CODE OF ETHICS

Agents of Metropol Corporation Limited (Including all its subsidiaries) must:

  1. Act with integrity, competence, diligence, respect, and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the risk management profession, and other participants in the markets that the company is involved with.
  2. Place the integrity of the company and the interests of clients above their own personal interests.
  3. Use reasonable care and exercise independent professional judgment when conducting any analysis, making recommendations, taking actions, and engaging in other professional activities.
  4. Practice and encourage others to practice in a professional and ethical manner that will reflect credit on themselves and the company.
  5. Promote the integrity of, and uphold the rules governing the industry, profession or market.
  6. Maintain and improve their professional competence and strive to maintain and improve the competence of other members of staff.

THE STANDARDS OF PROFESSIONAL CONDUCT

1. PROFESSIONALISM

1.1 Knowledge of the Law

Agents must understand and comply with all applicable laws, rules, and regulations of any government, regulatory organization, licensing agency, or professional association governing their professional activities. In the event of conflict, Agents must comply with the more strict law, rule, or regulation. Agents must not knowingly participate or assist in any violation of laws, rules, or regulations and must disassociate themselves from any such violation.

1.2 Independence and Objectivity

Agents must use reasonable care and judgment to achieve and maintain independence and objectivity in their professional activities. Agents must not offer, solicit, or accept any gift, benefit, compensation, or consideration that reasonably could be expected to compromise their own or another’s independence and objectivity.

1.3 Misrepresentation

Agents must not knowingly make any misrepresentations their performance or other professional activities.

1.4 Misconduct

Agents must not engage in any professional conduct involving dishonesty, fraud, or deceit or commit any act that reflects adversely on their professional reputation, integrity, or competence or that of the company.

2. DUTIES TO CLIENTS

2.1 Loyalty, Prudence and Care

Agents have a duty of loyalty to their clients and must act with reasonable care and exercise prudent judgment. Agents shall, to the best of their ability, carry out their duties and ensure that the services that they provide are provided efficiently and honestly.

2.2 Fair Dealing

Agents must deal fairly and objectively with all clients when conducting any analysis, making recommendations, taking actions, and engaging in other professional activities.

2.3 Performance Presentation

When communicating information to prospective, new or existing clients, Agents must make reasonable efforts to ensure that it is fair, accurate, and complete.

2.4 Preservation of Confidentiality

Agents must keep information about current, former, and prospective clients confidential unless:

  1. 2.4.1.1 The information concerns illegal activities on the part of the client or prospective client,
  2. 2.4.1.2 Disclosure is required by law, or
  3. 2.4.1.3 The client or prospective client permits disclosure of the information.
  4. 2.4.1.4 Information is already in the public domain

3. DUTIES TO THE EMPLOYER

3.1 Loyalty

In matters related to their agency, Agents must act for the benefit of their employer and not deprive their employer of the advantage of their skills and abilities, divulge confidential information, or otherwise cause harm to their employer.

3.2 Confidentiality

Agents shall exercise utmost discretion regarding all matters of official business. They shall not communicate to any unauthorized persons any information known to them by virtue of their official position and which has not been made public with the authority of the Chief Executive Officer, nor shall they at any time use such information to their private advantage. This obligation does not cease upon termination of the agency.

3.2 Additional Compensation Arrangements

Agents must not accept gifts, benefits, compensation, or consideration that competes with, or might reasonably be expected to create a conflict of interest with, the employer’s interest unless they obtain written consent from all parties involved.

3.3 Responsibilities of Supervisors

Supervisory Staff within the agency must make reasonable efforts to detect and prevent violations of applicable laws, rules, regulations, and the Code and Standards by anyone subject to their supervision or authority.

4. CONFLICTS OF INTEREST

4.1 Disclosure of Conflicts

Agents must make full and fair disclosure of all matters that could reasonably be expected to impair their independence and objectivity or interfere with respective duties to their clients, prospective clients, and employer. Agents must ensure that such disclosures are prominent, are delivered in plain language, and communicate the relevant information effectively.

4.2 Direct Competition

Agents must not engage in any activity, or support any activity whether full-time or part-time, or be a direct beneficiary in any business that competes directly with the business of the employer during the duration of the tenure of their agency. Where conflict of interest is likely to occur, Agents shall declare the interest to the company.

DISCIPLINARY ACTION

In the event that any Agent is found to be in breach of the Code and Standards as outlined above, disciplinary action will be taken against the culpable party. Disciplinary action includes but is not limited to; warning letters, suspension and termination.

In the event that the breach aggrieves or offends any external parties, the employer may take any other action in accordance with standard practice or applicable law, without prejudice to any of other rights and remedies of the offended party, which include any right to claim damages and indemnification.

Remedial action taken subsumes the laws of the Republic of Kenya and any breach or offense that violates such laws will also be subject to judicial processes and penalties under said laws.