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Code of Ethics and Conduct

1. General Provisions: Haitong faithfully complies with to the legal, normative and regulatory provisions applicable to it, as well as the rules and procedures for compliance, promoting fair competition with its market partners.

It does not allow any kind of discrimination or the adoption of disloyal practices within or outside its premises.

 

The Bank in Brazil has Policies and Manuals that define and establish the ethical principles and rules of conduct; the rules and parameters of activity; the internal procedures and controls; the operational risks; and the handling of internal information and computer systems.

 

2. Relationship with Clients and the Market: Haitong guarantees, for all its Clients and Partners, that it will provide services with quality and efficiency, conducting its operations with diligence and fairness. The clients businesses are dealt with as priority.

 

3. Transparency with its Clients: In the exercise of its activities, the Haitong offers to its Clients services that are in their interests, prioritizing the anticipated clarification of risk and costs related to the operations they want to conduct. the Haitong is open to receive questions at any time, so that they can be quickly resolved.

Group in Brazil charges its Clients a fee that is commensurate with the services provided.

 

4. Conflicts of interest: Haitong prohibits situations that could be characterized as conflicts of interest with its clients, suppliers or market partners, and adopts tools for monitoring and control to prevent such situations. Such situations may include relationships of exclusivity, special benefits, and the like.

 

5. Privileged Information: All employees of the Haitong are aware of their obligation to maintain confidentiality of information about their clients, and any other information considered privileged, and are expressly prohibited from transmitting this information to anyone outside the scope of their normal duties.

 

6. Personal Obligations of the Employees: Employees should questioned Compliance Departament before assuming any position. The permitted investments are restricted to the cash and options market with a minimum holding period of 4 days.

 

7. Environment and Community: Haitong adopts and promotes the adoption of the best environmental practices, assuming a socially responsible attitude towards the Community.