Code of Conduct

1.1 The Code applies to all employees and officers of Pareto Securities AS, whether permanent or temporarily employeed, including all of our branches and subsidiaries in Norway and abroad (“Pareto Securities”).

1.2 The Code has been adopted by the Board of Directors. The Board of Directors shall review the Code and assess the need for any revisions at least every third year. 

1.3 The Code is based on relevant legal requirements and internationally agreed upon standards. These primarily encompass the ten principles of the United Nation’s Global Compact which are derived from international agreements. These include the UN’s Universal Declaration of Human Rights, the Conventions of the International Labour Organizations, the UN Convention against Corruption, and the Rio Declaration on Environment and Development.

1.4 The securities legislation and other relevant legislation in the countries in which we operate define a minimum standard for the conduct of Pareto Securities personnel. Such legislation has been made operational through internal regulations and procedures for Pareto Securities and supplementary guidelines. However, it does not always suffice to comply with the letter of the law and our internal regulations and procedures. Pareto Securities shall contribute to upholding market integrity by refining good business practice standards. This requires each employee to take an active approach to ethical dilemmas in his or her work situation.

1.5 The Code cannot exhaustively regulate the ethical dilemmas one is faced with in the work situation. Our business is in continual change and we are exposed to many ethical challenges, small and large. We shall loyally adhere to the intention behind the principles in the Code whenever these do not directly prescribe how one is expected to conduct oneself. This requires levelheadedness and sound judgement. A key test is whether the action would withstand public scrutiny. If you are worried that colleagues, clients, the press, government authorities or other stakeholders may discover what you are up to, there is every reason to believe that what you are contemplating is not in conformity with these principles. All activities at Pareto Securities shall stand up to critical internal and/or external examination.

1.6 If you are in doubt as to what is the appropriate conduct, you shall discuss the matter with colleagues, your supervisors or Compliance.

2.1 We shall comply with laws, regulations, and agreements. These comprise both external and internal regulations, such as policies, standards, instructions, processes, routines/procedures and agreements. Any errors and nonconformance identified shall be managed in accordance with our routines for reporting of incidents and nonconformances.

2.2 As an employee, you are responsible for reading all training material and monitoring updates within your discipline. All employees are expected to comply with the information and training provided, and to talk with a superior if in doubt. All employees are expected to speak out if they become aware of any breaches of laws and regulations.

2.3 We do not commit or induce anyone to commit illegal activities, for example financial misreporting and misconduct or economic and financial crime.

2.4 We are alert to illegal activities by knowing our clients.

2.5 We take reasonable actions to verify compliance before we make decisions. In any doubts we seek guidance and advice prior to making the decisions.

3.1 We shall offer our clients sound financial solutions and investment opportunities. The interests of the client shall be placed before our own interests in all contexts, and the clients shall never have cause to doubt that such is the case.   

3.2 There may be conflicting interests between our clients; between those who want to sell at a high price and those who want to buy at a low price, etc. The role of the intermediary is to find the market equilibrium, which will be achieved if we facilitate informed decisions by the parties.

4.1 In all our work activities, we shall seek the truth and never attempt to modify, distort or hide relevant facts or the truth. There is no room for lies at Pareto Securities.

4.2 Information provided to clients shall be correct, clear and not misleading, thus enabling them to make informed decisions.

4.3 Information to governmental authorities or others should, to the best of our knowledge, be accurate, thus ensuring that these parties have an appropriate understanding of our activities.

4.4 The principles extend to conduct on social media platforms, including but not limited to LinkedIn, X (Twitter), Facebook, and Instragram. These principles should be kept in mind when engaging in chats, blogs and other social media platforms. This is particularly important when sharing information or participating in discussions on social media within our professional fields. We should refrain from posting work-related opinions on our personal social media channels, as it may blur the line between our private personas and our roles as representatives of Pareto Securities. However, sharing unaltered information from Pareto Securities' official social media accounts is acceptable.

5.1 Pareto Securities shall act independently of other companies and our clients.  

5.2 We shall actively avoid situations in which our independence may be questioned.

6.1 We strive to avoid conflicts of interest as they can compromise our decision-making ability. If conflicts of interest arise nonetheless, we will be transparent about them and resolve them appropriately. Please refer to our Conflicts of Interest Policy for further guidance.

6.2 A conflict of interest might arise when the interests of Pareto Securities do not align with personal interests. Such conflicts can occur between the requirements and expectations of authorities, the needs and interests of clients, and the commercial objectives and expectations of Pareto Securities’ owners.

6.3 As an employee, you should exercise extra caution in situations where your personal interests, or those of your family and friends, may conflict with the interests of Pareto Securities or its clients. This includes being particularly cautious and observant when engaging in private transactions involving assets such as property and financial instruments.

7.1 Humility, respect and politeness shall characterise all of our relations.

7.2 We play fair with competitors. Clients and assignments shall be won by offering superior products, not by talking down competitors or using inappropriate business methods.

7.3 Communications channels made available by Pareto Securities, such as landline telephones, mobile telephones, Bloomberg and e-mail, shall never be used to pass on messages with pornographic or racist content, or content that is unlawful or offensive.

7.4 We may be identified with Pareto Securities outside the work situation as well, and we shall act accordingly. Unacceptable conduct outside working hours, such as the use of illicit drugs, illegal gambling or the procurement of sexual services, represent a violation of this Code.

7.5 We shall keep our private finances in order and settle our debts in a timely manner. Unpaid bills may cloud one’s judgement and give rise to undesirable conduct. All personnel are encouraged to contact their immediate supervisor in the event of payment problems. 

8.1 We shall continuously work to secure safe and inclusive workplace by promoting health and wellbeing.

8.2 We take precautions to prevent workplace accidents or injuries, by understanding the risks in our daily work environment.

8.3 We all contribute to a positive and stimulating work environment. Bullying, harassment or discrimination of colleagues or others is never acceptable.

8.4 We promote and value diversity and inclusion. We employ, assess, promote and compensate based on competencies and performance, not on bias or personal preference. Please refer to our Diversity and Inclusion Policy for further guidance.

8.5 We are committed to providing continuous learning and development to our employees. This enhances their relevant skills, abilities, and knowledge, thereby ensuring they maintain their job qualifications and contribute to the performance of the business.

9.1 We respect fundamental and internationally recognised human rights in our operations. We bear the responsibility to ensure that our business activities do not adversely affect these human rights. Please refer to our Human Rights Policy for further guidance.

9.2 We take action to minimise the risk that we are complicit in human right abuses.

9.3 We pay our employees a fair living wage and respect the upper limits on regular and overtime hours allowed by the law of the country in which they are employed.

9.4 We ensure that our employees have written contracts in place.

9.5 We respect and recognise the right to freedom of association, as well as applicable collective bargaining agreements. We ensure that employees have the liberty to resign as per established regulations.

9.6 We are committed to the effective abolition of child labour. We do not accept forced labour, slave labour or other non-voluntary labour in our value chain.

10.1 We have zero tolerance for bribery and corruption. Please refer to our Anti-corruption Policy for further guidance.

10.2 We shall never accept gifts or other benefits that are intended – or may be perceived to be intended – to influence the performance of our work.

10.3 We shall never exploit our affiliation with Pareto Securities to obtain undue personal advantages, such as entry to private events, reservations at private restaurants, or for personal profit. The use of one’s Pareto title externally should only occur when it is pertinent to one’s professional duties.

10.4 We shall not give any gifts, grant any benefits, or provide any services of such nature or scope that these may give rise to inappropriate dependence between Pareto Securities and its client.

10.5 We shall not make facilitation payments and shall in no way be involved in corruption.

11.1 Employees get access to confidential information on a regular basis. Our position of trust in relation to clients and government bodies depends on such information never being misused and never being disclosed to unauthorised parties.

11.2 Confidential information shall only be used for the purpose for which it is gathered. A need-to-know principle applies internally within Pareto Securities.

11.3 We shall work actively to prevent confidential information from being disclosed to unauthorised parties.

11.4 No client information searches in internal registers or databases shall be made for any other purpose than the performance of work duties.

11.5 Confidential client information may, depending on the circumstances, represent inside information within the meaning of the securities trading legislation. Such information is subject to particularly strict disclosure restrictions. We shall actively assess whether any information represents inside information and take any appropriate measures to prevent the disclosure and/or misuse thereof.

12.1 We are committed to safeguarding the privacy of our clients, employees, and business partners. We shall fairly, lawfully, and transparently collect and process the personal data of our clients and employees, for legitimate purposes only.

12.2 We shall respect the right of individuals to control the personal data they share with us, including the purposes for which is it used, as far as is feasible within the legal obligations imposed on us. We shall ensure that personal dato is disclosed to those who are authorised to receive it, both within Pareto Securities and externally, such as with our third-party collaborators.

12.3 We are committed to implementing security measures to safeguard against the loss, misuse, and alteration of the personal information under our control.

13.1 We shall protect Pareto Securities from being used to move the proceeds of crime, for example money laundering, funding of terrorist acts and violating sanctions.

13.2 We manage financial crime risks in our daily activities across Pareto Securities in line with our risk appetite and compliance culture.

13.3 We know our customers and other parties, enabling us to manage the financial crime risk in our personal and digital relationships.

14.1 We acknowledge that we have a shared responsibility in combating climate change by supporting the transition to a climate-resilient global economy. Please refer to our Sustainability Policy for further guidance.

14.2 We shall integrate environmental issues into our business strategy by focusing on the areas we can impact, including assessments of climate-related risks.

14.3 We are committed to support and encourage the use and development of environmentally friendly technologies, products, and services, aiming to contribute to sustainable development.

14.4 We shall strive to minimize the environmental footprint of our own business operations and in our value chain. Please refer to our Code of Conduct for Business Partners and Suppliers for further guidance.

15.1 We give notice of inappropriate conduct at Pareto Securities, in accordance with designated whistleblowing procedures and regulations. Our whistleblowing function is intented to encourage our employees to confidentially and anonymously report, without fear of retaliation, any inappropriate conduct and is handled by an independent law firm with a duty of confidentiality.

15.2 Pareto Securities is required to report suspicious transactions to the authorities. Employees shall report potentially suspicious transactions internally.

15.3 Notification shall have no negative consequences for whistleblowers. Failure to give notice may, on the other hand, have consequences, cf. Principle 17.

16.1 Each employee has independent responsibility for adherence to the principles set out in the Code.

16.2 Heads of department shall be responsible for compliance with these principles in their department, and shall embody such principles in their own conduct.

16.3 Adherence to the principles set out in the Code shall be promoted by Compliance through training and other awareness enhancement measures.

17.1 Violation of the ethical principles set out in the Code may have consequences for the employee in question. Relevant consequences may be written warnings, reduced variable remuneration, reassignment to a different position, termination of employment, referral to the Disciplinary Committee of the Norwegian Securities Dealers Association (or corresponding bodies in other jurisdictions) and/or  reporting to the police.

17.2 Each employee is required to stay updated, on an ongoing basis, on the development of external rules and regulations within his or her area of work, as well as any amendments to internal regulations and procedures, in order to ensure compliance with relevant internal and external rules.