Employees are expected to comply with all provisions of this Code. This Code will be strictly enforced, and violations will be dealt with immediately, including subjecting the employee to corrective and/or disciplinary action, including without limitation, dismissal or termination.
Situations that may involve a violation of ethics, laws, or this Code may not always be clear and may in some cases require difficult judgment.
Employees who have concerns or questions about violations of laws, rules or regulations, or of this Code, should report them to their immediate supervisor. If the concerns involve accounting, internal controls and auditing matters, such concerns may also be reported by employees on a confidential and anonymous basis to the Chief Executive Officer.
Following receipt of any complaints submitted hereunder, the case will be investigated as reported and a final report will be made to the collective shareholder partnership of Axiom Asset Management (the “Partnership”). The Partnership will have primary authority and responsibility for the enforcement of this Code.
AXIOM GROUP encourages all officers and employees to report promptly any suspected violation of this Code to the Chief Executive Officer. AXIOM GROUP will tolerate no retaliation for reports or complaints regarding suspected violations of this Code that were made in good faith.
Open communication of issues and concerns without fear of retribution or retaliation is vital to the successful implementation of this Code. AXIOM GROUP will take such disciplinary or preventive action as it deems appropriate to address any violations of this Code that are brought to its attention.
This Code will be circulated to all employees of AXIOM GROUP on an annual basis and whenever changes are made. New directors, officers and employees will be provided with a copy of this Code.