Code of Business
Prime staff abides by the following Code of Business:
- Exercise due care to ensure that the business is fair, accurate and complete
- Uphold integrity of the capital market and act for the benefit of the customers. Staff members who possess material considered non public information that could affect the value of an investment do not act or cause others to act based on the information they possess. Staff members do not engage in practice that distort prices or artificially inflate trading volume with the intent to mislead market participants
- Act with integrity, competence, diligence, respect and in an ethical manner with the public, colleagues in the profession, existing and prospective customers. Staff members have a duty of loyalty to their customers and must act with reasonable care and apply prudent judgment. Staff members must act for the benefit of customers and place their customers’ interest before their own interest
- Prime staff members deal fairly and objectively with all customers when providing investment analysis, making investment recommendations, taking investment actions or engaging in other professional activities
When Prime staff is engaged in an advisory relationship with a client, they:
- Make reasonable inquiry into the existing or prospective customer’s investment experience, risk and return objectives and financial constraints prior to making any investment recommendation or taking investment action and must reassess and update this information regularly
- Determine that an investment is suitable to the customer’s financial situation and is consistent with the customer’s objectives, mandates, and constraints before taking any investment decision
- Judge the suitability of investments in the context of the customer’s total portfolio
- Communicating investment performance information after making reasonable efforts to ensure that it is fair, accurate and complete
- Prime staff members keep information about their current, former and prospective customers’ confidential unless:
- The information concerns illegal activities
- Disclosure is required by law
- The customer permits disclosures
- Prime staff members do not accept or offer gifts, benefits, compensations or considerations that compete with or might reasonably be expected to create a conflict of interest with Prime
- Prime staff members make reasonable efforts to detect and prevent violations of applicable laws and regulations
- Prime staff members are prohibited from making any political contribution
Conflict of Interest Policy:
- Disclosure of Conflicts: Prime staff members make fair and full disclosure of all matters that could reasonably be expected to impair their independence and objectivity or interfere with their respective duties to their customers and to the company itself. They ensure that such disclosure is prominent, are delivered in plain language and communicate the relevant information effectively
- Priority of Transactions: Investment transactions for customers and the company itself have priority over their own transactions
- Referral Fees: Prime staff members disclose to the company and customers as appropriate; any compensation, consideration or benefit received from or paid to others for the recommendation of product or service.