top of page

Code of business
and ethics

1. Introduction

1.1 Purpose

This Code of Business Conduct and Ethics provides guidelines for conducting the business of Sovereign USA Inc. ("Sovereign USA" or the "Company") with the highest standards of ethics. This Code applies to all employees, officers, directors, and contractors of Sovereign USA and its subsidiaries. Compliance with this Code is mandatory, and violations may result in disciplinary action.


1.2 Seeking Help and Information


This Code is not exhaustive. If you face a situation not covered here, seek guidance from your supervisor, the Compliance Department, or the Legal Department. Apply the following questions to your decisions:

  • Is it legal?

  • Is it honest and fair?

  • Is it in Sovereign USA’s best interest?

  • Would I feel comfortable if my actions were published?

1.3 Reporting Violations


Report any known or suspected violations of this Code, laws, or company policies to your supervisor or the Compliance Department. 

​

1.4 Disciplinary Consequences


Violations of this Code or company policies may result in disciplinary action, including termination of employment. Failure to report known violations can also lead to disciplinary measures.

 

1.5 Confidentiality and Non-Retaliation


Reports of violations will be handled with sensitivity and confidentiality. Sovereign USA prohibits retaliation against anyone who, in good faith, reports a violation or seeks guidance.

 

1.6 Waivers of the Code


Waivers of this Code may only be granted in exceptional circumstances by the Chief Compliance Officer and must be approved by the Board of Directors for directors and principal officers.


2. Conflicts of Interest


2.1 Identifying Conflicts of Interest


A conflict of interest arises when personal interests interfere with the interests of Sovereign USA. Avoid situations where your personal interests could influence your professional judgment. Examples include:

  • Outside employment with a competitor, customer, or supplier.

  • Receiving improper personal benefits from a supplier or customer.

  • Significant financial interests in competitors or business partners.

2.2 Disclosure of Conflicts


Disclose any potential conflicts of interest to the Legal Department or Chief Compliance Officer. Some conflicts may be permissible but require formal approval.


2.3 Family Members


The actions of family members can also create conflicts of interest. Disclose any family relationships that could lead to a conflict to your supervisor or the Compliance Department.


3. Corporate Opportunities


Employees must not exploit corporate opportunities for personal gain. Disclose any opportunities related to Sovereign USA's business to your supervisor before pursuing them.


4. Confidential Information


Protect all confidential information acquired during employment. This includes business plans, customer lists, and other sensitive information. Your obligation to safeguard confidential information continues even after your employment ends.


5. Competition and Fair Dealing


Compete fairly and honestly. Avoid taking unfair advantage of anyone through manipulation, concealment, abuse of privileged information, or any unfair-dealing practice.


6. Gifts and Entertainment


Do not offer or accept gifts or entertainment that could appear to influence business decisions. Gifts of nominal value and reasonable business entertainment may be acceptable but must comply with company policies.


7. Interactions with Government Officials


Conduct all interactions with government officials ethically and in compliance with applicable laws. Avoid offering anything of value to influence government decisions.


8. Protection and Use of Company Assets


Use company assets responsibly and for legitimate business purposes only. Report any misuse or theft of company property.


9. Company Records


Maintain accurate and reliable records. Ensure that all financial transactions are documented accurately and promptly.


10. Compliance with Laws


Adhere to all applicable laws and regulations in every aspect of business conduct.


11. Reporting and Enforcement


Report any concerns or violations to the Compliance Department or via the Ethics Helpline. Sovereign USA will investigate all reports and take appropriate action.


12. Amendments


Sovereign USA reserves the right to amend this Code at any time. Employees will be notified of any significant changes.

bottom of page