Code of Conduct

1. Preamble.

This Code of Conduct establishes guidelines to cultivate exceptional business relationships, enabling ∆vantiQs, its clients, and business partners to thrive continuously. This Code further specifies ∆vantiQs’ core values, underscoring our collective commitment to uphold the highest standards of integrity and ethical conduct. These principles are non-negotiable for all members of ∆vantiQs.

2. Definitions.

This Code of Conduct and the related internal policies are hereinafter collectively referred to as the “Code”.​​

The terms “∆vantiQs” includes all its members, acting individually or jointly on behalf of the ∆vantiQs brand, including but not limited to employees, officers, directors, consultants, advisors, affiliates, licensees, licensors, contractors, sublicensees and agents. They are collectively referred to as the “∆vantiQs Organisation” or “∆vantiQs“, “we”, “us”, “ourselves” and “our”, as used in this Website from time to time.

3. Leading with Integrity​​.

At ∆vantiQs, we believe that our competitive advantage is built upon delivering superior services and solutions — not through unethical or unlawful practices. We aspire to be a respected provider of first-class consulting services for the financial services industry, and a leader in ethical behaviour. In this sense, this Code provides guidance for our ethical decision-making and, in cases where specific laws, regulations, or policies are absent, directs us to apply sound judgment to honour its spirit. In essence: ∆vantiQs is deeply committed to honesty and integrity in all business dealings. This commitment means:

• We consistently act with integrity, take responsibility for our actions, and show respect for each other and those with whom we do business. We prioritise doing the right thing, in the right way, even when it is more challenging.
• We set and maintain high expectations, take ownership, and hold ourselves accountable. These priorities are fundamental to ∆vantiQs.
• We abide by the letter and spirit of the laws and regulations everywhere we do business, maintaining zero tolerance for unlawful or unethical behaviour.

3.1 Impeccable Ethics and Business Conduct.

At ∆vantiQs, we engage with customers, business partners and any other stakeholders fairly and in good faith, and exercise sound judgment. This means that we do the right things, even when it is more challenging.

We do not take unfair advantage of anyone through manipulation, concealment, abuse of privileged or confidential information, misinterpretation of material fact, or other forms of unfair dealings or practices. By adhering to ethical business practices, we preserve the reputation of ∆vantiQs, its clients, and its business partners, and foster a safe, productive, and collaborative work environment.

Moreover, we are committed to upholding market integrity and avoiding any action that might impair fair competition. We neither engage in, nor appear to condone, corruption, misconduct, or otherwise illegal or contestable activities or practices. We refrain from offering, promising, soliciting, or accepting anything of value intended to improperly influence decision-making for ∆vantiQs or its clients.

3.2 Ownership and Accountability.

Ownership and personal accountability are central to ∆vantiQs’ culture. We uphold the highest ethical standards when representing ∆vantiQs, ensuring our actions reflect our commitment to integrity, mutual respect, and inclusivity. This includes proactively assessing and managing the potential impacts and risks of decisions and actions.

We hold ourselves accountable for our conduct and encourage members to voice concerns regarding potential misconduct that may violate laws, regulations, or this Code, in conformity with Section 7 of this Code.

Nobody, whether internally or externally, has the authority to instruct any ∆vantiQs member to act unethically or unlawfully.

3.3 Compliance.

Violating the law or engaging in unfair, deceptive, or abusive acts or practices may weaken customer confidence, put our reputation at risk, impact market integrity, result in legal action, fines or penalties, or other cause negative repercussions for ∆vantiQs. This is why we comply with the letter, spirit, and intent of laws, regulations, and this Code. In cases of conflict between this Code and applicable laws, legal compliance takes precedence.​

Compliance is not just a requirement for our business, but part of our identity and continued commitment to quality and ethical business.

4. Avoiding Conflicts to maintain Objectivity, and protect our Credibility.

Conflicts of interest can harm ∆vantiQs’ reputation, weaken client relationships, increase regulatory and litigation risks, and/or negatively affect our collaborative culture.

∆vantiQs honours its fiduciary obligation to act in its customers’ best interest. We put our client first, ensuring that personal interests do not take precedence. This includes avoiding relationships and activities that might affect our objectivity in making decisions and recommendations on behalf of ∆vantiQs, or otherwise undermine our credibility, including but not limited to

Personal finances:

We comply with all applicable laws, regulations, and this Code when managing personal finances and investment activities, or those of related third parties (e.g., family, friends). We notably do not improperly use or make available any information that we learn from work, or invest in the business of a client or business partner with whom we have, or recently had, dealings with on behalf of ∆vantiQs. This extends also to other forms of quasi-financial transactions – whether money is exchanged or not – including but not limited to betting. That is particularly critical in the case of publicly traded prospects, clients or partner organisations, regarding which we may have access to privileged, confidential or material, non-public information. We adequately protect this information from unauthorised use, including from other members of ∆vantiQs who do not have a legitimate and continuous business need to access said information. In particular, we use care when working away from the office to ensure our workspaces provide proper privacy.

Personal relationships:

We remain impartial and objective in our business dealings at all times. We therefore ensure that personal relationships do not create conflicts of interest. In particular, we do not engage in self-dealing, or act on behalf of ∆vantiQs in any transaction or business relationship that involves significant personal connection or material financial interest.

Gifts, business hospitality and other incitements:

While the exchange of gifts and business hospitality may be common business practice, ∆vantiQs does not accept or provide gifts, business hospitality or other forms of incitements to customers and business partners that violates law, regulations, or this Code, or otherwise create an actual or perceived conflict of interest. In particular, ∆vantiQs does never solicit, suggest, or request gifts, hospitality or other forms of incitements in exchange for business or any form of unfair advantage (e.g., counter affairs).

Personal outside interests and other external activities:

We ensure that personal outside interests and other external activities do not restrict ∆vantiQs’ business opportunities, reflect adversely on ∆vantiQs and its clients, create an actual or perceived of interests with ∆vantiQs or its clients, or cause a disruption of the operations of ∆vantiQs or its clients. In particular, it is prohibited to solicit ∆vantiQs’ members or clients, or use ∆vantiQs resources in connection with personal outside interests.

Political engagement:

While respecting each member’s right to personal political expression, which are personal endeavours, ∆vantiQs maintains a policy of political neutrality. ∆vantiQs hence does not provide, promise or imply sponsorship, contributions, or any other form of support to political parties, individual candidates, or political action committees, including the use of ∆vantiQs time or resources.

5. A winning Culture for superior Results.

5.1 A dynamic, stimulating and thriving work environment.

Nothing is more vital to the long-term success of ∆vantiQs, its clients, and its business partners, than the ability to work with the brightest talents. For this reason, ∆vantiQs is dedicated to cultivating a respectful, fair safe, and supportive work environment, fostering mutual respect, safety, and productive collaboration. This notably means that we are committed to a working environment that is free of threats, intimidation, harm, or other forms of disruptive or destructive behaviour.

We conduct ourselves appropriately when acting on behalf of ∆vantiQs, as our conduct can be perceived as a reflection of the standards of ∆vantiQs, its clients and/or its business partners.

We comply with all applicable laws and policies relate to health, safety, and security of the members of the ∆vantiQs organisation, the client organisation, and others involved in our dealings. We promptly report any acts or threats of violence, or other situations that could pose a threat to the integrity of others.

5.2 Diversity and Inclusion is Priority.

The success of ∆vantiQs, its clients, and its partners relies on our joint ability to successfully integrate a diverse network of people, leveraging a broad range of experiences and skills to establish a vibrant cultural mix. At ∆vantiQs, we thus embrace diversity as a strategic asset, empowering us to serve diverse clients and address varied marketplace needs.

Consequently, ∆vantiQs has a zero-tolerance policy for, and strictly prohibits, any form of discrimination, harassment, bias, or prejudice against any individual or group, including but not limited to those based on

• Personal Characteristics: Age, physical or mental disability, or other protected condition.
• Identity: Race, ethnicity, nationality, gender, and sexual orientation.
• Belief Systems: Creed, religion, or political orientation.
• Family Situation: Relationship status, family status, pregnancy, or other caring responsibilities.
• Public Service: Active military or civil service duties, or veteran status.
• Other: Any other status protected under applicable law, or any other factor deemed suitable to discriminate, harass, display bias or prejudice.

This commitment aligns with both international human rights standards and national anti-discrimination laws.

∆vantiQs takes all allegations of discrimination or harassment serious, regardless of jurisdiction. It is each ∆vantiQs member’s responsibility to report any concern or conduct that is or may be unlawful, abusive, or otherwise violates the Conduct, in conformity with Section 7.

Our policies ensure that we uphold a respectful and inclusive environment for all members of ∆vantiQs, its clients, and its business partners.

6. Mandatory Reporting Obligations concerning Violations of this Code.

∆vantiQs is committed to maintaining a culture of accountability and openness, encouraging its members to report any conduct that may violate applicable laws, regulations, or this Code. ∆vantiQs members have a mandatory responsibility to act when aware of any actions that contradict our standards – regardless of company affiliation, role or seniority – in conformity with Section 7 of this Code. Failure to report known or suspected violations may itself constitute a breach of this Code and is subject to review.

∆vantiQs assures that individuals reporting suspected breaches in good faith will be protected against adverse treatment, including retaliation or other negative repercussions.

Members uncertain about the implications of specific conduct or seeking guidance on how to proceed are encouraged to consult with appropriate supervisory personnel, or ∆vantiQs executive leadership.

All reports of violations are taken seriously and investigated in an objective, thorough, and timely manner.

7. Reporting of Violations and ethical Concerns.

All ∆vantiQs members have a duty to report any known or suspected breaches of this Code. Reports can be made confidentially through the following channels:

• Directly to the supervisor; or
• Via the secure reporting portal.

Reprisal or retaliation against members who report violations in good faith is strictly prohibited. Such actions will themselves be considered violations of this Code.

If you have questions regarding this Code of Conduct, please reach out to compliance@avantiqs.com, or write to ∆vantiQs, c/o Marc Woodfield, Chemin Daniel-Ihly 20, CH-1213 Petit-Lancy.

8. Final provisions.

If any portion of this Code of Conduct is invalid or unenforceable in any jurisdiction, then

• in that jurisdiction it will be re-construed to the maximum effect permitted by law in order to effect its intent as nearly as possible, and the remainder of this Code of Conduct will remain in full force and effect; and
• in every other jurisdiction, all of this Code of Conduct will remain in full force and effect.
• In the event of disputes concerning the interpretation or enforcement of this Code, matters will be governed and resolved by the laws and standards applicable in the jurisdiction of Switzerland.
• Place: Petit-Lancy, Switzerland.
• Last Update: January 15, 2024.