True Global Ventures 4 Plus Pte. Ltd.
Our Code of Ethical Conduct - Doing what is right and ethical
At TGV, we embrace a set of core values that drives our every endeavour: honesty, integrity, and professionalism. These values serve as the fundamental principles of our culture, shaping our behaviour and fostering a culture of good conduct underpinned by strong standards of ethics.
As an investment partner and custodian of client assets, trust is our most invaluable asset. We recognise that mere compliance with regulatory requirements or internal rules is not enough to build and maintain a sound organisation culture. We believe in doing what is right and ethical and upholding high standards of business ethics and professional conduct so as to earn and nurture the trust of our stakeholders.
TGV's Code of Ethical Conduct that follows serves as a compass, describing the general principles that we expect all our employees to uphold.
Our Code of Ethical Conduct - Doing what is right and ethical
At TGV, we embrace a set of core values that drives our every endeavour: honesty, integrity, and professionalism. These values serve as the fundamental principles of our culture, shaping our behaviour and fostering a culture of good conduct underpinned by strong standards of ethics.
As an investment partner and custodian of client assets, trust is our most invaluable asset. We recognise that mere compliance with regulatory requirements or internal rules is not enough to build and maintain a sound organisation culture. We believe in doing what is right and ethical and upholding high standards of business ethics and professional conduct so as to earn and nurture the trust of our stakeholders.
TGV's Code of Ethical Conduct that follows serves as a compass, describing the general principles that we expect all our employees to uphold.
- Fair Dealing - Employees must deliver fair dealing outcomes to clients as this is an important organisation priority. This includes always prioritising the interests of the fund(s) and its investors over the interests of TGV and its employees.
- Personal or Client Account Dealing - All personal or client account transactions must adhere to TGV’s Insider Trading Policy that prohibits any insider trading and TGV’s Market Abuse Policy that prohibits any illegal market conduct or unacceptable business practices.
- Managing Conflict of Interests - Conflicts of interest may arise between:
- the interests of clients;
- the interests of clients and interests of TGV; or
- the interests of clients and the interests of individual employee.
As a fiduciary manager, TGV will not favour the interests of one client over that of another client and will not give or appear to give unfair preference to its own interests over the interests of its clients. Likewise, our employees shall not take any action(s) or have any interest(s) that would make it difficult for them to discharge their responsibilities to TGV and/or the client objectively and effectively. We have in place proper escalation processes to ensure that our employees shall bring forthwith to the attention of Compliance any actual or potential conflict of interest as soon as possible upon awareness.
- Professional business conduct - Employees must not take any inappropriate advantage of their positions at TGV to gain any personal benefit for themselves or their connected persons.
- Confidentiality - Information concerning the price and size of securities in the investment portfolio of the fund(s) managed by TGV and the identities or personal data of investors in the fund(s) must be kept confidential.
- Portfolio management - Independence must always be maintained in the investment or divestment decision-making process of the fund(s).
- 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 employees and our business partners to share our zero-tolerance stance against corruption and bribery. TGV will not engage in business dealings with those known or reasonably suspected to be engaging in corruption and bribery.
- Whistleblowing - TGV promotes open and honest communication and supports our employees and our business partners in providing feedback and raising concerns/issues discretely, in a safe environment. We have in place a whistleblowing channel that allows employees and our business partners 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 employees the assurance that whistleblowers will be protected from retaliatory action and discrimination and the information provided will be held in confidence.