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We trust that robust corporate citizenship and commitment to good governance principles are essential for our long-term development and success. We are dedicated to operating with integrity, contributing to the business communities, promoting diversity and inclusion, developing our talent capability, and being responsible stewards of natural resources. We are focused on the security of our data and safeguarding our clients’ privacy. We are certain that a conscientious approach to business strategy, corporate governance and responsibility could create mutual long-term benefits for our clients and stakeholders.
1. Purpose of the Principles
We believe that it is vital that enterprises manage their business with due consideration for the interests of stakeholders and improve their long-term business value. To achieve this goal, it is essential for the company’s corporate governance to function properly. We adhere high corporate governance rules in our investment and shall also seek the same degree of governance standard for firms held within of our portfolios. We fully believe that companies that adhere to these principles will operate their businesses autonomously in a way that benefits our clients’ interests and our enterprise value in the long run.
2. Compliance Management
We believe that firms may increase their long-term enterprise value by operating properly while adhering to the highest standards of compliance and corporate governance. Our “Compliance Management” approach serves as a foundation for our business to make sound decisions and take necessary actions. All aspects of LeadNorth’s corporate behaviour are observed with the Compliance Management under the relevant laws, society norms and internal rules and regulations.
3. Ideal Form of Corporate Governance
LeadNorth believes that in order to enhance the company's long-term value and protect the interests of the clients, the following corporate governance standards should be met:
• The Board of Directors shall has a sufficient number of qualified directors who can provide appropriate business decisions and lead the company to function effectively.
• The statutory auditors and the audit committee are competent to perform relevant audits on the business's activities and perform their duties efficiently.
• Where the Board of Directors has established committees to perform certain responsibilities, each committee must be comprised of qualified members and able to work independently. Specifically, the staff remuneration is well balanced and compatible with the long-term enterprise value creation and appropriate management incentives are always in place to reduce conflicts of interest.
• Corporate governance framework is in place to ensure adequate standards and controls in terms of compliance and internal audits.
4. Accountability through Disclosure
We constantly monitor and uphold the accountability of the company via proper and timely public disclosure. We shall release adequate disclosure and explanation, as well as remedial steps, in the case of any unlawful or inappropriate acts.
LeadNorth has a strong corporate culture that fosters the highest levels of ethics and compliance in our organisation. Our Code of Business Conduct and Ethics establishes the fundamental principles that govern the behaviour of our employees, officials, and directors. The Code oversees the management of conflicts of interest and corporate opportunities, forbids any illegal behaviour in the operations of the company. The Code demands all business affairs to be managed in line with ethical standards and applicable laws. All employees certify that they have read and agree to comply with the Code at least once a year.
Employees must report any violations of the Code, as well as any relevant law, rule, or regulation, to the Company. Any real or suspected code breaches, misbehaviour, misconduct or concerns may be reported confidentially to a Human Resources Manager or Compliance Officer. Retaliation in response to such reporting is strictly prohibited by LeadNorth.
LeadNorth is obligated to do business in a way that avoids conflicts of interest and the potential for improper influence. LeadNorth and all of its employees are expected to completely comply with Mauritius' anti-bribery, anti-corruption, and political donation laws, including but not limited to the Foreign Corrupt Practices Act, the Mauritius Anti-Bribery Act, and federal and state pay-to-play legislation and regulations. Employees are not permitted to give any money, gift, or donation, either directly or via intermediaries, for the purpose of securing or maintaining business for LeadNorth, or gaining an advantage in the conduct of any business. Any political contributions by employees to candidates for federal, state, and municipal office must be pre-approved and disclosed quarterly.
Employees must certify at least once a year that they have read and agree to abide by this policy.
LeadNorth has a structured information security programme in place which intended to build and maintain the privacy and data security to secure the company’s assets and sensitive third-party information (including personal information). This programme is controlled by a committee comprised of senior management personnel, which meets on a regular basis and reports to the Board of Directors at least once a year.
LeadNorth recognises the significance of safeguarding information assets such as personally identifiable information (PII) of our clients and employees and has implemented policies, supervision procedures and accountability structures, and technological processes to safeguard these data. All LeadNorth employees and vendors that have access to these data must yearly certify to information security rules and participate regularly security awareness training which prepare them for the proper management and reporting procedure in case of any possible privacy breach or data security issues.
LeadNorth’s information security measures includes internal and external resources geared to identify, protect, detect and recover from ant harmful acts of various cyber threats and attacks. LeadNorth employs monitoring tools and security services that are available 24x7x365 to ensure the confidentiality, integrity, and availability of firm assets and data. Regular internal and third-party assessments of procedures and technology are performed regularly to assess the effectiveness of privacy and data security management, with external independent audits undertaken at least once every two years.
LeadNorth monitors the best practices of data privacy and security, including an enhanced scrutiny on the sensitive data of third-party services providers. LeadNorth strives to monitor all the security controls and implement breach notification procedures, in occurrence of any data breach. LeadNorth also has a fully documented proprietary incident response plan and security strategy, with defined roles and duties that handle reporting requirements and processes, in the event of a data breach.
LeadNorth is committed to ensuring company continuity and resiliency. In the case of an emergency or natural disaster, we have established procedures, policies and processes in place to preserve clients data and protect all information of our employee and business.
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