At Fullerton, we embrace a set of core values that drives our every endeavour: excellence, courage, openness, integrity, accountability and collaboration. These values serve as the bedrock of our vibrant culture, molding our behaviour and underpinning our decision-making process. We believe in cultivating meaningful relationships to provide exceptional experiences, fostering trust through stewardship and investment excellence, and creating value through innovative and sustainable solutions.
As an investment partner and guardian of client assets, trust is our most invaluable asset. We recognise that upholding the utmost standards of business ethics and professional conduct is essential for earning and nurturing the trust of our stakeholders.
Fullerton's Code of Professional Conduct and Ethics ("Code") that follows serves as a compass, delineating the ethical standards we demand from our personnel. It provides clear guidance regarding our responsibilities, highlights the significance of individual accountability, and emphasises our obligation to voice any concerns we may have.
Compliance with laws and regulations
Fullerton is committed to comply with both the letter and spirit of the laws and regulations in all jurisdictions in which it operates.
Honest and Fair Dealing, acting with due care and diligence
Fullerton is committed to ensure that the business is aligned with the core values of ensuring integrity and supports the delivery of fair dealing outcomes to clients. We expect our people to deal fairly, honestly and objectively with all clients when providing investment analysis, making investment recommendations, taking investment action and/or engaging in other professional activities.
Loyalty to Fullerton
All Fullerton employees have an obligation to act for the benefit of Fullerton and not deprive Fullerton of the advantage of their skills and abilities, divulge confidential information, or otherwise cause harm to Fullerton.
Confidential information includes all non-public information that might be of use to competitors or harmful to the Company or its customers, vendors, or business partners if disclosed. Our people have an obligation to handle confidential information of Fullerton and our clients with integrity and discretion in compliance with applicable law and regulations.
Managing conflict of interest
Conflicts of interest may arise between:
a. the interests of clients;
b. the interests of clients and interests of Fullerton; or
c. the interests of clients and the interests of individual employee.
As a fiduciary manager, Fullerton will not favour the interests of one client over that of another client and should not give or appear to give unfair preference to its own interests over the interests of its clients. Likewise, our people shall not take any action(s) or have any interest(s) that would make it difficult for them to conduct their responsibilities to Fullerton and/or the client objectively and effectively. We have in place proper escalation processes to ensure that our people shall bring forthwith to the attention of Compliance any actual or potential conflict of interest as soon as possible upon awareness.
Fullerton is committed to ensuring honest and accurate recording and reporting of information is important for Fullerton to conduct its business with integrity and professionalism and make responsible business decisions.
Professional business conduct and trading activities
In Fullerton, guiding fiduciary principles that govern our overall business and professional conduct of our people include but are not limited to the following:
a. Personal investment activities of our people must be conducted in compliance with all applicable laws, regulations and Fullerton’s internal policy and procedures.
b. Ensure that our client’s interest receive priority over the interest of Fullerton and our people.
c. Proprietary information of Fullerton and our clients acquired by our people through their position/ roles within Fullerton should not be misused to advantage personal investments/ benefits.
Anti-bribery and corruption
It is our policy to conduct business with integrity and without the use of corrupt practices or acts of bribery to obtain an unfair advantage. We expect our people and our business partners to share our zero-tolerance stance against corruption and bribery. Fullerton will not engage in business dealings with those known or reasonably suspected to be engaging in corruption and bribery.
Proper handling of gifts and entertainment
The exchange of gifts and offers of entertainment are common business practices, but it can be misinterpreted or suggest the appearance of something improper, even when there is no improper intent. We expect our people not to solicit or be unduly influenced by the receipt of gifts, entertainment or other benefits to avoid any potential conflict of interest situations. Likewise, our people shall also not attempt to influence counterparties seeking/ having a business relationship with Fullerton through the offer of gifts, entertainment or other benefits. As part of our commitment to being transparent, Fullerton has in place policies on gifts and entertainment to ensure that the giving and receiving of gifts and entertainment by our people do not, in actuality or appear to, exceed that legitimate purpose.
Continuous learning and development
We believe that continuous learning and development is integral for employees to acquire new skills and keep their knowledge and competencies current with developments relevant to their scope of work. We are committed to providing our people with training and opportunities for development so as to be able to evolve with the ever-changing industry landscape and enhance their professionalism and value contribution to Fullerton.
Proactive risk management
Proactive risk management is critical to protect Fullerton’s reputation and enable sustainable growth. We expect our people to be familiar and comply with Fullerton’s internal policies and procedures, including our risk management frameworks which sets out the key risk management principles used to shape decision making and actions relating to risk management in Fullerton.
Fullerton promotes open and honest communication and supports our people in providing feedback and raising concerns/issues discretely, in a safe environment. We have in place a whistleblowing channel that allows employees to raise concerns and report any suspicions over inappropriate, unethical and unlawful conduct and escalate these issues other than via their usual reporting lines. Our Whistleblowing Policy provides our people the assurance that whistleblowers will be protected from retaliatory action and discrimination and the information provided will be held in confidence.
Equal employment opportunity
Equal Employment Opportunity is a fundamental principle at Fullerton, where employment is based upon personal capabilities and qualifications. We prohibit discrimination against any employee or candidate for employment on the basis of race, color, religion, gender, age, marital status, citizen status, national origin, disability, sexual orientation or any other protected characteristic established by applicable law. This policy of equal employment opportunity applies to our policies and procedures relating to recruitment, hiring, compensation, benefits, termination, and all other terms and conditions of employment.
Individual accountability and responsibility
Everyone in Fullerton is required to comply with the Code, as well as the policies, procedures and regulations that apply to their particular jurisdictions and roles. Fullerton conducts an annual undertaking to ensure that our people understand and comply with the Code’s principles.