codeofconduct

Applying Personal and Business Integrity

A. Fraud, bribery and corruption
B. Conflicts of interest
C. Personal Investment
D. Insider trading and market abuse
E. Handling of gifts and improper payments
F. Offering gifts and entertainment
G. Political activity

4A. Fraud, bribery and corruption
We are committed to maintaining the highest standards of ethics and integrity in the way we do business. Any act of fraud, bribery or corruption is not tolerated by GS Group, nor is any help given to people carrying out such acts.
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4B. Conflicts of interest
A “conflict of interest” arises when you use your position to make a personal gain or benefit over and above what is defined in your employment agreement. We must ensure that our personal interests do not conflict with the interests of the business or our customers.

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4C. Personal investment
Ensure that your investments or personal business do not create conflicts of interest or impair your ability to make objective decisions on behalf of GS Group. Conflicts can occur if personal investments are made in GS Group competitors’, suppliers’ or customers’ businesses. Publicly traded mutual funds, index funds and similar pooling of securities, when the individual investor has no say in which investments are included, do not present conflicts.

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4D. Insider trading and market abuse
We have a legal duty to never use company information that has not been made public for our own benefit, or for the benefit of others we know – for example, by selling or buying shares on the basis of price-sensitive information. Using information for our own benefit or for others is called insider trading and in almost all cases is a serious criminal offense. Other abuses of information such as disclosing sensitive material other than in the proper course of your employment (known as “market abuse”) may also result in serious criminal and/or civil penalties.

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4E. Handling of gifts and improper payments
Business gifts and entertainment from business partners build goodwill, but they should never influence – or appear to influence – our business decisions in any way. As such, we will never seek or exert improper influence in exchange for promises or gifts, regardless of the local business practice.

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4F. Offering gifts and entertainment
It is common in the commercial world to offer social amenities and business courtesies such as modest gifts, meals and entertainment to enhance business relationships. However, every courtesy offered should always comply with the policies of the recipient’s organization.

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?4G. Political activity
We have no political affiliations and make no political donations – we work with governments and parties around the world only on issues vital to the interests of GS Group. All employees have the right to be politically active as long as they keep their work separate and remain professional around customers, colleagues, etc.

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