Our Corporate Mission
- Be the partner of choice for international investors in Central Asia.
- Exploring exceptional investment opportunities for international strategic investors.
- Provide access to international markets for solid companies in the region.
- Contribute to the development of financial markets in Central Asia.
- Provide an excellent environment to attract and retain the brightest professionals to the Ansher team.
Code of Conduct and Ethics
1. General Philosophy
This Code of Conduct ("Code") has been adopted by Ansher group of companies ("the Company") to provide ethical standards and policies by which employees of the Company will conduct themselves in order to promote integrity and sound business practices. These standards are linked closely to our corporate vision, strategies and values and are intended to provide guidance to persons functioning in managerial or administrative capacities, as well as to all employees.
The integrity, reputation and profitability of the Company ultimately depend upon the individual actions of our employees, directors and agents. It is the policy of the Company and its subsidiaries to comply with all applicable laws and to adhere to ethical standards in the conduct of our business. Each employee is expected to read and understand this Code of Conduct, uphold these standards in daily activities and take personal responsibility for compliance with all applicable policies and procedures.
2. Compliance with Laws, Rules and Regulations
All Company employees must comply with all applicable laws, regulations, rules and regulatory orders applicable in the country, state and local jurisdictions where business is conducted, including securities laws, antitrust laws and other fair competition laws. Each officer, director and employee is expected to acquire appropriate knowledge of the requirements relating to his or her duties sufficient to enable him or her to recognize potential issues or violations. Violations of laws, regulations, rules and orders may subject the employee to individual criminal or civil liability, as well as to disciplinary action by the Company. Because such individual violations may also subject the Company to civil or criminal liability or the loss of business, the Company takes legal compliance measures seriously and works diligently to enforce them.
3. Conflicts of Interest
A "conflict of interest" occurs when your private interest in any way interferes with the interests of the Company. You are expected to avoid all situations that might lead to a real or apparent material conflict between your self-interest and your duties and responsibilities as an associate, officer or director of the Company. Any position or interest, financial or otherwise, that could materially conflict with your performance as employee of the Company, or that affects or could reasonably be expected to affect your independence or judgment concerning transactions between the Company, its clients or competitors or otherwise reflects negatively on the Company would be considered a conflict of interest. When unsure whether your situation presents a conflict of interest, you should consult with your manager or a member of senior management.
Each employee is responsible for recognizing situations in which a conflict of interest or the appearance of a conflict of interest is present or might arise and for taking appropriate action to eliminate or prevent such conflict or appearance of a conflict, including reporting the situation to the appropriate level of management. Where an employee believes it is not possible to avoid any of these situations, or to avoid any other potential conflict of interest, the employee must inform his or her supervisor and make full written disclosure (in advance whenever possible) to the Company's Board of Directors.
4. Confidentiality
Nonpublic information regarding the Company or its business, associates, customers and suppliers is confidential. As an associate, officer or director, an employee is trusted with confidential information. An employee is only to use such confidential information for the intended business purpose of the Company. No one is not to share confidential information with anyone outside of the Company, including family and friends, or with other associates of the Company who do not need the information to carry out their duties. Employees may be required to sign a specific confidentiality agreement in the course of your employment at the Company. Whether a specific confidentiality agreement is required, an employee’s obligation to keep all information confidential continues even if such employment with the Company ends.
5. Insider Trading
It is both unethical and illegal to buy, sell, trade or otherwise participate in transactions involving the securities of any client or partner company while in possession of similar non-public material information concerning such companythat has not been released to the general public, but which when released may have an impact on the company's activity. Any questions concerning the propriety of effecting a transaction in the client's securities should be directed to the Company's Board of Directors or Company counsel.
6. Outside Business Relationships
Before agreeing to act as a director or employee for any other business organization, one should notify your manager or supervisor who will review outside employment requests for potential conflicts of interest.
7. Protection and Proper Use of Company Property
All employees and directors should protect the Company's property and assets and ensure their proper use. Theft, carelessness and waste can directly impact the Company's profitability, reputation and success. Permitting the Company's property (including data transmitted or stored electronically and computer resources) to be damaged, lost, or used in an unauthorized manner is strictly prohibited.
8. Reporting of Illegal or Unethical Behavior
The Company recognizes that its employees must have faith and confidence in the honesty and character of its personnel. Fraud is an element of business that can significantly affect the reputation and success of the Company. The Company requires its employees and directors to talk to supervisors, managers or other appropriate personnel to report and discuss any known or suspected criminal activity or violations of this Code involving the Company or its associates. If, during the course of your employment, you become aware of any suspicious activity or behavior, you should report such activity or behavior to a member of the Company's senior management.
9. Waiver of Code of Conduct and Ethics
All managers and direct supervisors are responsible for reviewing this Code of Conduct and Ethics with their subordinates each time a new edition of the Code of Conduct and Ethics is published.
Employees and directors of the Company are expected to follow this Code of Conduct and Ethics at all times. In rare circumstances, situations may arise in which a waiver may be appropriate. Waivers will be determined on a case-by-case basis by the Company's senior management. However, waivers for directors and executive officers may only be granted by the Board of Directors, which shall have the sole and absolute discretionary authority to approve any deviation or waiver from this Code of Conduct and Ethics. Known or suspected violations of this Code of Conduct and Ethics will be investigated and may result in disciplinary action up to and including immediate termination of employment from the Company.
