This Policy applies to CoinShares Asset Management (”CSAM” or “the Company”), which is an affiliate of CoinShares International Limited (”CSIL”), and so forms part of the CoinShares Group (”the Group”).
This Policy applies to all CSAM Company Personnel (i.e. all employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers of the Company).
All Company Personnel will be required to read and understand this policy.
Queries on the content of this Policy should be addressed to the Compliance Officer in the first instance.
As legal and regulatory requirements change, this policy will be updated and Company Personnel advised of such changes.
The focus of this Policy is the conduct of the companies and Company Personnel in respect of bribery and corruption and not matters in respect of clients at higher risk of bribery and corruption such as Politically Exposed Persons.
CSAM is regulated in France by the Autorité des Marchés Financiers (“AMF”) under the Alternative Investment Fund Managers (“AIFM”) Directive for carrying on Management of AIFs within the meaning of Directive 2011/61/EU (AIFM Directive) and Portfolio management and Investment advice within the meaning of Directive 2004/39/EC (MiFID).
CSAM must comply with all applicable anti-bribery and corruption legislation including Article 17 of the French Sapin II Law (“Sapin II”) (“Anti-Bribery Laws”). Moreover, the Company complies with the Group Anti-Bribery and Corruption Policy.
The purpose of this Policy first and foremost to act as a tool for the internal communication of the procedures and practices that must be followed with regards to preventing bribery and corruption.
The primary objectives of this Policy is to ensure that:
CSAM, in accordance with the relevant legislation, imposes personal obligations on Company Personnel, which include: