Code of ethics

Subject to Regulation

1. This regulation includes the business conduct and ethics rules for employees of the "C‑QUADRAT Ampega Asset Management Armenia" LLC (hereinafter – the “Company”) and measures for prevention of conflict of interest
2. This Regulation is an internal legal act adopted on the basis of the 2nd Article of the RA Law “On Legal Acts” according to the 68th article of the RA Law “On Investment Funds".
3. This Regulationaims to contribute to
   • the Company’s corporate culture improvement,
   • the growth and enhancement of the corporate image and the reputation of the Company,
   • the Company and its employees’ conduct regulation,
   • the regulation of the Company’s fund manager’s activities.
4. This regulation applies to the following relations:
   • the Company and its employees,
   • relations arising in the working environment,
   • public administration bodies,
   • settlement of conflicts of interest.
5. Defining the ethical and professional standards set for the fund managers performing fund management activities on behalf of the Company or individual fund managers (hereafter - the “managers”).

Concepts
The following definitions are used in the regulation:
Employee - a person, with whom the Company has entered into an employment contract,
Customer - a person who is the owner of the shares of the fund managed by the Company or addresses the Company for using its services.
Pension secret - as defined by the 2nd and 19th articles of the RA Law “On Funded Pensions”,
Service information: as defined by the 97th article of the RA Law on “Investment Funds”
Classified securities: A list of securities where, at the point of composing or refreshing the list, the Company and its managed funds have investments or have the intention to make an investment.

Subject to Regulation

Company’s employees are obliged to:

1. respect other employees, regardless of their race, national origin, sex, age, religion, marital status, political preferences and work experience,
2. always look for new business opportunities, be open to accept the exchange of experience and progressive attitudes and perceptions, and introduction of new technologies,
3. continuously improve their professional skills, knowledge and personal qualities,
4. unite in a team for the realization of the Company’s mission and strategic goals by bearing personal responsibility for the individual or collective activities, or, if necessary, assist the other team members,
5. strive to improve the quality of the operations, increase labor productivity and contribute to the formation and maintenance of a favorable business environment in the Company,
6. realize the connection between the outcomes of the work and the development of the Company, invest all possible efforts for the individual, team and corporate growth,
7. act as a citizen but not as a Company employee or use Company’s name when engaging in politics or supporting any political party or candidate. The employee can engage in political activities only outside of working hours by informing the immediate supervisor.
8. The employees are required to comply with the requirements of the regulation. In case of uncertainty of any provision of this regulation, the employee shall apply to its immediate supervisor.

Employees’ duties with the Company and customers

Company’s employees are obliged to:

1. respect the customers, regardless of their race, national origin, sex, age, religion, marital status, political preferences and work experience,
2. always seek new ways to cooperate with customers, met and to identify their needs and expectations,
3. provide customers with all necessary details about the products in an easy and understandable manner,
4. prior notify the customers about their cooperation conditions and their changes,
5. refuse to provide service to the customer if it does not comply with the requirements of the RA legislation, or is not based on clients legal and/or economic needs,
6. identify the services the customer needs and that can best satisfy the customers’ needs,
7. disclose the service information about the customer or pensions secret only in accordance with RA legislation,
8. use any customer’s service information or pension secret only in accordance with requirements set by RA legislation and ensure their protection,
9. implement the Company's internal regulations’ provisions relating to the relationship with customers.

Employees’ duties with the Company and the partners

Company’s employees are obliged to:

1. investall efforts to fulfill the obligations of the Company towards the Company partners in good faith,
2. act in the interests of the Company in the partners relations,
3. uphold the reputation of the Company in the Company's partners relations, follow the requirements of the law and the Company's internal regulations,
4. build partner relations based on equality, mutual respect, trust, and principles of ensuring business interests,
5. disclose partners’ information only in accordance with RA legislation and provisions of signed contracts,
6. use any non-public information regarding partners only in cases provided by the contract and RA legislation.
7. notify the immediate supervisory, if the relations with partners do not match, or if there are suspicions that it may not fully reflect the requirements of the Rules.

Employees’ duties with the Company and government agencies

Company’s employees are obliged to:

1. ensure Company’s legal compliance,
2. express the official position of the Company in relations with government agencies,
3. in cases not prohibited by the legislation, respond promptly to inquiries of the state authorities and provide complete and accurate information,
4. avoid influencing state authorities decisions by illegal ways,
5. not mislead the public authorities, directly or indirectly interfere with the process of collecting information, data, statements or other documents,
6. not hide, modify, or destroy any documents that are subject to state authorities’ inquiries or investigations,
7. notify the immediate supervisory, if the relations with the authorities do not comply or there are suspicions that they may not fully reflect the requirements of the Rules

Employees’ duties for the Company’s property

Company’s employees are obliged to:

1. protect the property entrusted to them against loss, theft, and not intended or unlawful use,
2. use the Company’s assets in the most effective and prudent way
3. protect and not disclose Company’s commercial information,
4. follow the requirements of the Company's internal regulations regarding the use of Company’s assets,
5. not use the Company’s property for personal purposes.

Employees’ duties in preventing and excluding conflict of interests

Company’s employees are obliged to:

1. avoid actions that could lead to decision-making not in the Company’s interest (acceptance of benefits and awards in forms of gifts, money and other forms),
2. prior to running as a candidate in other companies’ management, consider the matter with the executive body’s head,
3. in relations with Company’s partners, avoid situations with conflicting interests between personal interests and the interests of the Company,
4. avoid loans or other services from persons having or striving to have business relations with the Company (does not apply to corporate or public offerings),
5. avoid any action which would have a negative impacton the execution of official duties,
6. avoid any personal financial bonuses, awards or other similar activities in the Company’s partner organizations, without the written permission of the executive body of the Company,
7. not provide any paid services to other bodies without the written permission of the executive body of the Company, taking into consideration the limitations of the RA legislation,
8. act as a member of the board of directors, the executive body or as other official of another organization only with the written permission of the executive body of the Company,
9. refrain from any action which may include the risk of arising conflict of interest,
10. immediately inform the supervisor in case of arising of the risk of conflict of interest for discussing and solving the problem,
11. if the possibility of arising conflict of interest between other employees is known, remind the colleague about their duty to notify the immediate supervisor.

Criteria for managers’ professional operations and ethics

The manager, when conducting its activities, must be guided by the following ethical standards:

1. Reasonable caution and diligence: managers are obliged to carry out their professional activities reasonably careful, consistent and diligent,
2. Independence and objectivity: when carrying out their professional activities, the managers are obliged to invest all reasonable efforts for ensuring their independence, objectivity and drawing a fair conclusion.
3. Priority of clients’ interests: managers are obliged to act in the interests of their clients by prioritizing the clients’ interests from personal, Company or third parties’ interests.
4. Professional competence: managers must constantly improve their professional knowledge and skills.
5. Following the rules: managers are required to follow the provisions of the law, regulations and professional ethics rules, if any, and refrain from any violation of ethical and moral character.

The manager should be guided by the following professional standards:

1. Reasonable and objective representation. The manager is obliged to:
   • provide a reasonable basis for investment activities,
   • clearly distinguish facts from opinions, by underlining the predictions,
   • present the analyzes / conclusions clearly and logically in order to avoid any incorrect interpretation,
   • prepare analytical materials with professional diligence,
   • invest all reasonable efforts to verify the correctness and reliability of information from foreign sources,
   • refrain from granting written or oral guarantees about the investment results,
   • show caution and sanity when using the materials prepared by third parties, indicate the author's name, publication or source of such information,
   • refrain from statements that may mislead the customers,
   • present the clients fair, accurate, complete and timely information about the investment activity.
2. Prevention and disclosure of conflict of interest. The manager is obliged to:
   • take all necessary measures to avoid conflicts of interest that may damage the their independence and objectivity,
   • avoid transactions that may be subject to conflict of interests between them and the client. In case it is impossible, give priority to clients’ interests,
   • disclose to customers and to employer all the relevant factors (including their own investments in securities) that could damage their independence and objectivity,
   • take adequate measures to prevent conflict of interest between them and the clients, as well as a variety of clients, clients and their managed funds or two different funds. If it is impossible, must take adequate measure to reduce them,
   • inform the Company's chief executive about pressure on them when performing their duties.
3. Loyalty to clients. The manager is obliged to:
   • Prioritize clients interest from theirs,
   • Refrain from business relations, that may affect their independence, objectivity and can lead to loosing loyalty to customers,
   • protect the confidentiality of information received from clients.
4. Trading. The manager is obliged to:
   • refrain from unfair use of inside information during trading securities,
   • in case of new investment possibilities, have the same approach towards all funds, and if that investment complies with all rules, than place the group of orders or the distribution of results according to the requirement of Company’s internal regulation and legislation.
   • invest all efforts to make investments complying to fund’s rules, implement appropriate actions concerning the best price and the best conditions for the fund.
5. Risk management and compliance. The manager is obliged to
   • follow Company’s policies, regulations and procedures and develop them for the Company’s compliance with RA legislation, prudential legal demands and to other principles and standards defined by the regulation,
   • assist the employee of the Company when monitoring and managing the claims of customers,
   • keep records about the transactions in accordance with Company internal legal acts,
   • contribute to the Company's risk management system formation which needs to identify the risk management methods.

Personal transactions

1. Employees are required to report in cases provided in this chapter to the CEO of the Company the quarterly reports with contents acceptable for the Company about the following:
   • information on transactions performed during the reporting period made on their or affiliated person’s account,
   • information about securities on their securities’ accounts or on accounts of affiliated persons.
2. In addition to cases provided by the 1st point of this chapter, the reports defined by that point are provided within a period of 10 working days after qualifying as a reporting employee.3. Provided by this chapter, reporting employees are obliged to refrain from investing in classified securities for a time period of 30 calendar days after being classified, or for longer if defined in the list.4. The Company shall maintain a list of reporting employees. Within 2 working days of being included in the list, the duties deriving from employee’s position are to be presented.5. The Company shall maintain a list of classified securities, which needs to be reviewed at least in the following cases:
   • On the day of deciding to invest in new securities, but not later than prior making the investment in cases the executive thinks that the security needs to be classified.
   • The next working day of the expiry of the classification time of the corresponding security.
3. The Company must present to reporting employees the list of classified securities on the next day from its composition or review.

This Regulation shall enter into force on the date of registration by the RA Central Bank and will be repealed from the moment of withdrawal from the registration by the RA Central Bank.