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Employee Code of Conduct & Ethics Policy

Last Updated: 01.01.2025

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GammaSigma Capital ("Company," "we," "us," or "our") is committed to maintaining a high standard of ethics, integrity, and professionalism in the workplace. This Employee Code of Conduct & Ethics Policy (the "Policy") provides guidelines for our employees and associates to ensure that they adhere to ethical practices, follow legal requirements, and maintain a professional and respectful environment.

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1. Introduction

At GammaSigma Capital, we expect all employees to uphold our values and principles, which include honesty, respect, responsibility, and accountability. The Company’s reputation for professionalism and trustworthiness is vital to our success, and each employee plays a key role in maintaining these standards.

2. Core Values

  • Integrity: We are honest, transparent, and ethical in all our dealings, both internally and externally. We do what is right, not what is easy.

  • Accountability: We take responsibility for our actions and decisions, and we hold ourselves accountable to our colleagues, clients, and stakeholders.

  • Respect: We foster a culture of respect, valuing diverse perspectives, opinions, and backgrounds.

  • Excellence: We strive for excellence in everything we do, continuously improving and innovating in our approach to our work.

3. Professional Conduct

Employees are expected to conduct themselves in a professional manner at all times. This includes, but is not limited to, the following:

  • Workplace Behavior: Treat others with respect, courtesy, and professionalism. Foster a collaborative and supportive work environment.

  • Teamwork: Work collaboratively and cooperatively with colleagues to achieve common goals.

  • Compliance with Laws: Follow all applicable local, state, and national laws and regulations in performing your duties.

  • Confidentiality: Protect the confidentiality of sensitive Company information, trade secrets, and personal data. Do not share, disclose, or misuse confidential information.

  • Conflict Resolution: Resolve conflicts with colleagues and clients in a constructive, respectful manner. Seek help from HR or management if needed.

4. Ethical Standards

Employees are expected to uphold the following ethical standards:

  • Honesty and Transparency: Always provide truthful and accurate information. Misleading or dishonest behavior is strictly prohibited.

  • Fair Treatment: Treat all individuals with fairness and respect. Avoid any form of discrimination, harassment, or bias.

  • Conflict of Interest: Avoid situations where personal interests conflict with the interests of the Company. Disclose any potential conflicts of interest to HR or management immediately.

  • Gifts and Entertainment: Do not accept gifts, favors, or entertainment from clients, vendors, or other business associates that may influence your business decisions. Any offers of gifts or entertainment must be reported to management.

  • Use of Company Resources: Use Company resources, including time, technology, and finances, responsibly and only for business purposes. Personal use of Company resources should be kept to a minimum and not interfere with job responsibilities.

5. Confidentiality and Privacy

Employees must maintain the confidentiality of all sensitive Company, client, and employee information, including:

  • Client Information: Do not disclose any confidential client data without proper authorization.

  • Employee Data: Respect the privacy of fellow employees and handle personal data with care, in accordance with relevant data protection laws.

  • Proprietary Information: Protect proprietary Company information, including intellectual property, trade secrets, business strategies, and financial data.

6. Compliance with Policies and Procedures

Employees are required to adhere to all internal policies, procedures, and guidelines. This includes:

  • Anti-Money Laundering (AML): Employees must comply with all AML regulations and report any suspicious activity promptly.

  • Know Your Customer (KYC): Employees should follow KYC procedures to ensure proper client identification and due diligence.

  • Security: Adhere to the Company’s security policies to safeguard both physical and digital assets, and report any security concerns immediately.

  • Reporting Violations: If you observe any violations of this Code or other Company policies, report them immediately to your manager, HR, or through the Company’s anonymous reporting system.

7. Workplace Behavior and Respect

  • Harassment-Free Environment: The Company is committed to maintaining a harassment-free workplace. Discrimination, harassment, or bullying based on race, gender, age, religion, disability, or any other protected characteristic is strictly prohibited.

  • Respect for Diversity: We value and respect the diversity of our employees, clients, and partners, and encourage an inclusive and welcoming workplace.

  • Substance Abuse: The use of illegal substances or being under the influence of alcohol or drugs while at work is prohibited. Employees should maintain a clear and focused mind to perform their duties.

8. Social Media and Public Communication

Employees should be aware that their online behavior reflects on the Company. Employees are expected to:

  • Exercise Caution: Be cautious when posting on social media or any public platform. Do not disclose confidential or proprietary information about the Company.

  • Respect Boundaries: Refrain from making negative or disparaging comments about the Company, colleagues, or clients on any platform.

  • Professional Representation: If representing the Company publicly, do so with professionalism and integrity, ensuring that your conduct aligns with Company values.

9. Compliance with Legal and Regulatory Requirements

Employees must comply with all applicable laws, regulations, and industry standards in the course of their work, including but not limited to:

  • Financial Regulations: Adhere to financial reporting and regulatory requirements, including the relevant trading laws in your jurisdiction.

  • Data Protection Laws: Ensure compliance with data protection regulations (e.g., GDPR) when handling personal data.

10. Disciplinary Actions

Failure to comply with this Code of Conduct and Ethics may result in disciplinary action, up to and including termination of employment. Disciplinary actions will be determined based on the severity of the violation and may involve warnings, suspension, or other corrective actions.

11. Reporting and Violations

If you become aware of any unethical or illegal conduct, you are encouraged to report it immediately. GammaSigma Capital has established procedures for reporting violations, and we offer protection from retaliation for employees who report in good faith.

12. Acknowledgment and Compliance

All employees are required to acknowledge and sign this Employee Code of Conduct & Ethics Policy upon hire and periodically throughout their employment. This acknowledgment confirms that you have read, understood, and agree to comply with the terms outlined in this policy.

13. Changes to the Code of Conduct

GammaSigma Capital reserves the right to update and modify this Code of Conduct at any time. Employees will be notified of any significant changes to this policy. It is the responsibility of each employee to review and adhere to the updated version of this policy.

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