Page 61 - Phil Reddin Financial Services Ltd DRAFT V1

SECTION 7: CODE OF CONDUCT

Phil Reddin Financial Services Ltd. obeys the law and works within all applicable regulations. We are
committed to conducting our business honestly and fairly. But we do much more than that. We act
ethically and set out to create a respectful responsible culture that is underpinned by our Company
Standards.

We strive to meet the highest standards in all our dealings with customers and colleagues, and to be
open, professional and accountable always.

We are operating in a period of unprecedented change for financial services and at a time when our
business environment is becoming more highly regulated. In such circumstances, it is crucial that we
are all clear about the standards we must apply to our conduct and behaviour.

This Code of Conduct, underpinned by more detailed policies and procedures, is our guide in this
regard. It's designed to shape how we interact with each other and with customers every day, and to
establish the standards we should apply in all our decisions and actions. It is vital that we all familiarise
ourselves with its requirements, both in terms of what we should always do and what we should never
do.

In addition, managers have a responsibility to lead by example, setting standards for their teams and
acting as custodians of our reputation.
It is the responsibility of each individual staff member to adhere to the spirit and the letter of this
Code. Failure to follow the Code, or to apply the terms of the associated policies, guidelines or
procedures, will be taken seriously and may lead to disciplinary action, up to and including dismissal.

This Code is a summary of the key standards for expected behaviour and conduct that apply to all
Company staff. It is not a comprehensive rulebook and simply provides examples of situations which
may arise. We are expected to exercise sound judgement, act honestly, fairly and with integrity in all
our actions.

7.1 OUR BUSINESS
Phil Reddin Financial Services Limited is a commercial organisation with responsibilities to
shareholders and other stakeholders. Our criteria for making business decisions are primarily
determined by economic risk and reward. Our decisions must also have a clear focus on the long-term
future and prosperity of our business, our customers, our environment and our society as a whole.

In managing our business, we maintain the highest standards of integrity and compliance with all laws,
regulations and codes of the jurisdictions in which we operate. We operate to stringent corporate
governance and risk management principles, and each business area has established procedures for
management, reporting and escalation which must be used appropriately.

We believe in open and fair competition. We do not engage in any form of bribery or collusive
anticompetitive discussions or agreements. We do not abuse our position in any of our markets to
gain unfair or unethical advantage.
We maintain high standards of physical security and information security to protect our customers,
our staff and our shareholders, together with their data and records.

We don't support businesses where we have reason to believe the customer is acting illegally.

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