Code of Business Ethics

Introduction, including our affiliates and related   entities, is committed to maintaining the highest level of public trust   and confidence. Alpesh Patel has earned a reputation for fairness,   honesty, and integrity, and considers this to be our most valuable corporate asset. We recognize that our reputation hinges on the adherence of our employees to the highest standards of ethical behaviour and professionalism in the performance of their duties, without which   our history of accomplishments would not have been possible.

The Code of Business Ethics and Employee Conduct (the “Code”) sets   forth a summary of the common standards we have established for the   Company, its managers, and employees. The Code is designed to promote   the values and principles it embodies and to deter any wrongdoing. The   Code is crucial in ensuring that our employees – as well as the public at   large – are aware of the standards we have set for ourselves. All   employees are personally responsible for compliance with the Code, and   failure to comply with its provisions is grounds for disciplinary   action, which may include dismissal, and referral to the relevant   governmental authorities and other regulatory bodies, where appropriate.   Regarding any course of conduct not specifically addressed in the Code,   employees are instructed to consult their supervisors or an appropriate   representative of the Legal or Compliance Departments, but ultimately,   they are responsible for using good judgment and acting in a manner   consistent with the spirit, principles, and values embodied in the Code.

Governing Laws & Regulations

Alpesh Patel’s objective is to provide our clients with the utmost in value   and client service and to maximise their forex trading experience.   Notwithstanding these objectives, the Company places legal and   regulatory compliance above profits. In our business conduct, we must   always be in compliance with applicable laws and regulations.

Core Ethical Values


Alpesh Patel realises that our success is based on the Company’s reputation   for integrity along with the public trust and confidence this   reputation has garnered. We respect the interests of our clients, honor   our commitments, and are forthright in promising only what we can   deliver.


Alpesh Patel is committed to treating those with whom we deal in the same   manner that we expect to be treated by others. We apply this approach in   a consistent, non-discriminatory manner; from our largest institutional   investors to our smallest account holders.

We compete aggressively in furtherance of our overall interests,   yet we do so fairly, ethically, and in a manner that fully complies with   all applicable laws and regulations, as well as the values and   principles embodied in this Code.

Our history of success has been achieved through honest business   competition. We do not seek competitive advantages through illegal or   unethical business practices. We endeavor to deal fairly with our   clients, service providers, other firms, and individual colleagues. We   oppose taking unfair advantage of anyone through manipulation,   concealment, abuse of privileged information, misrepresentation of   material facts, or any other unfair practice.


Alpesh Patel has a history of living up to the commitments and   responsibilities we have toward our clients, employees, service   providers, government authorities, regulators, other firms, the media,   and society. To our clients, we are committed to providing our products   and services in an efficient and innovative manner consistent with their   needs, and we offer a trading environment that is fast, reliable,   convenient, and valuable in terms of price and quality. To our   employees, we offer challenging positions in a professional and   collegial environment and equal opportunities for performance-based   professional development. To our service providers, we seek to build   mutually beneficial relationships, while promoting the Code’s principles   in the process. To our regulators, we strive to strictly observe and   comply with all relevant laws, rules, regulations, and standards of good   business practice. We do not sacrifice legal and regulatory compliance   for the sake of profits; rather, we offer the authorities and regulatory   bodies our cooperation and assistance toward the shared goal of   investor protection. To other firms, we are committed to respectable   business practices and to compete by providing superior products and   services. To the media, we offer our support in providing accurate and   objective coverage of our business. As a member of society at large, we   offer our support to many organizations and institutions dedicated to   social, charitable, educational, humanitarian, and cultural causes. We   are committed to remaining a responsible, law-abiding corporate member   of society.


Alpesh Patel invests tremendous resources of time, energy, and expense into   developing the superior forex products and services that have earned us   widespread recognition as an industry leader in the online currency   market. As a result, our trading volume is virtually unrivaled in the   industry, and has enabled us to build strong execution relationships   with many of the world’s largest banks.

We value both innovation and experience in our personnel. Our   executives and employees possess a wealth of experience in the foreign   currency markets, and many have been involved as pioneers in online   foreign exchange since the inception of the industry. We are uniquely   qualified in our field.


Reliability is the hallmark of Alpesh Patel and the products and services   we offer. The Company provides a 24-hour multilingual support network   that includes sales, dealing, administrative, and technical support, 7   days a week. Our goal is to give clients peace of mind in the knowledge   that they can depend on us, thereby freeing them to dedicate more   attention to their individual investment strategies.

Core Professional Values: Business Practices

Regulatory Compliance

Alpesh Patel acknowledges the importance of all relevant laws, rules,   regulations, policies and standards�whether internal or external�and   complies with them. We are committed to strict management discipline and   a first-class control and compliance environment.


It is Alpesh Patel’s policy that the information in our communications be   full, fair, accurate, timely, and understandable. This policy applies to   communications with government authorities, regulators, employees,   clients, and the media. All employees involved in our disclosure process   (including upper-level management) are responsible for acting in   furtherance of this policy. In particular, these individuals are   required to maintain familiarity with applicable disclosure   requirements, and they 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 independent   auditors. Those engaged in a supervisory role over our disclosure   process have an obligation to discharge their duties with diligence.

Books & Records

Alpesh Patel records in a complete, accurate, and timely manner, all   transactions and obligations on our client accounts. We maintain systems   of internal accounting controls designed to ensure the reliability and   adequacy of our client account records, and the regulatory reports they   generate. We maintain records for the period required by applicable laws   and regulations.


Alpesh Patel is committed to an independent, robust internal and external   audit process to supplement our operational processes and to help us   identify and address any relevant accounting, internal accounting   controls, or auditing matters. Our managers cooperate fully with our   auditors to reach and implement solutions in an efficient and timely   manner.


Alpesh Patel maintains appropriate instruments to control and monitor the   transfer of confidential and sensitive information within and, as far as   possible, outside the Company on a need-to-know basis. We do not   deliberately disclose non-public information concerning our business,   our clients or our employees, unless in connection with the delivery of   services to our clients, upon request of our clients, or as required to   do so by law.


Alpesh Patel strives to maintain an open and transparent dialogue with our   clients and others, based on fairness, mutual respect, and   professionalism.

Risk Management

Alpesh Patel advises clients to engage in conscious, disciplined, and   intelligent risk taking. For our part, we are guided by the principle of   adherence to the appropriate legal and regulatory frameworks as well as   the instruments, procedures, and managerial approval processes to   monitor, control, and manage the risks to which we are exposed.

Anti-Money Laundering

Money laundering is the process by which persons or businesses   attempt to conceal the origin and ownership of the proceeds of illegal   activity such as fraud, theft, drug trafficking, or any other crime.   Money laundering may also involve the use of legitimately derived funds   to finance terrorism. Various financial products and transactions,   including those related to the foreign exchange market, may be involved   in money laundering schemes. Accordingly, we are aggressive in not   allowing the Company to be used as a vehicle for such activity. Money   laundering is a criminal offense and can subject its perpetrators and/or   facilitators to substantial criminal and civil sanctions, including   imprisonment and fines.

To ensure compliance with anti-money laundering laws and   regulations, Alpesh Patel has implemented policies and procedures to detect,   prevent, and report money laundering or other suspicious activity.

Continuous Improvement

While this Code does not create legally binding obligations on   Alpesh Patel, nor does it confer legal rights to our employees or others, we   actively review our past performance and strive to adhere to the   principles and values included herein.

Core Professional Values: Employment Practices

Alpesh Patel’s Commitments to Employee Excellence & Equal Opportunity

Alpesh Patel seeks to create and maintain a professional environment   designed to attract, develop, and retain outstanding people. We offer   equal opportunities, irrespective of race, national origin, ancestry,   gender, sexual orientation, religion, age, physical disability, medical   condition, or pregnancy. We will not tolerate any form of unlawful   discrimination, harassment, retaliation, or retribution. Employees are   instructed to consult the Employee Manual for our complete harassment   policies and reporting procedures.

Competitive Reward System

Alpesh Patel offers a performance-based culture, with a corresponding   competitive reward system and periodic fair and objective evaluations   that take into account personal contribution to our overall efforts, as   well as adherence to the values and principles set forth in this Code.   Our partners and managers maintain an open-door policy designed to give   each and every employee easy access to management.


We assess whether violations of this Code have occurred and, if so,   determine whether or not disciplinary measures should be taken against   the violator and others involved in the wrongdoing. Disciplinary   measures may include, but are not limited to, counseling, oral or   written reprimands, warnings, probation or suspension without pay,   demotions, reductions in compensation, termination of employment,   restitution, and legal action.

We may waive application of the Code in certain limited situations.   Any waivers of Code provisions may be granted only in exceptional   circumstances, upon management review. An employee who believes that a   waiver may be called for is instructed to discuss the matter with our   General Counsel and/or Chief Compliance Officer.

Employee Responsibilities


Each employee of Alpesh Patel is personally responsible to abide by all laws,   rules, and regulations, as well as the internal policies of Alpesh Patel,   including the principles and values embodied in this Code. These   responsibilities include being familiar with the laws, rules,   regulations, guidelines, manuals, and emerging best business practices   relevant to their duties, and implementing them to the best of their   abilities.

Client Focus

We actively seek to distinguish ourselves from other firms in the   area of client service. We expect and encourage our employees to foster a   client-focused approach, and to treat our clients with utmost courtesy,   professionalism, and respect.


We expect our employees to embrace teamwork and to contribute their best efforts toward reaching common goals.


We expect our employees to act at all times in good faith, with due   care, competence, credibility and diligence, and without any   misrepresentation of material facts.


During the course of their service, employees may be provided   access to information regarding our clients, trade practices, systems,   marketing or strategic plans, fees and revenues, and other knowledge   considered proprietary by Alpesh Patel or our clients. Employees are not   permitted to disclose or use, either during or subsequent to their   employment with Alpesh Patel, any such information they receive or develop,   except for authorised business purposes or where legally mandated. This   includes, but is not limited to, information stored on any computer   system as well as proprietary software developed by Alpesh Patel.

Any employee who possesses confidential information has an   important responsibility to keep that information confidential, and to   disclose such information internally only on a need-to-know basis.   Employees must be discreet with confidential information and avoid   communicating confidential matters in ways that are susceptible to   interpretation or use by third parties.

Conflicts of Interest

Personal conflicts of interest arise when employees face a choice   between their personal interests (financial or otherwise) and those of   the Company. Conflicts of interest may call into question the Company’s   integrity as a whole. Accordingly, an employee’s service to the Company   may not be subordinated to personal gain and advantage. All employees   are expected to act in the Company’s best interest. Any employee in a   position where his or her objectivity may be questioned because of an   individual interest or family or personal relationship should consult   his or her supervisor or an appropriate representative of the Legal or   Compliance Departments. Similarly, any employee aware of a material   transaction or relationship that could reasonably be expected to give   rise to a personal conflict of interest should promptly discuss the   matter with a supervisor or Legal or Compliance Officer.

Outside Employment

Employment and participation in other activities outside the   Company could interfere with an individual’s duties as an Alpesh Patel employee.   Service by any employee as a director, trustee, or officer (paid,   unpaid, elected, appointed, or otherwise) of any business other than   Alpesh Patel requires written approval from the Legal or Compliance Departments.   Unless given specific permission, service by any employee on a board or   in an advisory position with other firms in the foreign currency   industry, and particularly with any of our clients, is not allowed.

Reporting Violations

Alpesh Patel’s policy is that our employees must report violations of laws,   rules, regulations, or this Code internally so that such matters can be   properly addressed. We encourage reporting to be done directly to the   relevant supervisors and appropriate representatives of the Legal and   Compliance Departments or, where appropriate, directly to higher levels   of management in accordance with the policies and procedures detailed in   the Employee Manual. Reports may be made on a confidential, anonymous   basis. In case of violations by senior employees and partners, such   reports should be made to an appropriate representative of the Legal or   Compliance Departments. The Company prohibits retaliation against any   employee for such reports made in good faith.

Insider Trading

All directors, officers and employees are prohibited from:

  • buying or selling Alpesh Patel’s securities at any time when in possession   of material, non-public information (including transactions in   securities held through employee benefits plans, such as 401 (k) plans);
  • buying or selling securities of any other company at any other time   when in possession of material, non-public information obtained as a   result of the employment or relationship of the director, executive   officer or employee of the Company;
  • disclosing material, non-public information to any other person,   including spouses, relatives, friends, co-habitants or business   associates, who then trades in securities or passes the information on   further (“tipping”) or starting rumors related to material, non-public   information;
  • engaging in short-term investment activities or “day-trading” of Alpesh Patel’s securities;
  • engaging in “short-selling” of Alpesh Patel’s securities (i.e. selling   Alpesh Patel’s securities that such person does not own and borrowing such   securities to make delivery);
  • buying or selling puts, calls, options or similar company-based derivative securities, including for hedging purposes.

Generally, information is “non-public” if it has not been effectively   made available to investors generally, and information is “material” if   there is a substantial likelihood that a reasonable investor would   consider it important in making a decision to buy, sell or hold a   security or where it is likely to have a significant effect on the   market price of the security.  Both positive and negative information   may be material.  While it is not possible to compile an exhaustive   list, information concerning any of the following items will likely be   considered material:

  • quarterly or annual results;
  • guidance on earrings estimates and confirming such guidance on a later date;
  • mergers, acquisitions, tender offers, joint ventures, or changes in assets;
  • new products or discoveries;
  • developments regarding customers or suppliers, including the acquisition or loss of an important contract;
  • changes in control or in management;
  • changes in compensation policy;
  • change in independent registered public accounting firm or   notification that the Company may no longer rely on such firm’s report;
  • change in independent registered public accounting firm or   notification that the Company may no longer rely on such firm’s report;
  • financings and other events regarding the Company’s securities   (e.g. defaults on securities, calls of securities for redemption,   repurchase plans, stock splits, public or private sales of securities,   changes in dividends and changes to the rights of security holders);
  • significant write-offs;
  • significant litigation;
  • bankruptcy, corporate restructuring or receivership;

The term “securities” should be broadly construed and shall include ,   but not be limited to, stock, preferred stock, debt securities, such as   bonds, notes and debentures, as well as puts, calls, options and other   derivative instruments.

The rules above apply to all directors, officers and employees,   regardless of whether they are located in the U.K, or abroad.  Violation   of these rules may expose Alpesh Patel and the director, officer and employee   to criminal and civil sanctions.  In addition, directors, officers and   employees who involve themselves in the prohibited transactions listed   above are subject to immediate termination.  It should be noted that   persons subject to the Code may not violated the rules above even   indirectly.  Accordingly, you should assume that your family members may   not take any actions which are prohibited from taking.

Alpesh Patel has adopted a securities trading policy entitled “Policies and   Procedures for Trading in Securities of Alpesh Patel Ltd. by Directors,   Executive Officer and Access Employees”.  Each director, executive   officer and Access Employee (as defined in such policies and procedures)   should read such policies and procedures in their entirely and refer   back to them periodically for additional guidance.

If you have any doubts as to the propriety of any transaction, you   should seek advice from the General Counsel’s office before undertaking   the sale or purchase of any Alpesh Patel or other securities.

Honesty & Fair Dealing

We expect our employees to act at all times in good faith, with due   care, competence, credibility and diligence, and without any   misrepresentation of material facts.

Each employee shall endeavor to deal with the Company’s customers,   competitors, suppliers and employees.  No employee shall take unfair   advantage of anyone through manipulation, concealment, abuse of   privileged information, misrepresentation of material facts or any other   unfair practice.

No bribes, kick back or other similar payments in any form shall be   made directly or indirectly to or for anyone for the purpose of   obtaining or retaining business or obtaining any other favourable   actions well as potential civil or criminal liability for violation of   the code.

Alpesh Patel Opportunities

It is the Company’s policy that directors, officers and employees may   not (i) take opportunities for themselves that are discovered through   the use of Company property, information or position or (ii) use Company   property, information or position for personal gain.  Furthermore,   employees may not compete with the company, directly or indirectly.    Employees have a duty to the Company to advance its legitimate interest   when the opportunity to do so arises.


Theft, carelessness and waste have a direct impact on the Company’s   profitability. Employees have a duty to safeguard Company assets and   ensure their efficient use. Company assets should be used only for   legitimate business purposes, and directors, officers and employees   should take measures to ensure against their theft, damage or misuse.

Company assets include intellectual property such as patents,   copyrights, trademarks/branding, business and marketing plans, salary   information and any unpublished financial data and reports. Unauthorized   use or distribution of this information is a violation of Company   policy.