Code of Ethics and Business Conduct

Performing with the highest ethical standards of business conduct is a key competitive strength


D3A Investments’ Code of Ethics and Business Conduct is a set of essential rules that we have formulated to govern company-wide relationships, the relationships between the company and its partner & employees, and the relationships of all partners & employees and the company with customers, suppliers, and other stakeholders.

We act with integrity, competence, diligence, respect and in an ethical manner with the public, clients, prospective clients, employers, partners & employees and colleagues in the investment profession.

We keep partners & employees informed on corporate governance principles, ensure that these principles are understood and accepted throughout the company, and are watchful of full compliance with them.

In D3A Investments we care how results are obtained, not just that they are obtained.


Compliance with laws

D3A Investments’ partners & employees comply unconditionally with all governmental laws, rules and regulations applicable to our business as well as rules and ethical principles that govern us. We cooperate with our regulators, being open and transparent in our dealings with them. Even where the law is permissive, D3A Investments chooses the course of highest integrity. We are well aware that local customs, traditions and mores differ from place to place, and that these differences must be recognized and respected.


Cross-border business

When we are working across borders, we obey all pertinent laws, rules and regulations – both at home and abroad. If we are selling to, buying from, investing in, visiting or dealing with clients in other jurisdictions, it is our job to understand what rules, laws or policies apply – and follow them.


Money Laundering and Sanctions

We have a duty to contribute to the integrity of the financial system, as well as our own business. We do not tolerate money laundering, corruption and terrorist financing. We comply with all global sanctions. We report suspicious activity in accordance with applicable law and this code and provide training to our staff on their obligations.

We do not tolerate bribery, corruption or facilitation payments;

  • Corruption is defined as the abuse of entrusted power for private gain.
  • Bribery is defined as the offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal, unethical or a breach of trust. Inducements can take the form of gifts, loans, fees, rewards or other advantages (taxes, services, donations, favours etc.).
  • Facilitation payments is defined as small bribes paid to public officials to speed up bureaucratic processes and access services the payer is lawfully entitled to.


Client relationships

We look after our clients for the long term, winning their loyalty by earning their trust. We try to anticipate what our clients are going to need before they ask. We go out of our way to give them an exceptional service. We make sure our products and services are adequate for our clients and are sold in a way that is not detrimental to their interests. We treat clients fairly, and with the same courtesy and respect, however large or small they may be.

Our clients trust us to keep the information they have shared with us safe and secure and only use it in the ways we’ve agreed with them. Consequently, we never share our clients’ details with anyone, unless we have their express permission to do so – or where we have a legal duty to share it with the relevant authorities. And even within D3A Investments, we will only share client details with those colleagues who genuinely need to see it to serve our clients’ best interests.


Fair competition

We believe in fair competition and comply with antitrust, unfair competition and/or anti-monopoly laws (or any other laws having an analogous meaning) and are mindful of the rules of fair competition in our dealings with competitors.

Antitrust laws are intended to preserve competition by prohibiting actions that could unreasonably restrain the functioning of a free and competitive marketplace, and they prohibit, among other things, price fixing, creation of a monopoly, boycotts, tying arrangements, exclusive dealing and refusals to deal. All partners and employees are expected to comply with applicable antitrust laws and do not participate in any activity that could be considered a violation.


Protecting our assets

We keep D3A Investments’ assets safe and secure – from sensitive, confidential information about our business, plans and people to our intellectual property, as well as documents, information and other materials belonging to others that are entrusted or made available to us. That means making sure that these assets are handled properly and used in line with relevant laws and regulations and doing all what we can to prevent them from being lost, stolen, damaged or misused.


Performance and professionalism

Our professionalism, integrity and pursuit of excellence are how we create value for our clients and shareholders. In line with this our compensation system is designed to reward long-term value creation by balancing performance and prudent risk-taking with a focus on conduct and sound risk management practices. We know that our business is only as strong as our people. So, we work hard to create a working environment where talent can thrive and reach its full potential.


Conflicts of interest

We are committed to honesty, transparency and to avoid conflicts of interests. We put our clients’ best interests before our own – and our company’s interests before our personal interests. We never let D3A Investments’, or our personal interests influence our advice to a client, or our dealings with them.

Each partner & employee is expected to avoid any outside activity, financial interest or relationship that may present a possible conflict of interest or appearance of a conflict.

Conflicts of interest also arise when a partner or employee, or a member of his or her family, receives improper personal benefits as result of his or her position in our company.

As a fiduciary, we have an affirmative duty of care, loyalty, honesty to our clients and a duty of utmost good faith to act in the best interests of our clients. Compliance with this fiduciary responsibility can be accomplished by avoiding conflicts of interest and by fully, adequately, and fairly disclosing all material facts concerning any conflict which arises with respect to any client.


Confidential information and personal data

We treat confidential information with due care and in accordance with external and internal regulations. We acknowledge the importance of data ethics and respect every individual’s fundamental right to protect personal data.

D3A Investments maintains, and possesses information that it views as proprietary, and it must be held strictly confidential by all partners & employees. This information includes, but is not limited to:

  • the financial condition and business activity of D3A Investments or any enterprise with which our company is conducting business
  • investment management agreements and partnership agreements
  • client specific information
  • holdings in client accounts
  • research analyses and trading strategies
  • internal communications
  • legal advice, and
  • computer access codes.

In order to safeguard D3A Investments’ proprietary information, as partners & employees we are expected to abide by the following:

  • We don’t share proprietary information with anyone at D3A Investments except on a needs-to-know basis
  • We don’t disclose proprietary information to anyone outside of the company, except in connection with D3A Investments’ business and in a manner consistent with the client’s interests
  • We exercise caution in displaying documents or discussing information in public places, or in the presence of outside vendors or others not employed by D3A Investments
  • We exercise caution when using e-mail, cellular telephones or messenger services
  • We don’t leave documents containing proprietary information in conference rooms, wastebaskets, or desks, or anywhere else where the information could be seen or retrieved.


Human Rights

We support and respect internationally proclaimed human rights. We do not tolerate child labour, forced labour, discrimination, harassment or abuse. We are committed to fair compensation and good working conditions including freedom of association. Health and safety, including both mental and physical health, of partners and employees is central.


Diversity and equal opportunity

We believe that people from different backgrounds, with different thoughts and opinions, make us a stronger business. They bring us valuable new ideas, approaches and experiences. Regardless of their status, everyone has the same chance, whatever their ethnicity, gender, national origin, age, ability, sexual orientation or religion. And we work to create a culture where everyone feels they are welcome, respected and that they are a valuable part of our team. We do not tolerate any kind of discrimination, bullying or harassment. And we encourage each other to speak up and report any misconduct through clear channels, without fear of reprisals.


Environmental impact

We actively strive to reduce our environmental impact and carbon footprint. We focus on sustainable development that meets the needs of the present without compromising the ability of future generations to meet their own needs.

The purpose of investing is to apply capital to productive use, addressing opportunities and challenges facing societies and economies, thereby building value over time for the investors supplying that capital. But that value-building economic activity does not take place within a hermetically sealed financial system. Value creation takes place in and depends on environmental, social, and governance systems. It requires the assets and resources those systems provide. Economic activity that is not sustainable degrades those systems, diminishing their future viability and value. Sustainable economic activity maintains or enhances those systems, increasing their future viability and value. The future value of the investment depends heavily on the future state of those systems.

In line with this, we are constantly looking for better ways to do business in an environmentally sound and socially responsible manner. That includes monitoring, managing and reducing any negative impact we might have on the environment. It means managing environmental risks that our own and our clients’ assets are exposed to. And it means looking for sustainable investment opportunities, for ourselves and our clients.



We ensure that all of D3A Investments’ reports, financial statements, and bookkeeping entries comply with national and international accounting principles. When we share financial information to our regulators, we take great care to make sure it is accurate, up to date and as easy to understand as it can be (and in line with any legal or regulatory requirements and best practice) and free from material misstatement.


Tax matters

We follow all the laws, rules, regulations and treaties around tax that apply to us, all over the world – not just to the letter, but in their true spirit. We pay and report all taxes due. We report information relating to our own tax position and that of our clients and employees as required. We will not help our clients or any other party avoid paying the tax that they owe or reporting their income and gains, nor will we support any transactions where we know or shall presume that the tax outcome is dependent on unrealistic assumptions or the hiding of facts. We will also not contract with third parties that provide services for or on our behalf, where those acts help others to evade taxes owed.



A clearly understood code, which we all believe in and which underpins our work, is a vital part of the D3A formula. In evaluating projects and supporting clients and our own people in taking the business forward, we combine adherence to the above principles with a desire to succeed. This means doing the right thing at all times. Commercial and societal benefit merge with no friction between the two. We stand or fall by making things happen with energy, conviction, integrity and total transparency. This forms our blueprint for success as D3A evolves and makes its mark.