Code of Conduct

The purpose of the Code of Conduct is to safeguard the trust that our investors and commercial partners have placed with all MV Credit entities. This is highly valued so by adhering to this code of conduct we also protect the interest of all MV Credit’s stakeholders whether it’s managing partners, directors, managers, employees, contracted consultants, and others acting on behalf of the firm as this promotes ethical awareness at all levels.

MV Credit expects all its employees to practice high ethical standards in their work and must, at all times, act in accordance with all relevant regulations, legislations and with the firm’s internal policies, procedures, and investment practices.

Discrimination, Harassment & Bullying

Bullying and harassment in the workplace are discriminatory acts which are unacceptable and unlawful. At MV Credit, we are committed to providing a working environment which is harmonious and acceptable to all.

Conflicts of Interest Policy

MV Credit pays due regard to the interests of clients and aims to always treat them fairly. The Firm has implemented systems and controls to prevent, identify, monitor, and manage conflicts of interest. Whilst MV Credit takes all appropriate steps to avoid conflicts of interest, this may not always be possible. In those instances, MV Credit will manage conflicts of interest fairly, both between itself (including its partners, staff and any person linked to the Firm directly or indirectly by control) and its client and between two or more clients. Any conflict of interest that cannot be resolved will be disclosed to the concerned investors.

MV Credit’s staff are required to take appropriate steps to identify conflicts and are required to notify the Compliance Officer immediately if they perceive there to be a (potential) conflict of interest.

Anti-money laundering and Counter terrorism financing and Corruption

MV Credit prohibits the offering, giving, solicitation or the acceptance of any bribe, whether cash or other inducement, to or from any person or company, wherever they are situated, and regardless of whether they are a public official, private person or company by any member of staff, agent or other person or body acting on MV Credit’s behalf in order to gain any commercial, contractual or regulatory advantage for MV Credit in a way which is unethical or in order to gain any personal advantage, monetary or otherwise, for the individual or anyone connected with the individual.

Inducement Policy

MV Credit will not pay or accept from any party any fee, commission or non-monetary benefit that relate to the provision of an investment service to a client unless a fee, commission or non-monetary benefit is designed to enhance the quality of the relevant service to the client and does not impair compliance with the Firm’s duty to act honestly, fairly and professionally in the best interests of the client.

Whistleblowing Policy

MV Credit is committed to maintaining the highest standards of honesty, openness and accountability and recognises that all members of staff have an important role to play in achieving this goal.

MV Credit takes all malpractice very seriously, whether it is committed by senior managers, staff, suppliers, or contractors. MV Credit has a whistleblowing policy which staff should follow to report their concerns.

Complaints Policy

MV Credit has implemented a Complaints policy which, in accordance with regulatory obligations, details the steps to be followed for handling clients claims.

Personal Trading Policy

Personal accounts dealing rules have been established in order to mitigate any conflicts of interest that may arise, for the prevention of market abuse and the misuse or improper disclosure of confidential information. All members of staff within the Firm are to ensure that they operate ethically and in the best interests of MV Credit and its clients.

Responsible Investment Policy

MV Credit has established an ESG policy describing its commitment and expectations as a responsible investor. The policy and associated guidelines set out different processes for considering environmental, social and governance factors and by assisting employees to make investment decisions on a more comprehensive and well-informed basis. MV Credit expects all its employees to act in accordance with this policy and guidelines.

October 2023

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