Corporate policies

Our policies and procedures are diligently implemented across our business from The Board of Directors to senior management to employees. We have clearly defined terms that are guided by our moral compass and ensure an honest, transparent and accountable environment.

Code of Conduct Policy
The Board of Directors has adopted a Code of Conduct Policy that outlines principles that the Board of Directors, senior management, and all employees (collectively, the “Arcapita Employees”) shall adhere to. The Code of Conduct Policy was adopted to promote honest and ethical business conduct at Arcapita. Arcapita Employees are required to have full loyalty to Arcapita and its operations and should conduct themselves with integrity, honesty, leadership, and professionalism in fulfilling their fiduciary responsibilities to Arcapita and its stakeholders, and to maintain full confidentiality with respect to any Arcapita confidential information. In addition, Arcapita Employees are required to avoid actual or potential conflicts of interest with Arcapita and to properly disclose and be transparent in any transactions involving Arcapita.

Insider Trading Policy
The Board of Directors has adopted an Insider Trading Policy that applies to all Arcapita Employees and all Arcapita Employees are required to certify in writing that they have read and understand such policy and agree to abide by its terms. The policy provides that, except with the prior written consent of the Chief Executive Officer, no Arcapita Employee who while acting for Arcapita Group obtains material non-public information which relates to any public company that Arcapita Group has invested in or is considering investing in (“Public Company”), may buy or sell or otherwise deal in securities of such Public Company or otherwise misuse or disclose such information to any person within or outside Arcapita Group, other than those persons who need to know such information on a case-by-case basis.

Whistle-blower Policy
The Board of Directors has adopted a Whistle-blower Policy that applies to all Arcapita Employees to encourage and provide a process for Arcapita Employees to raise any serious concerns regarding any wrongdoing or improper conduct at Arcapita and a reassurance that they will be protected from possible recriminations if they have made a good faith disclosure in connection with such concerns.

Anti-Money Laundering Policy
The Board of Directors has adopted a comprehensive Anti-Money Laundering Policy to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the financing of terrorist or criminal activities. Arcapita will not establish a relationship with, or conduct a transaction for, a customer (i) whose funds appear to be the proceeds of or involved with illegal activity, (ii) whose identity or legitimacy cannot be satisfactorily established and (iii) who fails to provide information which is necessary to comply with the policy. All Arcapita Employees who handle customer transactions, or who are managerially responsible for such transactions, participate in Anti-Money Laundering training on an annual basis.