Code of Ethics and Business Conduct Covering Directors and Employees


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PREAMBLE

The basic responsibility of all employees and directors is to act in the best interest of NBIMC in directing its affairs, and to do so within applicable laws, regulations, and codes. NBIMC’s directors, officers, and employees have a relationship of trust with our stakeholders. It is imperative that there is no perceived violation of that trust, whether warranted or not, in the management of our business. These responsibilities can be summarized below into three basic duties that each NBIMC employee is charged with:

  • The duty of diligence: this is the duty to act reasonably, prudently, in good faith and with the best interests of NBIMC and its stakeholders;
  • The duty of loyalty: this is the duty to place the interests of NBIMC first, and not to use one’s position to further private interests. Confidentiality is also an important aspect of the duty of loyalty;
  • The duty of obedience: this is the duty to act within the scope of the governing policies of NBIMC and within the scope of other laws, rules and regulations that apply to NBIMC and any professional designation that has been specifically earned by an employee or director.

PURPOSE OF THE CODE

NBIMC is a fiduciary. Information to be collected under this code is collected so as to ensure accountability by NBIMC with respect to its fiduciary obligation and compliance by NBIMC of statutes, rules and other laws applicable to it and to fiduciaries generally.

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