Guildwell expects its directors, employees, contractors and other people acting on behalf of a Group entity to act with integrity, professionalism and sound judgement.
The Group maintains conduct, conflicts and whistleblowing frameworks designed to support fair treatment, appropriate decision-making and the escalation of concerns where something does not appear right.
Conduct and ethics
Personnel are expected to:
- act honestly, fairly and professionally
- comply with applicable law, regulation and internal policies
- protect confidential and sensitive information
- treat clients and counterparties fairly
- act with due skill, care and diligence
- remain within their delegated authority and the approved scope of the entity for which they are acting
- avoid misleading statements about regulatory status, permissions or services
- escalate concerns where authority or regulatory scope is unclear
Commercial pressure, fees, commissions, personal relationships or business targets must not override legal, regulatory, compliance or client-protection obligations.
Conflicts of interest
Guildwell maintains arrangements to identify, assess, record and manage actual, potential and perceived conflicts of interest.
Conflicts may arise from personal, financial, professional, commercial, intragroup or client relationships.
They may also arise through relationships with issuers, investors, introducers, brokers, custodians, counterparties or other service providers.
Relevant personnel are expected to disclose conflicts and update those disclosures where circumstances change.
Where appropriate, a person may be required to step back from a decision or activity while the conflict is assessed.
Disclosure alone does not resolve every conflict.
Where a conflict cannot be adequately prevented or managed, the relevant activity, relationship or transaction may be restricted, reassigned, escalated or declined.
Material conflicts are disclosed to affected clients or counterparties where required.
Fees and incentives
Fees, commissions, referral arrangements and other economic interests can create conflicts.
Where relevant, these interests are identified and assessed under the applicable conflicts framework.
Remuneration and commercial incentives must not improperly influence communications, client treatment or decisions made on behalf of a Guildwell entity.
Confidential information
Personnel must protect confidential client, transaction, issuer, investor and commercially sensitive information.
Information must not be used for personal benefit, the improper benefit of another person, or an unauthorised Group purpose.
Information sharing between Group entities remains subject to the applicable privacy, confidentiality and entity-specific requirements.
Speaking up
Guildwell provides channels for employees, contractors, directors and other individuals working with a Group entity to raise concerns about suspected misconduct, unethical behaviour or regulatory breaches.
Concerns may include:
- breaches of law or regulation
- fraud, theft or misuse of funds
- conflicts of interest or corruption
- privacy or confidentiality violations
- client harm
- safeguarding or control failures
- accounting or recordkeeping irregularities
- concealment of incidents or complaints
- misconduct involving personnel or service providers
- retaliation against someone who has raised a concern
Reports should be made in good faith.
Whistleblowing channels
Guild Financial Ltd. / Guildwell Canada
Sparling Financial, Cayman Islands
whistleblower@sparlingfinancial.com
A person raising a concern is not required to report first to someone who is implicated in the matter.
Where a conflict exists, the concern may be escalated through an appropriate non-conflicted governance channel.
Confidentiality and protection from retaliation
Guildwell seeks to handle whistleblowing reports confidentially and restrict information to those who need it for assessment, investigation or response.
Retaliation against a person who raises a concern in good faith is not permitted.
Reports are assessed according to their nature and seriousness, and may result in investigation, remediation, disciplinary action or regulatory reporting where required.
Entity-specific accountability
Each Guildwell entity remains responsible for the conduct, conflicts and whistleblowing obligations applicable to its own activities.
Shared personnel, systems or Group policies do not transfer regulatory responsibility from the entity conducting the relevant activity.