Corporate ethics and code of conduct for the company's directors and employees

Introduce

Stratos Markets Limited, including its affiliates and related companies, is committed to maintaining the highest standards of public trust. Gold Elephant Ltd has built a reputation for fairness, honesty and integrity. We believe this is our most valuable asset. We recognize that our reputation is built on adhering to the highest standards of ethical conduct and professionalism in the performance of our duties, without which we would not be as successful as we are today.

Our Code of Business Ethics and Conduct (“Code”) contains a summary of the standards we have developed to apply to our Company, its managers, and its employees. This Code is designed to promote good values ​​and prevent bad behavior. This Code is especially important to ensure that our employees and the public are aware of the standards we set for ourselves. All employees are appropriately personally liable under the Code, which serves as the basis for disciplinary action for violations, including termination. Be accountable to relevant government agencies and other regulatory bodies where necessary. For matters not specifically addressed in this Code, employees should consult with their manager or the appropriate legal or compliance officer. But most importantly, we have a responsibility to judge and act in accordance with the spirit, principles and values ​​expressed in this Code. .

Laws and regulations

Gold Elephant's goal is to maximize customer service value and enhance the foreign exchange trading experience. Despite these goals, the company still prioritizes legal and regulatory compliance over profits. Our business ethics require us to always comply with applicable laws and regulations.

Stratos Markets Limited is registered with the Financial Conduct Authority (“FCA”) in London under registration number 217689. Gold Elephant's FCA license is effective from 27 May 2003.

Stratos Markets Limited affiliates are also registered with the Commodity Futures Trading Commission (CFTC) as a Futures Commission Merchant (FCM) in the United States or hold an Australian Financial Services License (No. 309,763) issued by the Australian Securities and Investments Commission (ASIC). I'm doing it. , ARBN with ASIC is 121934432. In Paris, Gold Elephant France is registered with the Autorité de controle Prudentiel (ACP), a subsidiary of Stratos Markets Limited., Securities and Futures Commission (SFC) in Hong Kong.

Core ethical values

Authenticity
Gold Elephant recognizes that our success is based on our reputation for integrity and the trust and reputation of our communities. We respect our customers' interests and our company's promises, and provide guarantees as honestly as possible.

Authenticity
It is a general requirement to connect information to the public to ensure that it is not misleading or falsified. Gold Elephant believes that the need for honesty does not simply arise from the strictness of the law, but rather an enhanced investor protection philosophy that we strive to implement to ensure that customer contact information and promotional materials are truthful and complete. Complete and accurate information can help investors make informed decisions. Therefore, we prepare reports to avoid confusion or misunderstanding.

Fair
Gold Elephant is committed to treating all customers fairly. We apply this approach consistently and without discrimination, from the largest institutional investors to the smallest account holders.

We compete vigorously to advance our interests, ensuring fairness, ethics and compliance, while adhering to all legal regulations as well as legal values ​​and principles in this field.

Our history of success has been achieved through honest business competition. We do not seek competitive advantage through illegal or unethical business practices. We strive to treat our customers, service providers, other companies and individual associates fairly. We oppose the manipulation, concealment, misuse of privileged information, misrepresentation of material facts, or other unfair practices to disadvantage anyone.

Responsibility
Gold Elephant has a history of commitment and responsibility to its customers, employees, service providers, government agencies, regulators, other companies, the media and society. We are committed to providing our customers with a fast, convenient and valuable business environment while delivering products and services in an efficient and innovative manner that meets their needs. The company's employees are provided with challenging positions in a professional work environment and equal opportunities to achieve professional results based on their performance. With regard to service providers, we seek to build mutually beneficial relationships based on the law. For regulatory agencies, we strive to comply with all applicable laws, rules, regulations and business practice standards. We do not sacrifice legal and regulatory compliance for profit; instead, we support and cooperate with authorities and regulators seeking to protect investors. Like any other business, we are committed to pursuing a respected and competitive business practice by providing better products and services. We help provide the media with accurate and objective information about our business. As part of society as a whole, we support many social, charitable, educational, humanitarian and cultural organizations. We are committed to being responsible and law-abiding members of society.

Capacity
Gold Elephant has become widely recognized as a leader in foreign exchange online exchanges by investing significant time, energy and money in developing premium foreign exchange products and services. As a result, our trading volume is almost always the largest in the online foreign exchange markets, which has allowed us to build strong relationships with some of the world's largest liquidity providers, including global banks, financial institutions, manufacturers and other market makers. .

We appreciate the creativity and experience of our employees. Our CEO and staff have extensive experience in the foreign exchange markets, many of whom have been pioneers in the online currency trading industry since its inception. We are qualified and experienced in our field.

Trust
Reliability is a hallmark of Gold Elephant and the products and services we provide. The company offers a multilingual support network 24 hours a day, 5 days a week, including sales, sales, management and technical support. Our goal is to give our clients peace of mind with our services so they can focus more on their personal investment strategies.

Core Professional Values: Business Practices

T Compliance

Gold Elephant recognizes the importance of and compliance with all applicable laws, rules, regulations, policies and standards, whether internal or external. We are committed to strict and disciplined management, the highest level of control and compliance. As an FCA registered company, Stratos Markets Limited must meet stringent financial standards, including capital adequacy or financial resource requirements. We are also required to submit periodic financial reports to domestic and foreign regulatory authorities. These standards are strictly enforced by the FCA, which has the power to fine companies or terminate their regulatory status for breaches.

Professional knowledge

Gold Elephant performs due diligence to ensure that its clients' transactions comply with all laws, rules and regulations. Gold Elephant has adopted a Customer Identification Program, also known as the Customer Identification Policy, which documents procedures for capturing, verifying and recording information to accurately identify individuals. All employees must comply with the Customer Identification Program and Customer Identification Policy policies and procedures.

Information

It is Gold Elephant's policy to ensure that company communications are complete, fair, accurate, timely and understandable. This policy applies to our communications with government agencies, regulators, employees, customers and the media. All employees (including senior management) participating in the disclosure process are responsible for implementing this policy. In particular, these persons must maintain knowledge of applicable disclosure requirements and, through material events, knowingly misrepresent or omit information or knowingly misrepresent or omit information to any other person inside or outside the Company, including independent members of the Company. It is forbidden. auditor. Those participating in an oversight role in the disclosure process have an obligation to take their duties seriously.

Make a list and keep records

Gold Elephant records and maintains complete, accurate and timely records of all transactions required for its clients' accounts. We maintain a system of internal accounting controls designed to ensure the reliability and completeness of our customer account records and related reports. We will retain records for as long as required by applicable laws and regulations.

Examination

Gold Elephant is committed to independent, high-quality internal and external audit processes that complement the Company's operations and help the Company identify and resolve related issues such as accounting, internal accounting controls or auditing. Company managers will cooperate fully with the Company's auditors to identify and implement solutions in an effective and timely manner.

Security

Gold Elephant maintains, as necessary, appropriate tools to control and monitor, to the greatest extent possible, the transmission of confidential and sensitive information within and outside the Company. We do not disclose non-public information related to our business transactions, customers or employees, except in connection with: According to customer's request; or as necessary to resolve legal matters

Transparent

Gold Elephant promotes open and transparent dialogue with clients and stakeholders based on fairness, mutual respect and professionalism.

Crisis Management

Gold Elephant encourages clients to increase awareness, discipline and insight into risk management. We follow compliance principles within the appropriate regulatory framework, as well as key management tools, procedures and processes to monitor, control and manage risks.

Anti-Money Laundering

Money laundering is a process by which individuals or businesses attempt to conceal the source and ownership of funds obtained through illegal activities such as fraud, theft, drug trafficking, or other illegal activities. Money laundering can also involve using legitimate funds to finance terrorism. A variety of financial products and transactions, including those involving foreign exchange markets, are more likely to be involved in money laundering schemes. Therefore, we firmly do not allow ourselves to become a vehicle for money laundering activities. Money laundering is a criminal offense. You may be a direct perpetrator and/or sponsor of money laundering activities and, depending on the severity, may be subject to imprisonment or fines.

To comply with anti-money laundering laws and regulations, Gold Elephant has implemented policies and procedures to detect, prevent, and report money laundering or other suspicious activity.

Continuous innovation

Although this Code is not a legal obligation for Gold Elephant, we actively review past performance and strive to adhere to the principles and values ​​of continuous innovation.

Core Professional Values: Employment

Gold Elephant’s Commitment to Employee Qualifications and Equal Opportunity

Gold Elephant creates and maintains a professional work environment to attract, develop and retain a highly qualified workforce. We provide equal opportunity regardless of race, national origin, ancestry, gender, sexual orientation, religion, age, disability, medical condition or pregnancy status. We will not tolerate any form of racism, harassment, retaliation, or retaliation. Company employees are directed to refer to our Compliance content for employees and managers to report policies and procedures related to this matter.

Reward System

Gold Elephant fosters a performance-based work culture through a corresponding competitive compensation system in which the contribution of individual accounts to the company's performance is evaluated fairly and objectively and periodically based on the values ​​and principles set out in this Act. Our partners and managers maintain an open-door policy designed to facilitate access and management of our employees.

violate

We will assess whether there have been violations of this law and, if so, determine whether disciplinary action should be taken against the violator and anyone involved in the violation. Disciplinary action may include, but is not limited to, counseling, verbal or written reprimand, warning, warning or suspension without pay, demotion, reduction in compensation, termination of contract, compensation and legal action.

The rules may be waived in certain circumstances. Exemptions from statutory provisions may apply in exceptional cases subject to management review. Exempt employees are instructed to discuss any violations with their attorney and/or the Company's Chief Legal Officer.

Employee Responsibilities

Follow

Each Gold Elephant employee is personally responsible for compliance with all laws, rules and regulations, as well as Gold Elephant's internal policies, including the principles and values ​​set forth in this Act. These responsibilities include understanding and implementing to the best of our ability the most appropriate laws, rules, regulations, guidelines, manuals and measures within the framework of the work being performed.

Customer Support

We strive to differentiate ourselves from others by continuously improving the quality of our customer service. We hope and encourage our employees to enhance their approach to our customers in the most focused manner and to take care of our customers in the most courteous, professional and courteous manner.

Teamwork spirit

We require our employees to practice good teamwork and contribute to the company's common goals to the best of their ability.

Authenticity

We expect our employees to always act with positivity, care, enthusiasm and reliability and to present facts accurately.

Security

In the course of providing services to our customers, our employees may be given access to information related to our customers, commercial activities, systems, marketing, strategic plans, commissions, revenues and other information. Any other information is considered proprietary information of Gold Elephant or its clients. Company employees are not authorized to disclose or use information received during or after employment with Gold Elephant except for permitted or legally authorized business purposes. This includes, but is not limited to, information stored on computer systems and proprietary software developed by Gold Elephant.

Employees with confidential information are responsible for keeping that information confidential and disclosing it internally only when necessary. Employees must be cautious with confidential information and avoid discussing sensitive security issues that could be misleading or making such sensitive information available to third parties.

Conflict of interest

Personal conflicts of interest increase when employees must choose between personal benefits and company benefits (financial or other benefits). Conflicts of interest can affect the integrity of the entire company. Therefore, an employee's employment cannot depend on his or her personal interests or merits. All employees are expected to act in the best interests of the company. Employees who have objective doubts about their position due to personal or family interests or personal relationships should consult with their manager or a member of the Legal Department. Likewise, employees who become aware of a material or relational transaction that may give rise to a potential personal conflict of interest should immediately discuss the matter with a supervisor or employee.

External Job

Participating in and engaging in non-company activities may interfere with the personal obligations of Gold Elephant employees. The services of officers such as directors, trustees, and employees (paid, unpaid, elected, appointed, etc.) in connection with Gold Elephant external business require official documentation from the Legal Department. Unless specifically authorized, Gold Elephant employees are prohibited from working in an official or consulting capacity with any other company in the foreign exchange industry, especially with permitted clients.

Protection and appropriate use of Gold Elephant assets

Theft, carelessness and waste have a direct impact on company profits. Employees have a responsibility to protect assets and use company assets effectively. Company assets may be used only for lawful business purposes. Directors, employees and workers must take steps to protect against theft, damage and abuse.

Company assets include intellectual property such as patents, copyrights, trademarks/trademarks, business and marketing plans, payroll information, and unpublished financial data and reports. Unauthorized use or distribution of this information is a violation of company policy.

Questions about laws and reporting violations

Employees are encouraged to consult with their supervisor if in doubt about the best course of action in a particular situation. Questions regarding application may be directed to your supervisor or Legal Department.

We encourage reports of violations of laws, rules, regulations or ordinances to be reported directly by the relevant supervisor and appropriate representative of the Legal Department or, as appropriate, directly to higher level management. Reports from employees and workers may be confidential and anonymous. If the violator is a director, officer or employee, this report must be made by the appropriate representative in the Legal Department.

In accordance with Gold Elephant's Whistleblower Policy, any employee may, at his/her discretion, (i) publicly, confidentially or anonymously report any questionable accounting, internal accounting controls or audits to the Audit Committee, General Counsel or the Legal Department Hotline; You can report it. problems, (ii) failure to comply with applicable legal and regulatory requirements or laws; or (iii) retaliate against employees and anyone who publicly questions accounting, internal accounting controls or auditing matters, in each specific case using the following means of communication: Currently available methods include:

Any interested party may report any suspicions regarding accounting, internal accounting controls or auditing matters, legal complaints or retaliation as specified above to the Audit Committee, General Counsel or the Legal Department hotline. These reports must be accompanied by the name of the person submitting the report.

All reports should be based on facts, not just speculation, and should include as much specific information as possible to enable an accurate assessment to be made. Additionally, all reports must include sufficient evidentiary information to support the investigation, including the name of the individual suspected of violating the law, the relevant facts of the violation, how the reporter learned of the violation, and previous steps taken. The Complainant has learned who may have been harmed or affected by the Breach and, to the extent possible, that the Breach has resulted in costs or damages to the Company resulting from the misrepresentation.

The above hotlines and websites are managed by an independent external service provider and any employee or other relevant party of the Company may make a report. Employees may submit reports anonymously and confidentially and do not need to disclose their names.

The hotline and service provider website above will explain to each reporter the procedures for following up their report (including those who may later provide additional information).

The Company prohibits retaliation against any director, officer or employee who reports honestly.