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Steward Code of Conduct

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  STANDARDS CODE OF CONDUCT FOR EMPLOYEES

  The work rules and standards of conduct for Steward Capital are important, and the Company regards them seriously. All employees are urged to become familiar with these rules and standards. In addition, employees are expected to follow the rules and standards faithfully in doing their own jobs and conducting the Company’s business. Please note that any employee who deviates from these rules and standards will be subject to corrective action, up to and including termination of employment (see Section 3.12, Corrective Action).

  While not intended to list all the forms of behavior that are considered unacceptable in the workplace, the following are examples of rule infractions or misconduct that may result in disciplinary action, including termination of employment.

  • 1. Theft or inappropriate removal or possession of property;
  • 2. Falsification of timekeeping records (See Section 5.2, Timekeeping);
  • 3. Working under the influence of alcohol or illegal drugs (See Section 4.6, Substance Abuse);
  • 4. Possession, distribution, sale, transfer, or use of alcohol or illegal drugs in the workplace (See Section 4.6, Substance Abuse);
  • 5. Fighting or threatening violence in the workplace;
  • 6. Boisterous or disruptive activity in the workplace;
  • 7. Negligence or improper conduct leading to damage of company-owned or customer-owned property;
  • 8. Insubordination or other disrespectful conduct;
  • 9. Violation of safety or health rules;
  • 10. Smoking in the workplace;
  • 11. Sexual or other unlawful or unwelcome harassment (See Section 4.3, Harassment, Including Sexual Harassment);
  • 12. Excessive absenteeism or any absence without notice (See also, Section 4.1 Attendance/Punctuality and 4.2, Absence without Notice);
  • 13. Unauthorized use of telephones, or other company-owned equipment (See Section 4.4, Telephone Use);
  • 14. Using company equipment for purposes other than business (i.e. playing games on computers or personal Internet usage);
  • 15. Unauthorized disclosure of business “secrets” or confidential information;
  • 16. Violation of personnel policies; and
  • 17. Unsatisfactory performance or conduct.
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  ATTENDANCE/PUNCTUALITY

  The Company expects that every employee will be regular and punctual in attendance. This means being in the office, ready to work, at their starting time each day. Absenteeism and tardiness places a burden on other employees and on the Company.

  The reporting time to work is 7:00am -7:30 am ( Mondays – Fridays) and 9:00am - 9:30am (Saturdays).

  If you are unable to report for work for any reason, notify your supervisor before regular starting time. You are responsible for speaking directly with your supervisor about your absence. It is not acceptable to leave a message on a supervisor’s voice mail, except in extreme emergencies. In the case of leaving a voice-mail message, a follow-up call must be made later that day. The company phone number is 0303 964 690. Should undue tardiness become apparent, disciplinary action may be required.

  If there comes a time when you see that you will need to work some hours other than those that make up your usual work week, notify your supervisor at least seven working days in advance. Each request for special work hours will be considered separately, in light of the employee’s needs and the needs of the Company. Such requests may or may not be granted.

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  ABSENCE WITHOUT NOTICE

  When you are unable to work owing to illness or an accident, please notify your supervisor. This will allow the Company to arrange for temporary coverage of your duties, and helps other employees to continue work in your absence. If you do not report for work and the Company is not notified of your status, it will be assumed after two consecutive days of absence that you have resigned, and you will be removed from the payroll.

  If you become ill while at work or must leave the office for some other reason before the end of the workday, be sure to inform your supervisor of the situation and check out with the receptionist.

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  HARASSMENT, INCLUDING SEXUAL HARASSMENT

  Steward Capital is committed to providing a work environment that is free of discrimination and unlawful harassment. Actions, words, jokes, or comments based on an individual’s sex, race, ethnicity, age, religion, or any other legally protected characteristic will not be tolerated.

  If you believe you have been the victim of harassment, or know of another employee who has, report it immediately. Employees can raise concerns and make reports without fear of reprisal.

  Any supervisor who becomes aware of possible harassment should promptly advise their supervisor or the Human Resources Representative who will handle the matter in a timely and confidential manner.

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  TELEPHONE USE

  Steward Capital’s telephones are intended for the use of serving our customers and in conducting the Company’s business. Personal usage during business hours is discouraged except for extreme emergencies. All personal telephone calls should be kept brief to avoid congestion on the telephone line.

  To respect the rights of all employees and avoid miscommunication in the office, employees must inform family members and friends to limit personal telephone calls during working hours. If an employee is found to be deviating from this policy, he/she will be subject to disciplinary action (See Section 3.12, Corrective Action).

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  PUBLIC IMAGE

  A professional appearance is important anytime that you come in contact with customers or potential customers. Employees should be well groomed and dressed appropriately for our business and for their position in particular.

  As a world class investment bank, dressing to work should be strictly formal. Ladies are to note that, all straight dress and skirt should at all material times be longer that knee level. Each of us will be required to wear the Steward Capital prescribe dress code which will consist of:

  The following are the Guidelines for Steward Weekly Dress Code

  Mondays:	White Top / Shade of Blue Top (e.g. Light Blue Top, Sea Blue or Navy Blue Top) with Blue black, black or grey trousers or skirt.
  Tuesdays:	White Top / Shade of Blue Top with Blue black, black or grey trousers or skirt
  Wednesday:	Also known as Easy Wednesday - Steward branded T-Shirt / Polo Top with the company logo embroidered on it or Any formal attire, but colours shouldn’t be Green, Red, Black Top, or any other colour strong colour.
  Thursday:	White Top/ Shade of Blue Top with Blue black, black or grey trousers or skirt.
  Friday:	Steward branded T-Shirt / Polo Top with the company logo embroidered on it or any prescribe cloth provided by management.

  NB: All Prescribed Steward Attire as referred to in respect of Wednesdays and Fridays will be provided and worn with blue black trousers or skirt (for ladies) (Monday - Friday) and with blue or black jeans on casual days (Saturdays and service holidays).

  Staff are expected to wear appropriate footwear – either black shoes or brown shoes at all times. Ladies are required to wear a minimum of Two Inch Heel shoe.

  The following items are considered inappropriate working attire for Steward Capital:

  • Open-toed sandals
  • Spaghetti-strapped shirts
  • Tank tops or revealing shirts
  • Short mini skirts
  • Sheer clothing
  • T-shirts with inappropriate or offensive gestures or advertising
  • Other inappropriate items may be added later.

  When meeting with a client, the dress code is more business-oriented, including attire such as:

  • Slacks and dress shirt or blouse
  • Dress or skirt and blouse

  If management occasionally designates "casual days," appropriate guidelines will be provided to you. Consult your supervisor if you have any questions about appropriate business attire.

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  SUBSTANCE ABUSE

  The Company is committed to providing a safe and productive workplace for its employees. In keeping with this commitment, the following rules regarding alcohol and drugs of abuse have been established for all staff members, regardless of rank or position, including both regular and temporary employees. The rules apply during working hours to all employees of the Company while they are on Company premises or elsewhere on Company business.

  The manufacture, distribution, possession, sale, or purchase of controlled substances of abuse on Company property is prohibited.

  Being under the influence of illegal drugs, alcohol, or substances of abuse on Company property is prohibited.

  Working while under the influence of prescription drugs that impair performance is prohibited.

  So that there is no question about what these rules signify, please note the Following definitions:

  Company property: All Company owned or leased property used by employees.

  Controlled substance of abuse: Any substance listed in Schedules I-V of Section 202 of the Controlled Substance Act, as amended.

  Drug: Any chemical substance that produces physical, mental, emotional, or behavioral change in the user.

  Drug paraphernalia: Equipment, a product, or material that is used or intended for use in concealing an illegal drug, or otherwise introducing into the human body an illegal drug or controlled substance.

  Illegal drug:

  • a. Any drug or derivative thereof whose use, possession, sale, transfer, attempted sale or transfer, manufacture, or storage is illegal or regulated under any federal, state, or local law or regulation.
  • b. Any drug, including – but not limited to – a prescription drug, used for any reason other than that prescribed by a physician.
  • c. Inhalants used illegally.

  Under the influence: A state of not having the normal use of mental or physical faculties resulting from the voluntary introduction into the body of an alcoholic beverage, drug, or substance of abuse.

  Consistent with the rules listed above, any of the following actions constitutes a violation of the Company’s policy on drugs and may subject an employee to disciplinary action, up to and including immediate termination.

  Using, selling, purchasing, transferring, manufacturing, or storing an illegal drug or drug paraphernalia, or attempting to or assisting another to do so, while in the course of employment.

  Working or reporting to work, conducting Company business or being on Company property while under the influence of an illegal drug or alcohol, or in an impaired condition.

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  TOBACCO PRODUCTS

  The use of tobacco products is not permitted anywhere on the Company’s premises.

  The use of tobacco products is not permitted anywhere on the Company’s premises except in authorized and designated locations. The designated smoking areas are located (will be inserted when appropriate locations are identified). Employees must follow all rules posted in designated smoking areas and adhere to all policies associated with this policy (See Sections 3.6, Break Periods and 3.14, Safety).]

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  INTERNET USE

  Steward Capital employees are allowed use of the Internet and e-mail when necessary to serve our customers and conduct the Company’s business.

  Employees may use the Internet when appropriate to access information needed to conduct business of the Company. Employees may use e-mail when appropriate for Company business correspondence.

  Use of the Internet must not disrupt operation of the company computer network. Use of the Internet must not interfere with an employee's productivity. Employees are responsible for using the Internet in a manner that is ethical and lawful.

  Internet messages are public and not private. Steward Capital reserves the right to access and monitor all files and messages on its systems.