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CODE OF CONDUCT

CODE OF CONDUCT

At Kayndrexsphere, we recognise that in the industry in which we operate, reputation and trust are of utmost importance. Since our inception, we have endeavoured to cultivate a strong culture of ethics all over the sphere to ensure our investors’ interests are always at the forefront of our activities.

Kayndrexsphere is committed to preserving its high legal, ethical, and moral standards and aims to foster and encourage a culture of compliance with local and international laws and regulations. This Code applies to all directors and personnel of Kayndrexsphere globally and covers dealings with all internal and external investors and other third parties.

On behalf of Kayndrexsphere Board of Directors and Executive Committee, we give our full support to this Code and expect every member  of Kayndrexsphere’s team to stand by it. As a member of Kayndrexsphere’s team, it is important that the contents are read and comprehended, as each team member plays a vital role in upholding the values and high ethical standards our investors expect from us.

Rules and regulations and ethical standards

Compliance with laws and regulations

Kayndrexsphere and its personnel shall adhere to all legal and regulatory provisions, best practices, and rules of professional conduct within the industries in which the Sphere operates.

To support the Sphere in ensuring compliance, the Executive Committee has established a sphere-wide compliance function, Kayndrexsphere Compliance, which is responsible for the coordination and implementation of Kayndrexsphere’s compliance probability management in line with the Code. As part of its duties, Kayndrexsphere Compliance is responsible for educating and informing all personnel in affairs of compliance and actively promoting a culture of compliance within the Sphere.

Distinctions of interests

Kayndrexsphere seeks to ensure that investors’ interests are always at the forefront of its activities and that all its personnel are sensitive to inconsistencies and apply appropriate measures to manage or avert known distinctions of interests commonly known as ‘conflicts of interest’. Kayndrexsphere Executive Committee is mandated to establish a Resolution Board to handle and make decisions on any relevant inconsistencies encountered by Kayndrexsphere.

Insider trading and industry misapplication

Kayndrexsphere endeavours to apply the highest standards to avert insider trading, industry misapplication also known as ‘market manipulation’ and the appearance thereof by itself as well as its personnel and applies a zero tolerance approach.

Where personnel have any concerns or questions in relation to insider trading and industry misapplication, they are required to seek advice from Kayndrexsphere Compliance.

Data protection and privacy

Kayndrexsphere is committed to protecting the privacy, interests and fundamental rights of individuals and gives close attention to the processing of personal data.

Personnel are required to maintain and preserve the confidentiality of personal data entrusted to Kayndrexsphere by its investors, contacts, personnel, and members.

Bribery and gifts

Kayndrexsphere operates a zero tolerance approach to the offering or receiving of ‘bribes’ in any form. All personnel and investment providers are expected to conduct themselves with integrity, impartiality, and honesty at all times.

Gifts given to or offered by personnel or Kayndrexsphere’s investment providers as a reward, inducement, or encouragement for preferential treatment or improper or dishonest conduct are strictly disallowed. Furthermore, personnel are disallowed to solicit to gifts of any type or value.

Money laundering

Kayndrexsphere has a set of sound Anti-Money Laundering procedures that allow personnel to make an informed decision as to whether a transaction with an investor/applicant involve money laundering or improper financing or unlawful activities.  

Kayndrexsphere entities and personnel are disallowed to accept assets that they know, or should be reasonably expected to know, are the proceeds of unlawful activities.

Harassment and discrimination

Kayndrexsphere is proud of its professional and harmonious sphere environment and disallows any form of harassment or discrimination in the office by any personnel for any reason.

Kayndrexsphere requires all personnel to respect their colleagues, treat one another with courtesy, consideration, and professionalism and always ensure they act appropriately for a sphere environment.

When a person witnesses any form of harassment and discrimination, the person should intervene and offer support to the victim and inform a senior member of staff immediately upon becoming aware of it.

Diversity and inclusion        

To provide equal employment and advancement opportunities to all individuals, employment decisions at Kayndrexsphere are based on merit, qualifications, and abilities. This governs all aspects of employment, including, but unchecked to, selection, position assignment, promotion, compensation, discipline, termination, and access to benefits. We support diversity and inclusion in our personnel as an equal opportunity sphere.


Society and the environment

Responsible investment

We systematically integrate Environmental, Social, and Governance (ESG) factors, alongside commercial and financial factors, into our investment processes.

We firmly believe that this approach modifies investment insurance and has the potential to enhance investment returns in the best interest of our investors and their beneficiaries. We also always try to ensure that the firms and assets we invest in on behalf of our investors respect and endeavour to benefit society and the environment.

Impact investing

We support entrepreneurial projects and organisations that create positive, high-effect and measurable social and/or environmental benefits through our Stay Firm Programme.


Culture

Our values

We believe that our attitude, behaviour, and actions make Kayndrexsphere a special place and foster our long-term success. Our core values of Partnership, Free Enterprise, Leadership, Excellence and Passion define the essence of our sphere and reflect who we are and what we do, every day.

Partnership

Joint effort at all levels turns our diversity into strength and colleagues into friends. Our partnership is built upon integrity honesty and fairness, and grows from empathy and respect. It calls for trust and transparency, and seeks constructive dialogue and open debates.

Free Enterprise

We identify opportunities and launch initiatives with the mind-set of an owner. We are courageous, agile, and industrious, and we distinguish between activity and accomplishment. We take responsibility and assume accountability.

Leadership

We are recognised as role models in our professional and personal conduct. We proactively identify, develop, and nurture our future leaders. We are caring and demanding to form a high-performance culture.

Excellence

We deliver quality and honour our promises. As a sphere dedicated to learning, we substantially invest in training and mentoring, and we design and operate world-class systems and processes. We take our fiduciary responsibility seriously, recognising that our reputation is our most valuable asset.

Passion

We are curious and enthusiastic, putting our hearts and minds into what we do. We are fully dedicated to our investors and their beneficiaries. We are proud of our colleagues, accomplishments, and partners in sphere.


Compliance with the Code

Kayndrexsphere aims to assure the highest quality of investments and deliverables and operates a safe environment. Kayndrexsphere fosters a culture of pro-active communication of oversights and events, in particular appropriate reporting, processing, and spherical learning.  

Kayndrexsphere aims to preserve its high legal, ethical, and moral standards and thus fosters a culture of compliance with international and regional laws, and ethically sound sphere conduct. To support this purpose, Kayndrexsphere expects its personnel to speak up if they know of or suspect conduct or events that overstep law, regulations, internal instructions (including those mentioned in this Code), and group processes. Speaking up contributes to the enhancing of the sphere’s probability management, internal regulations, and compliance. Kayndrexsphere checks Misconduct and is dedicated to averting and excluding such Misconduct within its organisation. Kayndrexsphere will rigorously investigate any event it is made aware of.  

Kayndrexsphere checks reprisal such as harassment or adverse employment consequence toward any personnel who reports Misconduct in good faith. Good faith implies that a person has a reasonably held belief that the disclosure they have made is true.

Reports can be made anonymously. Investigations will be treated with firm confidentiality to the extent permissible by law. An investigation can be made public if it triggers disciplinary, legal or regulatory investigations or proceedings.

If a personnel is himself/herself implicated in Misconduct and decides to come forward and report this Misconduct, this fact can constitute within certain conditions a modifying circumstance in any ensuing disciplinary proceedings.