Eden Asset Management
Code Of Conduct

We expect all members of Eden to read, understand and abide by this code of conduct.

Eden expects all members (employees, board members, contractors and investment committee members) to act honourably, abide by the law and treat all related individuals with courtesy and respect.

We embrace individual identity and expression, with all members having the right to have their opinion heard and considered. We endeavour to only employ people who embrace and value the spirit of the company, who share the drive to grow the company, while always acting with integrity and professionalism.

We expect all members of Eden to read, understand and abide by this code of conduct. Failure to do so can result in disciplinary action, including termination of employment. Any waivers of this code for employees and/or directors must be approved by our board.

I. Avoiding Conflicts of Interest

Eden operates in an environment where numerous conflicts of interest may arise. All members of Eden have a responsibility to report all conflicts of interest to the board of directors and should endeavour to mitigate potential conflicts of interest. For the sake of clarity, a conflict of interest is any action or situation that could create an incentive for an individual to act in a manner not in alignment with the company.  This extends to a benefit created for themselves, a friend, family member or any other associated individual, company or entity.

Eden reserves the right to immediately terminate employment of individuals and pursue them for loss of revenue resulting from conflicts of interest.

The company maintains a zero-tolerance policy regarding ‘background dealing’.  This refers to undisclosed compensation to individuals for the provision of services or assets with any relation to Eden. This includes but is not limited to the receiving of intangible benefits such as favours, or tangible benefits such as cash, shares, rights and options.

II. Financial Management and Integrity

It is the responsibility of all members of Eden to maintain financial integrity. This means ensuring that financial records are complete and accurate, internal controls are honoured and all funds are appropriately spent.

If any member of Eden observes or suspects that there may be inconsistencies in the financial management and integrity of the company and accounts this should be reported immediately to the board of directors.

III. Obey the Law

All members of Eden, regardless of role are a representation of the company. Therefore, it is an expectation and requirement that all individuals abide-by and adhere to all laws and related regulations such as: anti-bribery, anti-corruption and insider trading regulations.

If at any point, you are unsure about the legality of your actions, ensure that you contact the board of directors or appropriate legal counsel before proceeding.

IV. To Conclude

We rely upon each and every individual for the efficient operation and management of the company. Eden prides itself on the flexibility and freedom of scope given to employees, where all members are given respect and responsibility for their individual actions and performance. This relies upon every member to demonstrate good judgement and a commitment to maintaining a high level of integrity and moral standards.

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