Capital Asset Management Limited HK is committed to the highest standards of integrity. This statement sets out our approach to anti-bribery, anti-corruption, and the identification and management of conflicts of interest.
1. Zero tolerance for bribery & corruption
We prohibit bribery and corruption in all forms, whether direct or indirect, and whether involving the public or private sector. Our staff and representatives must never offer, promise, give, request or accept any bribe or improper advantage.
2. Gifts & hospitality
Gifts and hospitality must be reasonable, proportionate, transparent, and never intended to improperly influence a business decision. Gifts of cash or cash equivalents are not permitted. Material gifts and hospitality must be recorded and, where required, pre-approved.
3. Facilitation payments
We do not make or accept facilitation payments.
4. Identifying conflicts of interest
A conflict of interest arises where our interests, or those of our staff, compete with a duty we owe to a client, or where we owe competing duties to different clients. Examples include personal relationships, outside interests, personal account dealing, and inducements.
5. Managing conflicts
- We maintain arrangements to identify, prevent and manage conflicts so that clients are treated fairly.
- Where a conflict cannot be avoided, we manage it through information barriers, independent oversight, or disclosure to the affected client.
- Staff must promptly declare any actual or potential conflict.
6. Personal account dealing
Staff personal dealing in digital assets is subject to policies designed to prevent misuse of information and conflicts with client activity.
7. Reporting & whistleblowing
Staff and third parties are encouraged to report suspected bribery, corruption or unmanaged conflicts. Reports can be made in good faith without fear of retaliation to info@custodyprimo.com.
8. Training & oversight
We provide regular training and maintain oversight and record-keeping to ensure ongoing compliance with this policy.
This document forms part of the CustodyPrimo terms that govern your use of our services. It should be read together with our other disclosures. If any provision conflicts with our Terms & Conditions, the Terms & Conditions prevail. We may update this document from time to time; the current version is always published on this page.