Group of Gatsby & White with the purpose to establish the principles and the rules of professional conduct and of integrity, in order to avoid any illegal and immoral action within the Company and between the Company and its clients, business partners, suppliers and contractors.

The Company encourages a professional environment where all employees are well aware and follow the laws and regulations in power and the internal policies and procedures, where there is open communication between all staff members and all the employees work together in the best interest of the Company and of its clients.

II.            Scope

This Code shall be approved by the Board of Directors and apply to all employees (permanent, temporary or on contract) of the Company without exemptions.

It applies in all jurisdictions in which the Company operates regardless of local laws or culture.

III.          Definitions

The following definitions are used in this Code:

AML” refers to anti-money laundering.
Board” refers to the Board of Directors of the Company.
Business relationship”: means a professional or commercial business relationship which is connected to the business activities of GW and which is expected to have an element of duration.
CAA” is the Insurances Supervisory Authority in Luxembourg or Commission Commissariat Aux Assurances referring to
“Code of Ethical Conduct” is a “Statement of principles and values that establishes a set of expectations and standards for how an organisation, government body, company, affiliated group or individual will behave, including minimal levels of compliance and disciplinary action for the organisation, its staff and volunteers”.[1]
CTF” refers to Counter Terrorism Financing.
GW” is intended as the Group of Gatsby & White including therefore the following companies: Gatsby & White S.A., Gatsby & White (Liechtenstein) AG and Gatsby & White Belgium S.A.
GWA” refers to Gatsby and White Agency S.A.
Management Committee” of “Management” refers to the persons in charge with the daily management of the Company.
Media” or “Social media” refers to all type of available massive communications means such as radio, television, newspapers, any Internet media and social networks;
Staff” or “Employees” refers to and the employees of the Company and it includes the members of the management and of the Board;

IV.          Statements

4.1 Prohibitions

The Company has laid down rules which cover all the internal activities that are carried out. In particular all businesses and all staff (permanent, temporary or on contract) shall consider the following prohibitions during the performance of their tasks:

  1. It is not allowed to offer or make any bribe, unorthodox or unauthorised payment or inducement of any kind to anyone;
  2. It is not allowed to solicit business by offering any bribe, unorthodox or unofficial personal payment to customers or potential customers;
  3. It is not allowed to accept any kind of bribe, unorthodox or unusual payment or inducement that would not be authorised by the Company in the ordinary course of business. All the employees must not behave in a manner that can lead to misunderstanding or false expectation. All employees must report any such offers to heads of their departments or to the members of the Management and to the Chief Legal and Compliance Officer
  4. The Company and its staff will not make direct or indirect contributions to political parties, organisations or individuals engaged in politics, as a way of obtaining advantage in business transactions. The Company will publicly disclose all its political contributions if any;
  5. The Company will not channel improper payments through agents or other intermediaries;
  6. The Company avoids dealing with contractors and suppliers known or reasonably suspected to be paying bribes. The Company undertakes due diligence, as appropriate, in evaluating prospective contractors and suppliers to ensure that they have effective anti-bribery policies.
  7. The Company prohibits any type of discrimination for any reason at the work place. The Company does not allow employees to make any statements at the work place that may encourage discrimination, hate, disrespect and unlawful behaviours;
  8. The Company prohibits any type of harassment at the work place;
  9. The Company prohibits any type of false or untrue statements or publications in media or social media about the Company, its employees, its clients and its business collaborators.

4.2 Rules of Conduct

In order to fully comply with the internal rules of conduct employees shall take in account the below:

  1. All employees must report any breaches of this Code, of any Internal Policy and Procedure and of any law and regulation in power even if, by doing so, the employees have to disclose own wrongdoing. Such reports must be notified to the Management, to the Compliance Officer and when necessary to the Board of Directors.
  2. The Managers and heads of departments must maintain a working environment where staff can make reports of breaches of this Code in confidence and without fear of reprisals;
  3. The Company must ensure that, except for knowingly reporting false accusations, every employee may report allegations without fear of retaliation;
  4. The Company’s business partners, suppliers and contractors must act with integrity and without thought or actions involving bribery and corruption and, where appropriate, clauses to this effect must be added in contracts offered to any such third parties;
  5. The Company must actively investigate all reported allegations of fraud, corruption or abuse of position for personal gain involving the Company and its staff, wherever they might occur;
  6. The Company must ensure that charitable contributions and sponsorships are not used as a subterfuge for bribery. The Company will publicly disclose all its charitable contributions and sponsorships, if any;
  7. All the employees without exception, including members from the Board of Directors, must comply with this Code of Ethics and of Business Conduct. The Company will apply appropriate internal measures in case of violations of this Code;
  8. The Company must conduct due diligence before entering into a joint venture or consortium. For the avoidance of doubt, this includes also intra-company outsourcing;
  9. The Company must perform properly documented due diligence before appointing agents and other intermediaries;
  10. The Company’s Management must review and approve all agreements with agents and intermediaries before entering into such agreements;
  11. The Company must ensure that compensation paid to agents and other intermediaries are appropriate and justifiable remuneration for legitimate services rendered;
  12. The Company must ensure that agents and other intermediaries contractually agree to respect the local laws and regulations in power;
  13. The Company must contractually require its agents and other intermediaries to keep proper books and records available for inspection by the Company, auditors or investigating authorities;
  14. The Company must monitor the conduct of its agents and other intermediaries, having a right of termination in the event that they pay bribes or act in a manner inconsistent with this Code;
  15. The Company must conduct its procurement practices in a fair and transparent manner, with regards to contractors and suppliers;
  16. The Company must monitor significant contractors and suppliers as part of its regular review of relationships with them, having a right of termination in the event that they pay bribes or act in a manner inconsistent with this policy;
  17. The Company must ensure that no employee will suffer demotion, penalty, or other adverse consequences for refusing to pay bribes, even if such refusal may result in the Company losing business;
  18. The Company establishes and maintains an effective system of internal controls to counter bribery, comprising financial and organisational checks and to balance over the Company’s accounting and record keeping practices and other business processes related to this Code;
  19. The Company must establish feedback mechanisms and other internal processes supporting the continuous improvement of this Code. The Management of the Company monitors the Code and periodically reviews its suitability, adequacy and effectiveness, and implements improvements as appropriate;
  20. The Company must fully comply with all the local laws and regulations in power that are applicable to the Company’s activities;
  21. The Company and all the staff at all times during its activities and operations must respect the local AML and CTF legislation in power (refer to AML / CTF Manual of the Group);
  22. The Company and all the staff must respect the principles of confidentiality, clean desk and the protection of personal data;
  23. When not authorized, the employees must refrain themselves from making statements or publications in media or social media on behalf of the Company or about the Company. All information that is published in social media from the Company must be reviewed and approved by the Management. The employees may share what the Company publishes officially.
  24. The Company means and resources must be purely and strictly used only in relationship to professional and business-related matters.
  25. The employees must dress appropriately in the work place and during meetings with clients, business partners and third parties.

V.            Getting help

Help and assistance with interpretations, problem resolution and special situations can be obtained from the following staff:

  • The Chief Legal and Compliance Officer;
  • Management of the Company.

[1] Source: Transparency International 2009