This Code of Conduct (“Code”) applies to all executive and non-executive directors, officers, and employees and contractors (collectively “Officers”) of GIL and its subsidiaries.

GIL is committed to delivering strong returns and shareholder value while also promoting shareholder and general market confidence in the company.

The objectives of the Code are to ensure that:

  • high standards of corporate and individual behaviour are observed by all employees in the context of their employment  with GIL;
  • Officers are aware of their responsibilities to GIL under their contract employment and always act in an ethical and professional manner; and
  • Officers, shareholders, suppliers, clients or competitors are dealt with in a manner consistent with the Code.

Officers should always use due care and diligence when fulfilling their role or representing GIL and should not engage in any conduct likely to bring discredit upon GIL. GIL currently does not employ any staff internally and has appointed the Manager to manage GIL. The Manager will adhere to GIL’s Code of Conduct in addition to its own.

Officers should, amongst others:-

  • Act honestly and in good faith at all times and in a manner which is in the best interests of GIL as a whole.
  • Not take advantage of property, information or position or opportunities arising from their position as an employee for personal gain or to compete with GIL.
  • Not participate in any investments which are offered or arranged by GIL where it might pose a conflict of interest. In any case, the investment should comply with GIL’s Share Trading Policy.
  • Restrict the use of non-public information (whether specific to GIL or entrusted to it by others) except where disclosure is authorised or legally mandated.
  • Not make improper use of any information acquired by virtue of being an employee, including the use of that information for personal gain or the gain of another party in breach of a person’s privacy.
  • Trade in securities, including trading in shares of GIL, in accordance with GIL’s Share Trading Policy.
  • Always deal with shareholders, clients, customers, suppliers, competitors and other officers in a manner that is lawful, diligent and fair and with honesty, integrity and respect.
  • Ensure that GIL’s assets are protected and only used for authorised and legitimate business purposes.

GIL actively promotes and encourages ethical behaviour and protection for those who report violations in good faith.