Responsible Business Practices

The Aberdeen Group seeks to be a good corporate citizen in all aspects of its operations and activities. To this end we have brought together a series of operating principles under the broad heading of corporate social responsibility to serve as a guide to employees in all aspects of their work for the company. The principles cover all aspects of Aberdeen’s operations and have been developed with reference to the relevant codes of corporate governance and best practice, including the revised Combined Code and international statements and guidelines, such as the UN Universal Declaration of Human Rights and the OECD Guidelines for Multinational Enterprises. The principles are as follows:

Ethical Business Conduct

We value the principles of accountability, honesty and integrity in all aspects of our business. Our policy is to conduct our business in a manner which ensures:

Fair treatment of all employees and clients
Transparency of our business policies and practices
High standards in all matters relating to health, safety and the environment
Ethical business practices throughout our operations

We recognise that the involvement of our employees is key to the future success of the business. We have consistently operated a remuneration policy that recognises both corporate and individual performance. We are also committed to best practice in employment matters, recognising the role this plays in attracting and retaining staff.

To succeed in delivering the best possible service to our clients, every employee is expected to adhere to Aberdeen’s core values and to uphold them in the workplace. Employees are expected at all times to exercise the highest ethical judgement and comply with laws applicable to their duties. These principles cover all employees globally.

Compliance with Codes and Regulations

In addition to Aberdeen’s internal operating principles, employees shall adhere to all national laws and regulations. As investors in more than one investment jurisdiction, investment managers will be required to familiarise themselves with the codes of practice in the domains for which they are responsible as well as those codes and regulations in force in the UK. These will include the rules of the FSA and other financial services regulators, regulations specific to UCITs and OEICs, the ERISA rules and the recent stipulations with Sarbanes-Oxley.

Whistle Blowing
In the event that an employee discovers a breach of company policy, there is a facility for him/her to report that breach in confidence either via his line manager or via an anonymous email address sent directly to the Head of Internal Audit. The Head of Internal Audit has a duty to investigate fully the detail behind such a report and as part of the investigation will not normally make reference to the anonymous report. Maliciously motivated reports for which there is no real basis are not welcome and may result in disciplinary action being taken against the employee making the accusation.

Outside Interests

Aberdeen requires that employees avoid at all times any situation which may involve a conflict of interest between the employee and the company. Employees are expressly prohibited from accepting other paid employment, including directorships in other companies, without the consent of the Executive. In general, this does not apply to charitable work or relationships with non-profit organisations, unless this has the potential to impact the employee’s normal duties.

Dealing with Customers, Stakeholders and External Parties

Aberdeen is committed to the provision of accurate information and fairness in all its dealings with customers, stakeholders, officials and any other external party having direct business with the Group.

Confidentiality

Every employee shall respect any information which is confidential to Aberdeen including, but not limited to, trade secrets, confidential knowledge or any information concerning the process or invention used by the Group. Breaches of confidentiality may be cause for disciplinary action.

Data Protection
We are committed to complying with the data protection principles established by the 1995 EU Directive on Data Protection. This commitment applies throughout the Group and in all countries in which it operates. If the Group conducts business in a jurisdiction where stricter rules apply, then it will comply with those rules as a matter of course. All employees and agents of Aberdeen are responsible for ensuring compliance with the policy. Information collected may be accessible throughout the Group but will not be disclosed to any third party in a form which identifies the individual concerned. It will not be used for marketing purposes without the individual’s consent and will not be sold to third parties. Upon request, individuals will be informed of the existence, use and disclosure of his or her personal data and will be given access to that data to confirm its accuracy or amend it as appropriate.

Fair Dealings

Dealings for clients will be taken in an order and manner which is unquestionably fair for the client. The buying and selling of equities, for example, will not prejudice any party and shall be administered with the compliance regulations governing trading operations.

Malpractice

The Group actively works to deter malpractice in its workplace, with specific attention to activities involving bribery and corruption, fraud, money laundering and insider trading. The Group has detailed procedures for staff to follow in order to ensure observance of these principles. The Compliance Database contains guidance on the values of gifts which may be given or accepted by staff, to or from counterparts in the industry, the frequency with which those gifts may be made or accepted and how they should be recorded. There are also detailed procedures in place to help staff to identify instances of money laundering and a member of the Compliance Team is designated as the Money Laundering Reporting Officer (MLRO). Staff are required to report any unusual patterns of trading activity, which could be interpreted as money laundering, to the MLRO. The MLRO is responsible for investigating any suspicious transaction reports, making a decision as to whether it does constitute money laundering, and if so, notifying the National Criminal Investigation Service. Relevant staff receive training, tailored to their specific roles in the company to assist them in identifying activities of money laundering.

The Group also has procedures in place to prevent insider trading by employees. All personal dealing, except for trading in unit trusts or OEICs, by fund management and administration staff who might have access to privileged information, requires prior approval by two senior members of staff. If the Group is dealing in a stock in which the employee wishes to trade, the employee can do so once the transaction on behalf of the corporate client has been completed. All employee investments must be declared on an annual basis and transactions must be declared at the end of each calendar quarter. Employees should avoid any financial situation that conflicts with the Group’s interests or potential interests.

Use of Company Information / Assets

Employees shall use the company’s computer systems, internet and intranet, and email systems for business use. Any employee found to have disclosed confidential information, been abusive or malicious in using these facilities, or misusing the systems in any way may face disciplinary action. The Group strictly prohibits the use of its intranet, internet or email systems for acquiring, producing, or disseminating pornography or similar material including the use of abusive language or offensive images.

How the Principles are Monitored

As indicated above, there are specific requirements to be observed by investment managers who deal for their own account. In addition to a series of mandatory checks and authorisations prior to placing an order, investment managers and all staff who may have knowledge of the Group’s investment activity on behalf of clients complete a quarterly return on personal dealing. The record of investments held by employees and any relationships with brokers must be updated annually.

Disciplinary Procedure
The Company has a detailed, formal disciplinary procedure, the full details of which are contained on the Company’s intranet.

Political Contributions

It is the Group’s policy not to make contributions for political purposes. However, employees are not hindered from being politically active in their own time using their own resources.