Forex Signs, Inc. (the "Company") is
committed to maintaining the highest level of public trust and confidence.
As a Commodity Trading Advisor, (CTA) we seek to earn a reputation
for honesty, fairness and integrity in the marketplace. Earning
the trust and confidence of our clients/traders is a priority and
our most valued corporate asset, which forms the basis of our
business success. It is recognized that earning this reputation
in the marketplace depends on our employees’ adherence to
the highest standards of behaving in both an ethical and professional
manner in conducting their duties.
The Forex Signs Code of Conduct (the "Code") sets forth common
standards for the Company, its partners, managers and employees. The
Code has been constructed and is designed to communicate and promote
the values and principles that Forex Signs embodies and to deter any
wrong-doing. The Forex Signs Code of Conduct is critical in setting
forth these values and principles in writing, so that our employees, as
well as the public at large, are fully aware of the standards we set
for ourselves and understand the importance of adherence to these
standards.
It is our expectation that all employees will assume personal
responsibility to comply with the Code, and any failure to comply with
the provisions of the Code is grounds for immediate disciplinary
action, which may include, but is not limited to: dismissal and
referral to relevant government authorities and/or other regulatory
bodies, as appropriate. Additionally, with regard to any conduct not
specifically covered by the provisions of the Code, employees are
instructed to consult their direct supervisors or an appropriate member
of the Legal or Compliance Departments, but ultimately all employees
are expected to act in good faith and to exercise good judgment in all
transactions, in a matter that is consistent and compliant with the
provisions of the Code and the values and principles that the Code
represents. In addition, all Forex Signs employees must recognize their
responsibility to protect our most valued corporate assets and to
maintain our reputation in the marketplace.
PRINCIPLES AND POLICIES
The Forex Signs, Inc. mission is to provide our customers with the utmost in
customer service and added value to our customers, enabling them to maximize
their foreign exchange trading experience while trading with us. However,
Forex Signs places a premium on legal and regulatory compliance above
all else and all employees must ensure that we remain in compliance with
applicable laws and regulations.
Forex Signs, Inc. is registered as a CTA with the National Futures
Association ("NFA"). The Company’s employees are expected to comply not
only with the Forex Signs Code of Conduct, but also with all applicable
laws and regulations.
ETHICAL STANDARDS
Forex Signs, Inc. realizes that ultimately our success is based
on the Company’s reputation for integrity, along with the
public trust and confidence in which this reputation is earned and
garnered. We respect the interests of our clients, honor our commitments,
and will always be honest and forthright in proposing to offer only
that which we can deliver to our customers. All employees are expected
to exercise integrity in all of our business dealings with clients,
as with affiliated and non-affiliated entities.
A general requirement of any National Futures Association (“NFA”)
member is that communications with the public may not be deceptive or
misleading. Forex Signs, Inc. believes that this imperative for
truthfulness does not stem solely from the language set forth in
regulations, but also due to our philosophy of increased investor
protection and confidence that requires we undertake every effort to
ensure that our client communications and promotional materials are
truthful and complete. Accurate and complete information enables
clients/traders to make intelligent investment decisions and, therefore
our statements are designed not to confuse, mislead or betray the trust
of our customers.
Equality
The Company is committed to treating our clients and all parties that
we interact with during the course of business in the same manner that
the Company would wish to be treated in all transactions and
operations. We apply this concept of fairness and equality to our
clients/traders by utilizing this approach in a consistent,
non-discriminatory manner, from the largest investors to our smallest
account holders, to ensure that we always uphold this important
principle.
We will compete in the marketplace in an aggressive manner in order to
fully pursue and further our overall interests and to fulfill our
mission, yet we will always do this in a manner that is fair, ethical
and that fully complies with our Code of Conduct and to all applicable
laws and regulations.
We do not, and will never, seek advantages over our competitors using
illegal or unethical means, and we endeavor to deal with each of our
clients, service providers, competitors, and individual colleagues in a
manner that is fair and ethical. We are strictly opposed to taking any
unfair advantage of anyone by manipulation, concealment, coercion,
fraud, collusion, and abuse of privileged information,
misrepresentation of material facts, or any other unfair and deceptive
business practices.
Dependability
Forex Signs seeks to consistently live up to the commitments and
responsibilities we have towards our clients, employees, service
providers, government authorities, regulators, competitors, the media,
and society. To our clients, we are committed and will seek to
continually provide all products and services in an innovative and
efficient manner that is consistent with their needs, with the highest
level of quality customer service. We will always provide a
comprehensive and easy to use trading environment that offers the
speed, reliability, convenience, and value that our customers need. We
also endeavor to deliver our products and services in a way that earns
customer confidence in transacting business with us.
To our employees, we will continue to offer challenging and rewarding
positions in a professional and collegial environment and base
professional development and advancement on merit alone.
To our service providers, we seek to build relationships that are
mutually beneficial and to collaborate with business partners to
provide our customers with the best possible customer service, while
promoting our Code of Conduct principles in the process.
To our regulators, we will pursue continued compliance with relevant
laws, regulations and standards of sound business practices, holding
these principles in the highest regard. We pledge not to circumvent our
legal and regulatory compliance for the sake of profits; rather we will
seek to cooperate with and uphold all compliance requirements to
provide our customers the shared goal of investor protection.
To our competitors, we are committed to competition through ethical and
respectful business practices while offering superior products and
services.
To the media, we offer our support in providing fair, accurate and
objective coverage of our business and business practices.
As a member of society at large, we at Forex Signs pledge to be good
corporate citizens and to offer our support to further the efforts of
quality organizations and institutions that are dedicated to serving
various social, educational, charitable, humanitarian and cultural
causes.
Continuous Improvement
Forex Signs, Inc. values both experience and innovation in our
personnel. While our Code of Conduct does not create legally-binding
obligations for the Company, nor does it confer legal rights to our
employees or to others, we will actively review our operating
performance and strive to adhere to the principles and values included
herein, while continually seeking efficient and effective ways to
improve upon our policies and procedures. We further pledge not to be
complacent in our efforts toward continuous improvement, in order to
remain competitive in the marketplace.
Reliability
Reliability is a key asset that sets Forex Signs apart in terms of its
products and services. Our goal is to create peace of mind for our
clients in the knowledge that they can depend on us, thereby freeing
them to dedicate more attention to their individual investment
strategies, while building confidence in our products and services.
Utilizing our trading platform, which combines both power and
functionality, investors will be able to make real-time, intelligent
investment decisions and we will provide the superior customer service
required to satisfy all of their investment needs.
ETHICAL PROCEDURES
Compliance
As our Code of Conduct defines, Forex Signs, Inc. acknowledges
the importance of all relevant laws, rules, regulations, policies
and standards – whether internal or external – and the
importance to comply with them. We are committed to strict management
discipline and to a first-class internal control and compliance
environment. We have established compliance and control department
and all employees are expected to consult with the compliance department
on specific compliance matters if any such inquiries should arise
during the normal course of business with our clients, service providers,
government authorities, regulators or the media.
Information Transmission
It is the
Company’s policy that the information in all of our communications be
full, fair, accurate, timely, relevant, and understandable. This policy
applies universally to all Forex Signs communications with government
authorities, regulators, employees, clients, and the media. All of our
employees involved in disclosure processes and procedures (including
upper level management) are responsible to set the proper tone in
furtherance of this policy. In particular, upper level management are
required to maintain familiarity with applicable disclosure
requirements, and are prohibited from knowingly misrepresenting,
omitting, or causing others to misrepresent or omit material facts to
others, whether within or outside the Company, including our internal
auditors and external independent auditors. Those engaged in a
supervisory role over our disclosure processes and procedures have an
obligation to conduct their duties with diligence and to report any
issues of non-compliance with these policies to the compliance and
control department immediately.
Audits
Forex Signs, Inc. is committed to an independent, robust internal and
external auditing process to supplement our operational processes and
to help us identify and address any relevant accounting procedures,
internal accounting controls or auditing matters. Kwangho Lee, CPA,
1270 Broadway, Suite 205, New York, NY 10001 has been engaged to
provide specialized accounting and audit services with a focus on
complex forex transactions. Our managers are expected to cooperate
fully in compliance with the auditing process with our auditors in
order to develop and implement solutions in an efficient and timely
manner.
Privacy Policy
Forex Signs, Inc. maintains appropriate technology and
controls in place to monitor the transfer of confidential and sensitive
information internally and, to the extent possible, provide sensitive
information outside of the Company on a need-to-know basis. We do
not deliberately disclose confidential, non-public information concerning
our clients, our business, or our employees unless it is in conjunction
with legal requirements or while providing services to our clients
or by our clients’ specific request. For further details,
please see our
privacy policy.
Transparency
Forex Signs, Inc. strives to maintain an open and transparent dialogue
with each of our clients and others, based on mutual respect, fairness,
professionalism and by acting in good faith.
Risk Management
Forex Signs, Inc. apprises its clients as to the risks of investing in
the forex market and will always suggest they engage in conscious,
disciplined and intelligent risk-taking in regard to their investment
activities. For our part, we are guided by adherence to all appropriate
legal and regulatory compliance requirements and the implementation of
policies and procedures to monitor, control, mitigate and manage those
risks to which we are exposed to as part of our day-to-day business
activities.
Anti-Money Laundering
To ensure compliance with anti-money laundering laws and regulations,
Forex Signs, Inc. has implemented policies and procedures to detect,
prevent and report money laundering or other suspicious activities or
unauthorized transactions in client accounts.
Forex Signs complies with the International Money Laundering Abatement
and Anti-Terrorist Financing Act of 2001, which is Title III of the USA
Patriot Act; as well as CFTC regulations thereunto. This minimizes the
risk of customers who engage in foreign exchange market with regard to
money laundering activities. Our procedures for identification are
outlined in our {name of Open an Account} section, where you will find
information about Forex Signs’ banks and clearinghouses, regulatory
bodies and account opening policies and procedures.
Read more about the
USA Patriot Act
EMPLOYMENT POLICIES
Forex Signs, Inc. seeks to create and maintain a professional
environment from which to attract, develop and retain outstanding
personnel who can excel based on their own merit and performance in the
workplace. We are fully committed to Equal Employment Opportunity, and
to attracting, retaining, developing and promoting the most qualified
employees regardless of race, gender identity, sexual identity, age,
disability, veteran status, or any other characteristic prohibited by
state or local law.
The Company endeavors to provide a
workplace culture that will promote advancement opportunities based on
merit, with a corresponding competitive reward system and periodic fair
and objective evaluations that take into account performance and
personal contribution to the Company’s overall efforts, as well as
adherence to the values and principles set forth in its Code of Conduct
and other policies as referenced in the Code. Our partners and managers
maintain an open-door policy designed to give each employee access to
management to freely communicate matters as they arise in the course of
business.
Breach of Policy
Forex Signs, Inc. will assess each case individually as to whether or
not any violations of its Code of Conduct have occurred, and to
determine whether of not disciplinary actions should be imposed upon
the violator, and any/or others involved in the alleged violations of
policy. Disciplinary actions may include, but are not limited to the
following: oral or written reprimand, counseling, warning, probation or
suspension without compensation, demotion, reduction in compensation,
termination of employment, restitution, and legal action against the
violator(s).
We may waive application of the Code of Conduct in certain, limited
situations. Any waivers of the Code provisions may be granted only in
exceptional circumstances, upon management review and any waivers are
solely at its discretion. An employee who believes that a waiver may be
justified is instructed to appeal his or her matter and discuss the
concern with our General Counsel in the Legal Department and/or Chief
Compliance Officer in the Compliance Department.
Accordingly, an employee’s service to the
Company may not be subordinated to any of the employee’s personal
interests, whether or not it is intended to further any personal
gain or advantage. All employees are expected to act in the Company’s
best interest at all times. Any employee who questions his/her objectivity
or who believes he or she may be questioned because of an individual
interest or a family or personal relationship, should immediately
consult with his or her supervisor or escalate the matter directly
to the attention of the appropriate representative of the Legal
or Compliance Department. Additionally, any employee aware of any
material transactions or relationships that could reasonably result,
or be expected to result, in a conflict of interest should promptly
discuss the matter with a supervisor or the appropriate representative
of the Legal or Compliant Department. Any failure to do so will
result in immediate disciplinary action taken against the employee
upon discovery.