Roxbury EQT Research and its Board of Directors are dedicated to the fair and ethical treatment of its employees, consultants and the communities that surround them. For more information on our policies, please see the codes and ethic documentation listed below.
This is the Corporate Code of Conduct (“Code”) for Roxbury EQT Research (“Roxbury”). It is designed to maintain confidence in the integrity of Roxbury and the responsibilities and accountability of individuals for reporting and investigating reports of unethical practices.
This Code expresses certain basic principles that Roxbury, its employees and external consultants should follow in all dealings related to Roxbury. They should be loyal to Roxbury, should show the highest business integrity in their dealings with others, including preserving the confidentiality of other peoples information and should conduct Roxbury’s business in accordance with law and principles of good business practice.
The Code reflects Roxbury’s recognition that Roxbury’s reputation is an essential element of Roxbury’s success. Each employee and consultant employed by Roxbury must act in a way that preserves and enhances Roxbury’s reputation.
Employees will often encounter issues in their work for Roxbury requiring judgment based on the principles expressed in this Code. While it is impossible to discuss every conceivable situation that might arise, Roxbury believes that the examples contained in this Code illustrate rules that should usually be followed to ensure that the actions of employees and consultants are not and will not be challenged for being unethical. The material in this Code is meant to be illustrative only and is not intended to limit the principles themselves.
Although Roxbury expects all employees to be familiar with the principles stated in this Code, Roxbury does not expect each employee and consultant to be fully versed in the law affecting his or her responsibilities. Whenever questions of any nature whatsoever arise in relation to the Code, each employee should seek guidance from general counsel or management who will in turn obtain advice on the interpretation of applicable laws and regulations from Roxbury’s solicitors.
The Code sets out the standards that Roxbury will adhere to whilst conducting its business and includes:
We have strict policies and professional standards that apply to every member of the firm.
All employees are responsible for Roxbury achieving the highest levels of business conduct. Roxbury’s employees are accountable for acting in line with the policies and standards outlined in the Code.
All Roxbury’s business activities will be carried out so as to protect the health and safety of employees, contractors, customers and the community while paying proper regards to the protection of the environment. Roxbury will use its best to conduct its operations in a manner that is environmentally responsible and sustainable. Roxbury will always conduct its business with the protection of the environment as a primary goal.
The objectives of Roxbury EQT Research in protecting the environment are to:
All aspects of environmental performance must be reported through senior management to the Board.
Roxbury is committed to the health and safety of all employees.
We strives to have injury-free workplaces.
The primary goal is to assist in providing a safe and healthy work environment for Roxbury’s employees, contractors and visitors. The objectives of Roxbury in ensuring health and safety are to:
All managers, supervisors and contractors are accountable for health and safety performance in their areas. All employees are required to follow rules for safe and healthy operations, report hazards to their supervisors and must always report any injuries that occur to either themselves or others.
Confidentiality is a key characteristic of an efficient and successful business. Employees are required to protect proprietary, commercial and other information that is confidential to Roxbury. These obligations of confidentiality continue after an individual's employment has ceased with Roxbury.
Information that is not generally available concerning the activities, results, strategies or plans of Roxbury must be used for authorized purposes only. This includes not giving confidential information to other business units in Roxbury or using the information provided for a different purpose without first obtaining permission. Confidential information should be handled and communicated with care, and must not be disclosed outside Roxbury without proper authority.
Any contracts that are entered into by Roxbury with customers, consultants and contractors should contain appropriate confidentiality clauses that ensure the protection of Roxbury’s confidential information.
Managers and supervisors are responsible for ensuring that arrangements are in place for protecting sensitive and confidential information.
The company secretary (with assistance from Roxbury’s solicitors where required) will conduct an annual review of the Code to ensure that the Code continues to reflect the letter and spirit of all applicable laws and regulations and Roxbury’s commitment to its staff and the community.
Directors and employees of Roxbury are encouraged to report any difficulties or challenges encountered by them in complying with the Code (including any inconsistencies between the Code and the business initiatives of Roxbury) to Roxbury. This will assist in the evaluation of the effectiveness of the Code and will highlight any areas of the Code that may require amendment or additional guidance.