CODE OF CONDUCT

At Trustmoore we act with integrity and purpose, empowering our people to deliver excellence and put the Client’s interests at the heart of every decision we make

MESSAGE FROM OUR CEO

At Trustmoore, our success is defined not just by what we achieve, but by how we achieve it. Our Trustmoore Values and Business Standards are more than just words on a page. They are the roadmap for everything we do.

To be on top of your game means more than personal excellence – it means having the courage to dare to be you while remembering that we only truly succeed when we score as a team. I empower each one of you to feel free to make it happen, provide we always act soundly and, above all, always put our client first.

Putting the client first is a commitment reflected in our rigorous Business Standards. We ensure our clients feel comfortable and respected in every interaction. We strive to secure the ultimate client experience by way of receiving tailored services and suitable advice that fits each client’s unique needs. We do that by providing clear information at every stage of our clients journeys, leading them to the ultimate experience of high-quality service without unreasonable barriers.

WOUTER PLANTENGA

Trustmoore’s Code

At Trustmoore we act with integrity and purpose, empowering our people to deliver excellence and put the Client’s interests at the heart of every decision we make. We achieve this by conducting business in a way that makes us proud to say we work at Trustmoore and makes our clients and partners proud to say they do business with us.

Our Code of Conduct is more than a manual – it is our compass. It guides us when the path ahead is unclear and ensures that we remain true to our values and standards even when faced with competing priorities. When policies and procedures don’t provide a specific answer, we seek guidance in our Code. It is designed to help each of us navigate conflicting demands with sound judgment and integrity. We each have a personal duty to live these principles every day, and we hold the same high expectations for every one of our employees.

We are all expected to promptly report any known or suspected violations of the Code, policies or procedures, or applicable laws and regulations. In such cases we should contact our direct manager, our local Human Resources or Compliance Function, or we can raise our concern directly via the dedicated reporting channel in HiBob.

We are transparent

Honesty is the cornerstone of the Trustmoore way – it is the foundation upon which all our values are built. We believe that true transparency is the only way to foster lasting trust with our clients, partners and all other stakeholders. We strive to build relationships based on mutual honesty, ensuring that expectations are clear and promises are kept. We don’t just ask if an action is legal, we ask if it is honest. By choosing transparency, we ensure that we are always acting soundly and living up to the Trustmoore Values.

The integrity test

“Is this communication or disclosure fully honest, providing a true and fair view without omitting critical information?”If the answer is ‘No‘, stop and reevaluate the message. To act soundly, ensure you are being clear before proceeding, as transparency removes suspicion and builds trust. If the answer is ‘Yes‘, communicate with confidence. This level of honesty is how we foster lasting business relationships and build trust in our employees.

We act with integrity

At Trustmoore, integrity is a core value of how we choose to conduct business – it is a non-negotiable standard that governs every action we take. Integrity means doing the right thing, even when it’s difficult. We are committed to strict adherence to the laws, regulations, and rules of every jurisdiction in which Trustmoore operates. In addition, we are committed to full compliance with our own policies and procedures, which we often set higher than the legal minimum. At Trustmoore, we do not engage in, or support any activities that attempt to bypass or undermine the spirit of the law, whether directly or indirectly.

It is important to understand the stakes. Integrity protects more than just our balance sheet, it protects our people (clients, partners, employees). Non-compliance is never worth the risk, as it can lead to loss of trust, severe financial loss, regulatory actions, or criminal sanctions, for both the company and the individuals involved.

The integrity test

“When facing a dilemma, ask yourself: Can I rationally expect everyone else to act the way I intend to act?”If the answer is ‘No‘, we at Trustmoore don’t do it.

We prevent financial crime

Financial crime is not a victimless offense, it represents a breach of existing laws and carries a profound social and economic toll, endangering the future of the communities and individuals we serve. At Trustmoore, we have zero tolerance for any and all forms of financial crimes. To protect our Clients and our integrity, we have implemented rigorous measures to prevent, detect, and respond to financial crime in all its forms. We remain alert to any activity involving bribery and corruption, money laundering, terrorist financing, and fraud.

We act in accordance with the spirit and the letter of the law. We don’t just aim to prevent financial crime, we aim to do what is right to ensure a safe and stable future for our stakeholders.

Trustmoore does not tolerate financial crime!

The integrity test

“Are you faced with a situation where you cannot identify the UBO, or you have knowledge that the client’s source of funds is linked to illegal activities, or you suspect fraudulent activity by an internal stakeholder?”If the answer is “Yes“, stop and report immediately to Compliance Function. It is your responsibility to act soundly and promptly signal for further investigation and actions that need to be taken.

We adhere to economic sanctions regimes

At Trustmoore, we recognize that Economic Sanctions are critical tools used by the international community to maintain global peace and safety. We strictly adhere to these measures to ensure our business activities do not undermine global security. Economic Sanctions have deep impact and are aimed at:

Preventing the support of regimes or organizations that violate fundamental freedoms
Encouraging nations to reform harmful foreign policies or behavior
Preventing the spread of nuclear weapons and other weapons of mass destruction
Using economic measures as a decisive alternative to military force

By complying with sanctions, we act soundly and ensure that our services are never used to facilitate activities that threaten international stability or human rights.

The integrity test

“The business relationship or transaction involves economic sanctions – individual/entity sanctioned, or there is a relation to sanctioned businesses/jurisdictions, etc.?”If the answer is “Yes“, stop and escalate. Do not proceed. To act soundly, we must flag this to the Compliance Function immediately for a full assessment.

We know how to manage conflicts of interest

At Trustmoore, we recognize that business and personal interests can occasionally overlap. Whether it involves family, friends, or outside professional roles, a conflict arises when these ties clash – or appear to clash – with the interests of Trustmoore. Even if the intentions are correct, the perception of a conflict may damage trust. Transparency removes suspicion. Therefore, we at Trustmoore disclose actual or potential conflicts of interest as soon as they arise. Conflicts are not always avoidable, nor are they strictly prohibited. However, they must always be properly managed. To protect our integrity and avoid poor decision-making, it is Trustmoore’s obligation to flag, assess, and mitigate every potential conflict of interest.

If you are unsure, disclose it. We would rather assess a situation that turns out to be fine than ignore one that puts the commitment to our values and standards at risk.

The integrity test

“Could a personal relationship, regardless of its nature, or outside interest, influence or appear to influence my professional judgement at Trustmoore?”If the answer is “Yes” or “I am not sure“, disclose immediately to Compliance Function. Transparency is the key. Flag the situation to your manager or the Compliance Function so the (potential) conflict can be assessed and addressed accordingly.

We are responsible for data management

At Trustmoore, we recognize that our clients, partners, and employees trust us with more than just information – they trust us with their privacy. “Putting our clients first” commitment means we guard this data with the highest level of integrity and care. We handle personal data responsibly, transparently, and in a strictly fair and lawful mange. We collect and use data only for specified, legitimate business purposes, and we never retain information longer than is strictly necessary to fulfil those needs. We never share personal information with unauthorized parties. To protect against loss or unauthorized access, we at Trustmoore apply rigorous technical and organizational security measures. We treat every piece of data as if it were our own, ensuring that our data management aligns with both the letter of the law and our own high internal standards.

Trustmoore handles (personal) data responsibly, transparently, with due care and in a fair and lawful manner!

The integrity test

“Am I assessing, sharing, or storing this (personal) data for a specified, legitimate business purpose and through authorized channels?”If the answer is “No” or “I am not sure” do not share the data. In case you are not sure, consult your manager, Compliance Function, IT, or Data Protection Officer to ensure you are following Trustmoore’s security controls.

We cooperate with regulators

At Trustmoore, we view our relationship with governments, regulators, and supervisors as partnership built on mutual respect and transparency. We are committed to maintaining a proactive and cooperative dialogue with all authorities. This commitment covers every possible touchpoint, including: regular reporting and ongoing communication; answering ad-hoc queries or requests for documentation; being subject to on-site examinations, audits, or regulatory investigations. During our communication with the regulators/supervisors, we at Trustmoore take great care to ensure that all information provided is precise, complete, and verified. We respect the timeliness set by authorities, recognizing the prompt cooperation is a hallmark of a professional and well-run organization. We provide clear, honest answers, ensuring that we meet both the spirit and letter of the regulatory requirements.

By being open and cooperative, we protect Trustmoore’s reputation and ensure we remain a trusted participant in the global financial market.

Our North Star: Living the Trustmoore way

This Code is more than a policy, it is the living pulse of our corporate culture. It transforms our Trustmoore Values and Business Standards from abstract concepts into a daily practice of excellence. When you follow these principles, you are actively safeguarding Trustmoore client’s trust, Trustmoore employee’s well-being, and Trustmoore’s enduring reputation.

Every day, we choose to act in a way that protects our clients, our partners, our employees, and our reputation. When in doubt, don’t just ask if it’s legal, ask yourself:

“Does it fit Trustmoore Values?”
“Does it serve the client’s best interest?”
“Would I expect everyone else to act this way?”