Compliance
Compliance Policy

Third Bridge Specialist Code of Conduct

Third Bridge has been a leader in independent investment research for over a decade — connecting analysts with experts to uncover human insights that guide decision making.  In the engagements that Third Bridge facilitates, our priority is to not only ensure interactions are appropriately matched but are also conducted with respect, integrity, professionalism, and in compliance with all applicable laws and regulations. For this reason, and the protection of all parties involved, Third Bridge asks all Specialists to comply with this Code of Conduct when engaging with Third Bridge, our Employees and Clients.

Third Bridge Specialist Code of Conduct 

The Code of Conduct sets out the key principles that Third Bridge expects from you as one of its Specialists. It runs in conjunction with our Compliance Programme which together ensure that our Specialists commit to: 

  • providing accurate and up to date information on their experience and relevance,
  • understand the nature of their ability and permissibility to work with Third Bridge and its Clients,
  • avoid sharing material non-public information or confidential information, and
  • act with respect and integrity with our Clients and Employees 

Compliance when engaging with Third Bridge and our Clients: 

  • You must have all necessary approvals to participate in an engagement. This means you need to check with any relevant parties (such as your current or former employer) if you are not sure whether or not you can participate.
  • You must not accept an engagement if it presents an actual or potential conflict of interest, or if it will breach a duty or contract that you have with a current or former employer, or any other third party. 
  • You must not disclose any confidential or proprietary information or any information which you are under a duty not to disclose.
  • You must not disclose the identity of Third Bridge’s Clients or share information about projects that they have been involved in with any third party or on any social media platforms or professional networking sites.
  • You must safeguard all information acquired as a result of your relationship with Third Bridge and not use it for any other personal or professional  reasons (such as trading) or to the benefit or detriment of Third Bridge, our Clients or any other third parties.
  • You are reminded to terminate an engagement early if you are uncomfortable or if you encounter any compliance issues during the engagement. Please remember that you must also bring this to the attention of Third Bridge immediately. 

Ensuring accuracy of information when engaging with Third Bridge and our Clients:

  • You must provide Third Bridge with accurate biographical information and keep Third Bridge informed of any changes especially at the time of accepting an engagement.
  • You must carefully assess your relevance to a project and only accept if you are sufficiently knowledgeable about the proposed subject matter to undertake the engagement diligently and professionally.
  • You must not misrepresent your experience or identity to Third Bridge or our Clients.

Maintaining professional standards when engaging with Third Bridge and our Clients:

  • You must engage with Third Bridge and our Clients in a professional manner – Third Bridge maintains a zero tolerance approach to behaviour or language that is deemed hostile, aggressive, abusive or that might constitute discrimination or harassment, or is otherwise inappropriate. 
  • Specialists must treat everyone equally and with respect regardless of race, ethnicity, natural origin, age, religion, sexual orientation, gender or disability.
  • You should exhibit professional and personal integrity and honesty at all times.
  • You must comply with all applicable laws (including data protection laws) and not encourage, assist or collude in any unlawful conduct. If you become aware of such conduct, please bring it to the attention of Third Bridge immediately. 
  • You must only share your own ideas and insights with Third Bridge and our Clients and must not infringe on the rights of any third party. 
  • You should be aware of your existing obligations, and exercise caution when considering engagements that may present a conflict of interest.

For the avoidance of doubt, and in the event of any discrepancy between the Specialist Code of Conduct and the Specialist Terms and Conditions, the Specialist Terms and Conditions shall prevail. 

Specialists should be aware that Third Bridge is under no obligation to provide them with any engagement opportunities and in the event that Third Bridge determines, in its sole discretion, that a Specialist has not adhered with the Specialist Code of Conduct or Specialist Terms and Conditions, Third Bridge may terminate or suspend its relationship with the Specialist without notice or explanation. 

Chinese citizens working as Specialists with Third Bridge and our Clients:
If you are a citizen of or reside in the People’s Republic of China, and either have or had access to:

  • information relating to China’s national security and interests, or
  • non-public statistical or other important data as it may relate to the Chinese economy or market,

you must be aware of your duties and obligations under relevant laws and must not discuss or disclose such information.
 

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