Ethics Leading Principle

Market Participants are expected to behave in an ethical and professional manner to uphold the fairness and integrity of the Precious Metals market.

The ethical and professional behaviour of Market Participants underpins the fairness and integrity of the market. The exercise of judgement is central to acting ethically and professionally and Market Participants (meaning both firms and their staff) should be guided in doing so by the high-level principles below when applying the specific guidance in the Code and at all times when participating in the market.

2.1 Ethics Principle 1 – Market Participants should strive for the highest ethical standards

2.1.1

Market Participants should:

  • Act honestly in dealings with Clients and other Market Participants;
  • Act fairly by dealing with Clients and other Market Participants in a consistent and appropriately transparent manner; and
  • Act with integrity by adopting best practice and responsible business practices.

2.1.2

Maintaining high standards of behaviour is the responsibility of:

  • Firms, which should promote ethical values and behaviour within their organisation, support efforts to promote high ethical standards in the Precious Metals market and encourage involvement by staff in such efforts;
  • Management, who should be proactive in embedding and supporting the practice of ethical values within the firm’s culture and be prepared to give appropriate advice to staff; and
  • Staff, who should apply judgement when facing ethical questions, expect to be held responsible for unethical behaviour and seek advice where appropriate. Staff should report and/or escalate issues of concern to the appropriate parties internally or externally, having regard to the circumstances.

Ethics Principle 2 – Market Participants should strive for the highest professional standards

2.2.1

All Market Participants share a common interest in maintaining the highest degree of professionalism and the highest standards of business conduct in the market. Firms should have staff who are appropriately trained and who have the necessary experience to discharge their employment duties in a professional manner.

2.2.2

High standards of conduct are underpinned by:

  • Having sufficient knowledge of, and complying with, Applicable Laws and relevant industry standards;
  • Having sufficient relevant experience, technical knowledge and qualifications;
  • Acting with competence and skill;
  • Applying professional judgement in following the firm’s guidelines and operating procedures, including but not limited to methods of execution, record-keeping and ethical behaviour; and
  • Engaging in efforts to strive for the highest standards of professionalism.

2.3 Ethics Principle 3 – Market Participants should identify and address conflicts of interest

2.3.1

Market Participants should have controls in place designed to identify relevant actual and potential conflicts of interest that may compromise or be perceived to compromise the ethical or professional judgement of Market Participants.

2.3.2

Market Participants should endeavour to effectively manage conflicts of interest so as to promote fair treatment of their Clients and other Market Participants, up to and including abstaining from undertaking the relevant activity or action due to the conflict of interests.

2.3.3

Staff should be aware of the potential for conflicts of interest to arise and comply with their firm’s policies in these areas.

2.3.4

Contexts in which conflicts may arise include but are not limited to:

  • Situations where staff or firm interests may conflict with those of a Client or other Market Participant, or where such a conflict arises for the Market Participant because the interests of one Client may conflict with those of another;
  • Personal relationships;
  • Gifts and corporate entertainment; and
  • Personal Dealing.

2.3.5

Where it is concluded that a specific conflict of interest cannot reasonably be prevented or effectively managed (including by ceasing to undertake the relevant service or activity), Market Participants should disclose sufficient details of the conflicts to enable the affected parties to decide beforehand whether or not they wish to proceed with the transaction or service.