How to report concerns, complaints and potential illegal or unethical conduct

Reef Origin is committed to conducting its business activities in the highest ethical and professional manner and to achieving compliance with applicable laws, rules, regulations, accounting standards and controls and audit practices. As part of this commitment, Reef Origin has a Code of Conduct Origin Handbook (copy available on request), which sets out basic principles of conduct applicable to all employees, and numerous other policies and procedures designed to help us meet our legal, regulatory and ethical obligations.

The Origin Handbook requires that you report any concerns you may have about potential illegal or unethical conduct which can be reported to a Reef Origin Partner or the Board of Director's.

Reports, which may be made anonymously, are treated confidentially to the extent reasonably possible. Reports made in good faith may be made without fear of dismissal or retaliation of any kind. You may also report potential violations of law or regulation directly to a regulator or government authority.

EMAIL: info@reeforigin.com 
(FAO: Board of Directors)

You may also send correspondence to our:

Board of Directors c/o Reef Origin

13/14 Welbeck Street

London, W1G 9XU

1. Introduction

This global Code of Business Conduct and Ethics (“Origin Handbook”) governs the general commitment by Reef Origin and its subsidiaries (collectively, “Reef Origin”) to conduct its business activities in the highest ethical and professional manner and to put client interests first. Reef Origin’s reputation for integrity is one of its most important assets and is instrumental to its business success. While this Code covers a wide range of business activities, practices, and procedures, it does not cover every issue that may arise in the course of Reef Origin’s many business activities. Rather, it sets out basic principles designed to guide Reef Origin employees and directors. Consultants and contingent, contract, or temporary workers are expected to comply with the principles of this Code and policies applicable to their location, function, and status.

Upon becoming a Reef Origin employee, and on an annual basis thereafter, Reef Origin employees are required to acknowledge their receipt of this Origin Handbook and any subsequent amendments. Reef Origin employees are provided with the Origin Handbook on induction.  Every Reef Origin employee and director — whatever his or her position — is responsible for upholding high ethical and professional standards and must seek to avoid even the appearance of improper behaviour. Any violation of this Code may result in disciplinary action to the extent permitted by applicable law.

2. Compliance with Laws and Regulations

Reef Origin’s global business activities are subject to extensive governmental regulation and oversight, and it is critical that Reef Origin and its employees comply with applicable laws, rules, and regulations, including those relating to insider trading. Employees are expected to refer to the guidance contained in the Compliance Manual and the various policies and procedures contained in the Policy Library in compliance with these laws and regulations and to seek advice from the Board as necessary.

3. Conflicts of Interest

Conflicts of interest may arise when a person’s private interest interferes, or appears to interfere, with the interests of Reef Origin, or where the interests of an employee or the firm are inconsistent with those of a client or potential client, resulting in the risk of damage to the interests of Reef Origin or one or more of its clients. A conflict may arise, for example, if an employee takes an action or has an interest that could appear to make it difficult for the employee to conduct the employee’s responsibilities to Reef Origin and/or the client objectively and effectively, or if such employee or any person associated with the employee, including but not limited to members of the employee’s family or household, receives an improper personal benefit, such as money or a loan, as a result of the individual’s position at Reef Origin. Reef Origin has adopted policies, procedures, and controls designed to manage conflicts of interest, which employees are required to comply with and other compliance-related policies, procedures, and controls and to help mitigate potential conflicts of interest by adhering to the following standard of conduct:

· Act solely in the best interests of clients;

· Uphold Reef Origin’s high ethical and professional standards;

· Identify, report, and manage actual, apparent, or potential conflicts of interest; and

· Make full and fair disclosure of any conflicts of interest, as may be required.

4. Insider Trading and Personal Trading

Employees and directors who have access to confidential information about Reef Origin, or its clients, are prohibited from using or sharing that information except in the proper conduct of our business. All non-public information about Reef Origin or any of our clients or issuers should be considered "confidential information." Use of material, non-public information in connection with any investment decision or recommendation or to “tip” others who might make an investment decision on the basis of this information is unethical and illegal and could result in civil and/or criminal penalties.

5. Gifts and Entertainment

Employees must act in the best interests of our clients and consider the reputation of Reef Origin when receiving or providing any gift or entertainment. Employees are prohibited from offering, promising, giving or receiving, or authorising others to offer, promise, give or receive anything of value, either directly or indirectly, to any party in order to improperly obtain or retain business, or to otherwise gain an improper business advantage.

In addition, strict laws (including criminal laws) govern the provision of gifts and entertainment, including meals, transportation, and lodging, to public officials. Employees are prohibited from providing gifts or anything of value to public officials or their employees or family members in connection with Reef Origin’s business for the purpose of obtaining or retaining business or a business advantage.

6. Corporate Opportunities

Employees and directors:

· are prohibited from taking personal opportunities for themselves that are discovered through the use of corporate property, information, or position without the consent of the Director’s;

· are prohibited from using corporate property, information, or position for improper personal gain;

· may not compete with Reef Origin either directly or indirectly; and

· owe a duty to

8. Competition and Fair Dealing

Reef Origin seeks to outperform its competition fairly and honestly by seeking competitive advantage through superior performance; Reef Origin does not engage in illegal or unethical business practices. Reef Origin and its employees and directors should endeavour to respect the rights of, and deal fairly with, Reef Origin’s clients, vendors, and competitors. Specifically, the following conduct is prohibited:

· misappropriating proprietary information;

· possessing trade secret information obtained without the owner’s consent;

· inducing disclosure of proprietary information or trade secret information by past or present employees of other companies; and

· taking unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other intentional unfair-dealing practice.

9. Confidentiality

Reef Origin’s employees and directors have an obligation of confidentiality to Reef Origin and its clients. Confidential information includes non-public information that might be of use to competitors or that might harm Reef Origin or its clients, if disclosed, and non-public information that clients and other parties have entrusted to Reef Origin. The obligation to preserve confidential information continues even after employment ends. This obligation does not limit employees from reporting possible violations of law or regulation to a regulator or from making disclosures under whistleblower provisions.

10. Reporting Any Illegal or Unethical Behaviour

Every employee is required to report any illegal or unethical conduct about which they become aware, including those concerning accounting or auditing matters. Employees may report concerns to a Reef Origin Partner or the Board of Director’s where there will be no retaliation or discrimination against any employee because of a good faith report. Employees have the right to report directly to a regulator and may do so anonymously; employees may provide protected disclosures under whistleblower laws and cooperate voluntarily with regulators, in each case without fear of retaliation by Reef Origin.

11. Protection and Proper Use of Reef Origin Assets

Employees and directors should make every effort to protect Reef Origin’s assets and use them efficiently. This obligation extends to Reef Origin’s proprietary information, including intellectual property such as trade secrets, patents, trademarks, and copyrights, as well as business, marketing and service plans, engineering and manufacturing ideas, systems, software programs, designs, databases, records, salary information, and any unpublished financial data and reports. Unauthorised use or distribution of proprietary information constitutes a violation of Reef Origin policy and could result in civil and/or criminal penalties.

12. Bribery and Corruption

Reef Origin employees and directors are prohibited from making payments or offering or giving anything of value, directly or indirectly, to public officials of any country, or to persons in the private sector, if the intent is to influence such persons to perform (or reward them for performing) a relevant function or activity improperly or to obtain or retain business or an advantage in the course of business conduct.

13. Equal Employment Opportunity and Harassment

The diversity of Reef Origin’s employees is a tremendous asset. Reef Origin is firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment of any kind. In particular, it is Reef Origin’s policy to afford equal opportunity to all qualified applicants and existing employees without regard to race, ethnicity, religion, colour, national origin, sex, pregnancy status, pregnancy-related medical conditions, gender, gender identity or expression, sexual orientation, age, ancestry, physical or mental disability, familial or marital status, political affiliation, citizenship status, genetic information, or protected veteran or military status or any other basis that would be in violation of any applicable ordinance or law. In addition, Reef Origin will not tolerate harassment, bias, or other inappropriate conduct on the basis of any of the above protected categories.

14. Protection and Proper Use of Reef Origin Assets

Reef Origin requires honest and accurate recording and reporting of information in order to conduct its business and to make responsible business decisions. Reef Origin’s books, records, accounts, and financial statements must be maintained in reasonable detail, must appropriately reflect Reef Origin’s transactions, and must conform both to applicable legal requirements and internal controls.