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Conduct

Code of Conduct

At SJS Partners, capital is not simply deployed; it is structured. Our professional conduct is governed with the same discipline.

1. Foundational Philosophy

At SJS Partners, capital is not deployed; it is structured. Similarly, our professional conduct is not assumed; it is governed. This Code of Conduct sets the behavioral and ethical parameters for all directors, employees, contractors, and authorized representatives operating under the SJS Partners banner globally.

2. Fiduciary Duty and Client Primacy

We operate in complex capital markets where trust is the ultimate currency.

  • Client Best Interests: We prioritize the strategic and financial interests of our clients above the firm's proprietary interests.
  • Transparent Execution: We provide clear, unvarnished advice. We do not obscure risks or misrepresent the capabilities or execution timelines of our mandates.

3. Market Integrity and Insider Trading

As architects of corporate transactions, our personnel may possess Material Non-Public Information (MNPI).

  • Absolute Prohibition: Trading in any securities or financial products while in possession of MNPI is a criminal offense and is strictly prohibited.
  • Information Barriers (Ethical Walls): We enforce strict compartmentalization of sensitive deal information. Personnel assigned to specific advisory mandates are structurally isolated from platform administration and distribution teams unless formally wall-crossed by the Compliance Officer.

4. Anti-Bribery, Corruption, and AML/CTF

SJS Partners maintains a zero-tolerance posture toward financial crime.

  • Bribery and Facilitation Payments: We strictly prohibit the offering, promising, giving, or receiving of any illicit financial advantage, bribe, or facilitation payment to public officials or commercial counterparties.
  • Vigilant Gatekeeping: We execute rigorous Know Your Client (KYC) and Source of Funds checks. Personnel must immediately escalate any suspicious transactional behavior or complex, opaque structuring requests that lack commercial rationale.

5. Conflicts of Interest

All personnel must act decisively to avoid conflicts between personal interests, the firm's interests, and client obligations. Any potential conflict, including outside directorships, personal investments, or close relationships with counterparties, must be proactively declared, registered, and managed via the Compliance Committee.

6. Whistleblower Protection

Accountability is a shared burden. We actively encourage the reporting of unethical, illegal, or non-compliant conduct. SJS Partners guarantees strict confidentiality and protection against reprisal, discrimination, or disadvantage for any individual who reports a genuine concern in good faith under our Whistleblower Policy.

7. Enforcement

Compliance with this Code is a fundamental condition of employment and partnership. Material breaches will result in immediate disciplinary action, up to and including termination, cessation of partnership, and referral to the relevant regulatory and law enforcement agencies.