Our Policy Framework

Guiding Principles for Ethical Business Practices

FCA Regulated

At Exclusive Market, we operate under a strict set of policies that govern every aspect of our business. These policies reflect our commitment to integrity, transparency, and client-focused service in all our operations.

Our policies are designed to exceed regulatory requirements and industry standards, ensuring we maintain the highest level of professional conduct in serving our clients.

Business Ethics

Code of Conduct

Our ethical framework includes:

  • Zero tolerance for conflicts of interest
  • Strict anti-bribery and corruption measures
  • Fair dealing with all clients and counterparties
  • Transparent fee structures

Whistleblower Protection

We maintain:

  • Anonymous reporting channels
  • Non-retaliation policy for good faith reports
  • Independent investigation of all concerns
  • Regular reporting to the Board

Client Protection

Best Execution

We guarantee:

  • Execution at most favorable terms available
  • Regular monitoring of execution quality
  • Transparent reporting of execution statistics
  • Periodic policy reviews

Asset Safeguarding

Client assets are:

  • Held with regulated custodians
  • Segregated from firm assets
  • Regularly reconciled
  • Insured against institutional failure

Risk Management

Operational Controls

Our framework includes:

  • Three lines of defense model
  • Independent risk oversight
  • Comprehensive business continuity planning
  • Regular stress testing

Market Conduct

We prohibit:

  • Front-running client orders
  • Market manipulation of any kind
  • Abusive trading practices
  • Insider trading

Detailed Policy Information

Our investment policy governs all portfolio management activities:

  • Suitability Assessment: All investment recommendations must be suitable for the client's financial situation, investment experience, and objectives.
  • Diversification: Client portfolios are constructed with appropriate diversification to mitigate concentration risk.
  • Due Diligence: Rigorous analysis of all investment products before they are offered to clients.
  • Performance Reporting: Regular, transparent reporting of investment performance against benchmarks.
  • Proxy Voting: Voting client shares in their best interests with full disclosure.

This policy is reviewed annually by our Investment Committee.

Our compliance framework ensures adherence to all applicable laws and regulations:

  • Training: Mandatory compliance training for all employees with role-specific modules.
  • Monitoring: Automated surveillance systems complemented by manual reviews.
  • Reporting: Timely regulatory filings and breach notifications.
  • AML/KYC: Robust anti-money laundering and know-your-client procedures aligned with FATF recommendations.
  • Personal Account Dealing: Strict controls on employee trading with pre-clearance requirements.

Our Chief Compliance Officer has direct access to the Board of Directors.

Our approach to data management and technology:

  • Cybersecurity: Multi-layered security architecture with regular penetration testing.
  • Data Governance: Clear classification of data with appropriate access controls.
  • Cloud Strategy: Secure use of cloud services with encryption and jurisdictional controls.
  • Disaster Recovery: Geographically dispersed backup systems with regular failover testing.
  • Vendor Management: Rigorous due diligence on all third-party service providers.

Key Principles:

  • Confidentiality: Client information is never disclosed without consent except as required by law.
  • Integrity: Systems ensure data accuracy and prevent unauthorized modification.
  • Availability: Mission-critical systems maintain 99.99% uptime.

Our commitment to sustainable business practices:

  • Investment Integration: Systematic consideration of ESG factors in all investment decisions.
  • Exclusions: Prohibition on investments in controversial weapons, tobacco, and thermal coal.
  • Corporate Citizenship: Annual charitable contributions equal to 1% of pre-tax profits.
  • Diversity: Targets for gender and ethnic diversity at all organizational levels.
  • Carbon Neutrality: Commitment to net-zero operations by 2030.

Our ESG performance is independently audited and published annually.

Policy Governance Framework

All policies are reviewed annually by the relevant governing bodies:

Board Oversight

The Board of Directors approves all major policies and receives quarterly compliance reports.

Risk Committee

Senior management committee that monitors policy implementation and effectiveness.

Policy Owners

Designated senior executives responsible for maintaining and updating specific policies.

Contact Our Compliance Team

For policy-related inquiries or concerns: