Legal & Compliance

Code of Conduct

Our commitment to the highest standards of ethical and professional conduct.

This Code of Conduct represents Sapphire Broking's commitment to the highest standards of ethical business conduct. All directors, employees, and authorized representatives are expected to adhere to this code in their daily activities.

The code is a living document that will evolve as our business and the regulatory environment change. It serves as a guide for how we conduct business and interact with our stakeholders.

Quick navigation

Ethical Practices Client Service Commitment Transparency and Disclosure Compliance Framework Human Resources and Training Technology and Cybersecurity Risk Management Marketing and Promotion Social Responsibility Implementation and Monitoring Specific Commitments

1. Ethical Practices

1.1 Honesty and integrity

Sapphire Broking shall conduct its business with integrity, fairness, dignity, and ethics.
We shall act honestly and fairly in the best interests of our clients.
We shall maintain high standards of integrity in all business dealings.
We shall not knowingly participate in or assist any violation of laws, rules, or regulations.

1.2 Conflicts of interest

Sapphire Broking shall take all reasonable steps to identify conflicts of interest.
We shall disclose actual or potential conflicts of interest to clients.
We shall implement measures to manage conflicts in a way that protects clients' interests.
We shall ensure that personal investments of employees do not conflict with client interests.

1.3 Market integrity

Sapphire Broking shall uphold the integrity and fairness of the securities market.
We shall not engage in manipulative, fraudulent, or deceptive practices.
We shall promote fair dealing in the securities market.
We shall report suspicious transactions to relevant authorities.

2. Client Service Commitment

2.1 Client classification and profiling

Sapphire Broking shall classify clients based on their knowledge, experience, financial situation, and risk tolerance.
We shall periodically update client profiles to ensure appropriate service.
We shall offer services suitable to each client's profile and needs.
We shall respect clients' investment objectives and constraints.

2.2 Best execution

Sapphire Broking shall take all reasonable steps to obtain the best possible result for clients.
We shall execute orders promptly, fairly, and expeditiously.
We shall not discriminate between clients when executing orders.
We shall maintain effective systems and controls for order execution.

2.3 Client communication

Sapphire Broking shall communicate with clients in a clear, fair, and not misleading manner.
We shall provide accurate information about services, fees, and charges.
We shall respond to client inquiries promptly and courteously.
We shall notify clients of significant matters affecting their accounts.

2.4 Safeguarding client assets

Sapphire Broking shall segregate client funds and securities from its own assets.
We shall ensure proper accounting of client assets.
We shall implement robust systems to prevent misuse of client assets.
We shall conduct regular reconciliation of client accounts.

2.5 Complaint handling

Sapphire Broking shall establish effective procedures for handling client complaints.
We shall investigate complaints promptly, thoroughly, and impartially.
We shall communicate the outcome of investigations to clients.
We shall use complaints as feedback to improve services.

3. Transparency and Disclosure

3.1 Fee disclosure

Sapphire Broking shall disclose all fees, charges, and commissions clearly.
We shall provide a detailed break-up of various charges.
We shall avoid hidden fees or unexpected charges.
We shall inform clients in advance about any changes in the fee structure.

3.2 Risk disclosure

Sapphire Broking shall adequately disclose all material risks to clients.
We shall ensure clients understand the risks associated with different products and services.
We shall not downplay risks to promote products or services.
We shall provide risk disclosure documents as required by regulations.

3.3 Transaction reporting

Sapphire Broking shall provide timely and accurate contract notes for all transactions.
We shall maintain comprehensive records of client transactions.
We shall provide periodic statements of accounts to clients.
We shall ensure all trade confirmations are accurate and complete.

4. Compliance Framework

4.1 Regulatory compliance

Sapphire Broking shall comply with all applicable laws, rules, and regulations.
We shall stay updated on regulatory changes and implement them promptly.
We shall cooperate fully with regulatory examinations and inquiries.
We shall maintain all required licenses and registrations.

4.2 Know Your Customer (KYC)

Sapphire Broking shall implement robust KYC procedures.
We shall verify the identity of clients using reliable, independent source documents.
We shall conduct enhanced due diligence for high-risk clients.
We shall periodically update KYC information.

4.3 Anti-Money Laundering (AML)

Sapphire Broking shall establish effective AML policies and procedures.
We shall monitor transactions for suspicious activities.
We shall report suspicious transactions to relevant authorities.
We shall provide regular AML training to staff.

4.4 Record keeping

Sapphire Broking shall maintain complete and accurate records as required by regulations.
We shall preserve records for the prescribed periods.
We shall ensure the security and confidentiality of records.
We shall maintain proper audit trails for all transactions.

5. Human Resources and Training

5.1 Staff competence

Sapphire Broking shall employ staff with appropriate qualifications and expertise.
We shall ensure staff remains competent through continuous professional development.
We shall assess staff performance regularly.
We shall maintain adequate supervision of staff activities.

5.2 Training and development

Sapphire Broking shall provide comprehensive training to staff.
We shall conduct regular training on compliance, ethics, and product knowledge.
We shall promote a culture of continuous learning and improvement.
We shall ensure staff is updated on market developments and regulatory changes.

5.3 Employee conduct

Sapphire Broking shall establish clear standards of conduct for employees.
We shall prohibit employees from engaging in unethical practices.
We shall require employees to disclose personal investments and outside business activities.
We shall implement disciplinary procedures for violations of the code of conduct.

6. Technology and Cybersecurity

6.1 System reliability

Sapphire Broking shall maintain reliable and efficient trading systems.
We shall conduct regular testing and maintenance of systems.
We shall implement backup and recovery procedures.
We shall have contingency plans for system failures.

6.2 Cybersecurity

Sapphire Broking shall implement robust cybersecurity measures.
We shall protect client data from unauthorized access.
We shall conduct regular vulnerability assessments and penetration testing.
We shall have an incident response plan for security breaches.

6.3 Data privacy

Sapphire Broking shall respect the privacy of client information.
We shall collect, use, and store client data in accordance with data protection laws.
We shall obtain necessary consents for data processing.
We shall implement appropriate data security measures.

7. Risk Management

7.1 Risk assessment

Sapphire Broking shall identify and assess risks in all aspects of operations.
We shall implement appropriate controls to mitigate identified risks.
We shall regularly review and update risk assessments.
We shall establish risk tolerance levels and monitoring mechanisms.

7.2 Margin management

Sapphire Broking shall implement effective margin collection and monitoring systems.
We shall inform clients about margin requirements and consequences of non-compliance.
We shall liquidate positions when margins are not maintained as required.
We shall conduct stress testing of margin requirements.

7.3 Business continuity

Sapphire Broking shall develop and maintain business continuity plans.
We shall test these plans regularly to ensure their effectiveness.
We shall ensure critical functions can continue during disruptions.
We shall train staff on their roles during business disruptions.

8. Marketing and Promotion

8.1 Honest representation

Sapphire Broking shall ensure all marketing materials are accurate and not misleading.
We shall not make unrealistic promises or guarantees about investment returns.
We shall clearly differentiate between facts and opinions in marketing communications.
We shall not misrepresent our capabilities, qualifications, or services.

8.2 Fair competition

Sapphire Broking shall compete fairly and ethically.
We shall not denigrate competitors or their services.
We shall not use unfair or deceptive practices to gain competitive advantage.
We shall respect intellectual property rights.

10. Implementation and Monitoring

10.1 Responsibility for implementation

The senior management of Sapphire Broking shall be responsible for implementing this code.
We shall allocate adequate resources for implementation.
We shall designate specific individuals to oversee compliance with the code.
We shall incorporate the code into all aspects of operations.

10.2 Monitoring and review

Sapphire Broking shall regularly monitor compliance with this code.
We shall conduct periodic reviews of practices against the code.
We shall update the code as necessary to reflect changes in regulations and industry standards.
We shall address any identified gaps or weaknesses promptly.

10.3 Reporting violations

Sapphire Broking shall establish channels for reporting violations of the code.
We shall protect whistleblowers from retaliation.
We shall investigate reported violations thoroughly.
We shall take appropriate corrective actions for confirmed violations.

11. Specific Commitments

11.1 To clients

Sapphire Broking shall prioritize clients' interests.
We shall provide appropriate advice and recommendations.
We shall execute transactions promptly and efficiently.
We shall maintain confidentiality of client information.

11.2 To regulators

Sapphire Broking shall comply with the letter and spirit of regulations.
We shall cooperate fully with regulatory authorities.
We shall report violations of regulations to appropriate authorities.
We shall participate constructively in regulatory consultations.

11.3 To employees

Sapphire Broking shall provide a safe and conducive work environment.
We shall promote diversity and inclusion.
We shall offer fair compensation and benefits.
We shall respect employee rights and dignity.

11.4 To business partners

Sapphire Broking shall deal fairly with business partners.
We shall honor contractual obligations.
We shall make timely payments to service providers.
We shall build relationships based on mutual respect and trust.

11.5 To markets

Sapphire Broking shall contribute to efficient and transparent markets.
We shall not engage in activities that disrupt market integrity.
We shall promote fair price discovery.
We shall support regulatory initiatives aimed at market development.

Compliance Framework

Preventive controls

Policies, procedures, and training to prevent violations of the Code of Conduct.

Detective controls

Monitoring and oversight activities to identify potential violations.

Corrective controls

Procedures for addressing violations and implementing corrective actions.

Need help?

Compliance Officer

Email: [email protected]
Phone: 0712-2996300

Last updated: April 1, 2025

Legal & Compliance

Code of Conduct

Our commitment to the highest standards of ethical and professional conduct.

The code is a living document that will evolve as our business and the regulatory environment change. It serves as a guide for how we conduct business and interact with our stakeholders.

Quick navigation

1. Ethical Practices

1.1 Honesty and integrity

Sapphire Broking shall conduct its business with integrity, fairness, dignity, and ethics.
We shall act honestly and fairly in the best interests of our clients.
We shall maintain high standards of integrity in all business dealings.
We shall not knowingly participate in or assist any violation of laws, rules, or regulations.

1.2 Conflicts of interest

Sapphire Broking shall take all reasonable steps to identify conflicts of interest.
We shall disclose actual or potential conflicts of interest to clients.
We shall implement measures to manage conflicts in a way that protects clients' interests.
We shall ensure that personal investments of employees do not conflict with client interests.

1.3 Market integrity

Sapphire Broking shall uphold the integrity and fairness of the securities market.
We shall not engage in manipulative, fraudulent, or deceptive practices.
We shall promote fair dealing in the securities market.
We shall report suspicious transactions to relevant authorities.

2. Client Service Commitment

2.1 Client classification and profiling

Sapphire Broking shall classify clients based on their knowledge, experience, financial situation, and risk tolerance.
We shall periodically update client profiles to ensure appropriate service.
We shall offer services suitable to each client's profile and needs.
We shall respect clients' investment objectives and constraints.

2.2 Best execution

Sapphire Broking shall take all reasonable steps to obtain the best possible result for clients.
We shall execute orders promptly, fairly, and expeditiously.
We shall not discriminate between clients when executing orders.
We shall maintain effective systems and controls for order execution.

2.3 Client communication

Sapphire Broking shall communicate with clients in a clear, fair, and not misleading manner.
We shall provide accurate information about services, fees, and charges.
We shall respond to client inquiries promptly and courteously.
We shall notify clients of significant matters affecting their accounts.

2.4 Safeguarding client assets

Sapphire Broking shall segregate client funds and securities from its own assets.
We shall ensure proper accounting of client assets.
We shall implement robust systems to prevent misuse of client assets.
We shall conduct regular reconciliation of client accounts.

2.5 Complaint handling

Sapphire Broking shall establish effective procedures for handling client complaints.
We shall investigate complaints promptly, thoroughly, and impartially.
We shall communicate the outcome of investigations to clients.
We shall use complaints as feedback to improve services.

3. Transparency and Disclosure

3.1 Fee disclosure

Sapphire Broking shall disclose all fees, charges, and commissions clearly.
We shall provide a detailed break-up of various charges.
We shall avoid hidden fees or unexpected charges.
We shall inform clients in advance about any changes in the fee structure.

3.2 Risk disclosure

Sapphire Broking shall adequately disclose all material risks to clients.
We shall ensure clients understand the risks associated with different products and services.
We shall not downplay risks to promote products or services.
We shall provide risk disclosure documents as required by regulations.

3.3 Transaction reporting

Sapphire Broking shall provide timely and accurate contract notes for all transactions.
We shall maintain comprehensive records of client transactions.
We shall provide periodic statements of accounts to clients.
We shall ensure all trade confirmations are accurate and complete.

4. Compliance Framework

4.1 Regulatory compliance

Sapphire Broking shall comply with all applicable laws, rules, and regulations.
We shall stay updated on regulatory changes and implement them promptly.
We shall cooperate fully with regulatory examinations and inquiries.
We shall maintain all required licenses and registrations.

4.2 Know Your Customer (KYC)

Sapphire Broking shall implement robust KYC procedures.
We shall verify the identity of clients using reliable, independent source documents.
We shall conduct enhanced due diligence for high-risk clients.
We shall periodically update KYC information.

4.3 Anti-Money Laundering (AML)

Sapphire Broking shall establish effective AML policies and procedures.
We shall monitor transactions for suspicious activities.
We shall report suspicious transactions to relevant authorities.
We shall provide regular AML training to staff.

4.4 Record keeping

Sapphire Broking shall maintain complete and accurate records as required by regulations.
We shall preserve records for the prescribed periods.
We shall ensure the security and confidentiality of records.
We shall maintain proper audit trails for all transactions.

5. Human Resources and Training

5.1 Staff competence

Sapphire Broking shall employ staff with appropriate qualifications and expertise.
We shall ensure staff remains competent through continuous professional development.
We shall assess staff performance regularly.
We shall maintain adequate supervision of staff activities.

5.2 Training and development

Sapphire Broking shall provide comprehensive training to staff.
We shall conduct regular training on compliance, ethics, and product knowledge.
We shall promote a culture of continuous learning and improvement.
We shall ensure staff is updated on market developments and regulatory changes.

5.3 Employee conduct

Sapphire Broking shall establish clear standards of conduct for employees.
We shall prohibit employees from engaging in unethical practices.
We shall require employees to disclose personal investments and outside business activities.
We shall implement disciplinary procedures for violations of the code of conduct.

6. Technology and Cybersecurity

6.1 System reliability

Sapphire Broking shall maintain reliable and efficient trading systems.
We shall conduct regular testing and maintenance of systems.
We shall implement backup and recovery procedures.
We shall have contingency plans for system failures.

6.2 Cybersecurity

Sapphire Broking shall implement robust cybersecurity measures.
We shall protect client data from unauthorized access.
We shall conduct regular vulnerability assessments and penetration testing.
We shall have an incident response plan for security breaches.

6.3 Data privacy

Sapphire Broking shall respect the privacy of client information.
We shall collect, use, and store client data in accordance with data protection laws.
We shall obtain necessary consents for data processing.
We shall implement appropriate data security measures.

7. Risk Management

7.1 Risk assessment

Sapphire Broking shall identify and assess risks in all aspects of operations.
We shall implement appropriate controls to mitigate identified risks.
We shall regularly review and update risk assessments.
We shall establish risk tolerance levels and monitoring mechanisms.

7.2 Margin management

Sapphire Broking shall implement effective margin collection and monitoring systems.
We shall inform clients about margin requirements and consequences of non-compliance.
We shall liquidate positions when margins are not maintained as required.
We shall conduct stress testing of margin requirements.

7.3 Business continuity

Sapphire Broking shall develop and maintain business continuity plans.
We shall test these plans regularly to ensure their effectiveness.
We shall ensure critical functions can continue during disruptions.
We shall train staff on their roles during business disruptions.

8. Marketing and Promotion

8.1 Honest representation

Sapphire Broking shall ensure all marketing materials are accurate and not misleading.
We shall not make unrealistic promises or guarantees about investment returns.
We shall clearly differentiate between facts and opinions in marketing communications.
We shall not misrepresent our capabilities, qualifications, or services.

8.2 Fair competition

Sapphire Broking shall compete fairly and ethically.
We shall not denigrate competitors or their services.
We shall not use unfair or deceptive practices to gain competitive advantage.
We shall respect intellectual property rights.

10. Implementation and Monitoring

10.1 Responsibility for implementation

The senior management of Sapphire Broking shall be responsible for implementing this code.
We shall allocate adequate resources for implementation.
We shall designate specific individuals to oversee compliance with the code.
We shall incorporate the code into all aspects of operations.

10.2 Monitoring and review

Sapphire Broking shall regularly monitor compliance with this code.
We shall conduct periodic reviews of practices against the code.
We shall update the code as necessary to reflect changes in regulations and industry standards.
We shall address any identified gaps or weaknesses promptly.

10.3 Reporting violations

Sapphire Broking shall establish channels for reporting violations of the code.
We shall protect whistleblowers from retaliation.
We shall investigate reported violations thoroughly.
We shall take appropriate corrective actions for confirmed violations.

11. Specific Commitments

11.1 To clients

Sapphire Broking shall prioritize clients' interests.
We shall provide appropriate advice and recommendations.
We shall execute transactions promptly and efficiently.
We shall maintain confidentiality of client information.

11.2 To regulators

Sapphire Broking shall comply with the letter and spirit of regulations.
We shall cooperate fully with regulatory authorities.
We shall report violations of regulations to appropriate authorities.
We shall participate constructively in regulatory consultations.

11.3 To employees

Sapphire Broking shall provide a safe and conducive work environment.
We shall promote diversity and inclusion.
We shall offer fair compensation and benefits.
We shall respect employee rights and dignity.

11.4 To business partners

Sapphire Broking shall deal fairly with business partners.
We shall honor contractual obligations.
We shall make timely payments to service providers.
We shall build relationships based on mutual respect and trust.

11.5 To markets

Sapphire Broking shall contribute to efficient and transparent markets.
We shall not engage in activities that disrupt market integrity.
We shall promote fair price discovery.
We shall support regulatory initiatives aimed at market development.

Compliance Framework

Preventive controls

Policies, procedures, and training to prevent violations of the Code of Conduct.

Detective controls

Monitoring and oversight activities to identify potential violations.

Corrective controls

Procedures for addressing violations and implementing corrective actions.

Need help?

Compliance Officer

Email: [email protected]
Phone: 0712-2996300

Last updated: April 1, 2025

Code of Conduct

1. Ethical Practices

1.1 Honesty and integrity

1.2 Conflicts of interest

1.3 Market integrity

2. Client Service Commitment

2.1 Client classification and profiling

2.2 Best execution

2.3 Client communication

2.4 Safeguarding client assets

2.5 Complaint handling

3. Transparency and Disclosure

3.1 Fee disclosure

3.2 Risk disclosure

3.3 Transaction reporting

4. Compliance Framework

4.1 Regulatory compliance

4.2 Know Your Customer (KYC)

4.3 Anti-Money Laundering (AML)

4.4 Record keeping

5. Human Resources and Training

5.1 Staff competence

5.2 Training and development

5.3 Employee conduct

6. Technology and Cybersecurity

6.1 System reliability

6.2 Cybersecurity

6.3 Data privacy

7. Risk Management

7.1 Risk assessment

7.2 Margin management

7.3 Business continuity

8. Marketing and Promotion

8.1 Honest representation

8.2 Fair competition

9. Social Responsibility

9.1 Environmental responsibility

9.2 Community engagement

9.3 Investor education

10. Implementation and Monitoring

10.1 Responsibility for implementation

10.2 Monitoring and review

10.3 Reporting violations

11. Specific Commitments

11.1 To clients

11.2 To regulators

11.3 To employees

11.4 To business partners

11.5 To markets

Compliance Framework

Preventive controls

Detective controls

Corrective controls

Compliance Officer

Code of Conduct

1. Ethical Practices

1.1 Honesty and integrity

1.2 Conflicts of interest

1.3 Market integrity

2. Client Service Commitment

2.1 Client classification and profiling

2.2 Best execution

2.3 Client communication

2.4 Safeguarding client assets

2.5 Complaint handling

3. Transparency and Disclosure

3.1 Fee disclosure

3.2 Risk disclosure

3.3 Transaction reporting

4. Compliance Framework

4.1 Regulatory compliance

4.2 Know Your Customer (KYC)

4.3 Anti-Money Laundering (AML)

4.4 Record keeping

5. Human Resources and Training

5.1 Staff competence

5.2 Training and development

5.3 Employee conduct

6. Technology and Cybersecurity

6.1 System reliability