Fundamental approach

The Westwood Group aims to enrich society with due regard to the integrity of the agarwood and various other businesses for the purpose of promoting an efficient and lucrative income source and wealth for our customers and stakeholders whilst protecting the environment and our natural resources.

Westwood Group people must act in the best interests of their customers.

Westwood Group People must understand how confidence in The Westwood Group could be undermined by any misconduct and how hard it could be to restore it. Therefore, Westwood Group People must promote proper understanding and compliance with the letter and spirit of all applicable laws, rules and regulations, including those concerning prevention of insider trading, money laundering, bribery and tax evasion.

Westwood Group People owe a duty to The Westwood Group to advance its legitimate interests whenever the opportunity arises. Westwood Group People are prohibited from taking for themselves personally opportunities that are discovered through the use of corporate property, information or position.

Westwood Group People should not take any actions that could have their private interests interfere in any way (or even appear to interfere) with the interests of The Westwood Group. Neither Westwood Group People nor their family members should receive improper personal benefits as a result of their positions in The Westwood Group, including loans, or guarantees of obligations, from The Westwood Group.

Westwood Group People must maintain the confidentiality of information entrusted to them by The Westwood Group or its customers in the conduct of its business, except when disclosure is authorized or legally mandated.

Westwood Group People must respect fair business practices in jurisdictions where they operate and endeavour to deal fairly with The Westwood Group’s customers, suppliers, competitors and Westwood Group People. Westwood Group People should not take unfair advantage of anyone through manipulation, concealment, abuse of confidential information, misrepresentation of material facts, or any other unfair-dealing practice.

The Westwood Group must reject all contacts with criminal or unethical organizations involved in activities in violation of applicable laws.

Westwood Group People may give or accept from non-government employees gifts or entertainment in accordance with specified guidelines of the relevant company of The Westwood Group. In addition, Westwood Group People may not give gifts to or entertain government officials without specified approval by the relevant company of The Westwood Group.

All Westwood Group assets should be used for legitimate purposes. Westwood Group People should protect The Westwood Group’s assets and ensure their efficient use.

The Westwood Group People must prepare documents relating to the business or accounting of The Westwood Group and retain such documents for specified periods in accordance with applicable laws and internal rules of the Company or the relevant company of The Westwood Group. In connection with litigation or examinations by any regulatory body, Westwood Group People shall not make false statements or intentionally conceal or destroy any relevant documents.

The Westwood Group is committed to acting in an environmentally responsible manner and should therefore approach environmental issues positively.

The Westwood Group as a good corporate citizen is committed to the pursuit of activities of social benefit.

The Westwood Group respects human rights and diversity, and values differences. The Westwood Group is committed to ensuring that anyone who interacts with The Westwood Group is treated with respect at all times and in all circumstances. No person shall be subject to discriminatory practices or harassment for reasons including, but not limited to, their national or ethnic origins, color, race, gender, age, religious belief, social status, sexual orientation or gender identity, or disability.

The Westwood Group is committed to providing equal employment opportunities and a sound working environment where Westwood Group people can, and do, perform at their best.

Westwood Group People must respect the culture and customs of all the countries where they operate and strive to manage their activities in such a way as to consider the societies and economies of such countries.

If Westwood Group People externally publish information relating to The Westwood Group business in publications, lectures and interviews, they must follow the guidelines promulgated by the relevant company of The Westwood Group.

If Westwood Group People buy or sell the stock of the Company for their personal accounts, they must comply with all applicable securities laws and follow specified procedures in accordance with the guidelines promulgated by the Company or the relevant company of The Westwood Group.

If Westwood Group People become aware of any conduct, including accounting, and auditing matters, that they believe is illegal or unethical, they must promptly notify an appropriate contact specified in the guidelines promulgated by each of The Westwood Group.

The contact above of Westwood Group People must take appropriate steps to investigate whether and how such misconduct occurred and, when necessary, to correct it and prevent its recurrence.

Westwood Group People are prohibited from retaliating against any individual who reports in good faith illegal or unethical conduct.

All Financial and Accounting Professionals must, in addition to the foregoing:

• promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
• make full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company and each of The Westwood Group files with, or submits to, any applicable regulatory body and in other public communications;
• comply with all applicable generally accepted accounting principles, government laws, rules and regulations;
• promptly report violations of this section to an appropriate contact specified in the guidelines promulgated by the Company or the relevant company of The Westwood Group, in cases they believe that such violations have occurred; and
• be accountable for their adherence to this section.

Financial and Accounting Professionals are prohibited from directly or indirectly taking any action to fraudulently influence, coerce, manipulate, or mislead any independent public or certified accountant in the performance of an audit of the financial statements of any of The Westwood Group for the purpose of rendering such financial statements materially misleading.

“Financial and Accounting Professional” means any professional employee of The Westwood Group in the area of finance, controllers, tax, treasury, risk management or investor relations and also includes the Group CEO, the Chief Financial Officer and the Chief Risk Officer and all Division Heads, all Business Division Heads, all Corporate Function Heads of The Westwood Group.

The Company shall disclose amendments to, and any waivers from, this “Code of Ethics of The Westwood Group” in accordance with applicable laws. For this reason, Westwood Group People shall promptly inform their senior management in the event they become aware of circumstances that may require an amendment or waiver under the Code so that the Company may comply in a timely fashion.