Ethics Code Assignment

GARP Code of Conduct

Adopted: February 26, 2007 Revised: June 23, 2010

June 23, 2010 GARP Code of Conduct

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I. Introductory Statement

The GARP Code of Conduct (“Code”) sets forth principles

of professional conduct for Global Association of Risk

Professionals (“GARP”), Financial Risk Management (FRM®)

and Energy Risk Professional (ERP®) certifications and other

GARP certification and diploma holders and candidates,

GARP’s Board of Trustees, its Regional Directors, GARP

Committee Members and GARP’s staff (hereinafter collec-

tively referred to as “GARP Members”) in support of the

advancement of the financial risk management profession.

These principles promote the highest levels of ethical con-

duct and disclosure and provide direction and support for

both the individual practitioner and the risk management

profession.

The pursuit of high ethical standards goes beyond

following the letter of applicable rules and regulations and

behaving in accordance with the intentions of those laws

and regulations, it is about

pursuing a universal ethical

culture.

All individuals, firms

and associations have an

ethical character. Some of

the biggest risks faced by

firms today do not involve

legal or compliance viola-

tions but rest on decisions

involving ethical considerations and the application of

appropriate standards of conduct to business decision

making.

There is no single prescriptive ethical standard that can

be globally applied. We can only expect that GARP Mem-

bers will continuously consider ethical issues and adjust their

conduct accordingly as they engage in their daily activities.

This document makes references to professional stan-

dards and generally accepted risk management practices.

Risk practitioners should understand these as concepts

that reflect an evolving shared body of professional stan-

dards and practices. In considering the issues this raises,

ethical behavior must weigh the circumstances and the

culture of the applicable global community in which the

practitioner resides.

II. Code of Conduct

The Code is comprised of the following Principles, Pro-

fessional Standards and Rules of Conduct which GARP

Members agree to uphold and implement.

1. Principles

1.1 Professional Integrity and Ethical Conduct. GARP

Members shall act with honesty, integrity, and compe-

tence to fulfill the risk professional’s responsibilities

and to uphold the reputation of the risk management

profession. GARP Members must avoid disguised con-

trivances in assessments, measurements and processes

that are intended to provide business advantage at the

expense of honesty and truthfulness.

1.2 Conflicts of Interest. GARP Members have a respon-

sibility to promote the interests of all relevant con-

stituencies and will not knowingly perform risk

management services directly or indirectly involving

an actual or potential conflict of interest unless full

disclosure has been provided to all affected parties

of any actual or apparent conflict of interest. Where

conflicts are unavoidable GARP Members commit to

their full disclosure and management.

1.3 Confidentiality. GARP Members will take all reasonable

precautionary measures to prevent intentional and un-

intentional disclosure of confidential information.

The pursuit of high ethical

standards goes beyond following

the letter of applicable rules

and regulations and behaving

in accordance with the intentions

of those laws and regulations,

it is about pursuing a universal

ethical culture.

GARP Code of Conduct[ ]

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2. Professional Standards

2.1 Fundamental Responsibilities.

• GARP Members must endeavor, and encourage

others, to operate at the highest level of profes-

sional skill.

• GARP Members should always continue to perfect

their expertise.

• GARP Members have a personal ethical respons-

ibility and cannot out-source or delegate that

responsibility to others.

2.2 Best Practices.

• GARP Members will promote and adhere to applica-

ble “best practice standards,” and will ensure that

risk management activities performed under his/her

direct supervision or management satisfies these

applicable standards.

• GARP Members recognize that risk management

does not exist in a vacuum. GARP Members commit

to considering the wider impact of their assess-

ments and actions on their colleagues and the wider

community and environment in which they work.

2.3 Communication and Disclosure. GARP Members

issuing any communications on behalf of their firm will

ensure that the communications are clear, appropriate

to the circumstances and their intended audience, and

satisfy applicable standards of conduct.

III. Rules of Conduct

1. Professional Integrity and Ethical Conduct

GARP Members:

1.1 Shall act professionally, ethically and with integrity

in all dealings with employers, existing or potential

clients, the public, and other practitioners in the

financial services industry.

1.2 Shall exercise reasonable judgment in the provision

of risk services while maintaining independence of

thought and direction. GARP Members must not offer,

solicit, or accept any gift, benefit, compensation, or

consideration that could be reasonably expected to

compromise their own or another’s independence and

objectivity.

1.3 Must take reasonable precautions to ensure that the

Member’s services are not used for improper, fraudulent

or illegal purposes.

1.4 Shall not knowingly misrepresent details relating to

analysis, recommendations, actions, or other profes-

sional activities.

1.5 Shall not engage in any professional conduct involving

dishonesty or deception or engage in any act that

reflects negatively on their integrity, character, trust-

worthiness, or professional ability or on the risk

management profession.

1.6 Shall not engage in any conduct or commit any act

that compromises the integrity of GARP, the (Financial

Risk Manager) FRM designation or the integrity or

validity of the examinations leading to the award of the

right to use the FRM designation or any other creden-

tials that may be offered by GARP.

1.7 Shall endeavor to be mindful of cultural differences

regarding ethical behavior and customs, and to avoid

any actions that are, or may have the appearance of

being unethical according to local customs. If there

appears to be a conflict or overlap of standards, the

GARP member should always seek to apply the higher

standard.

2. Conflict of Interest

GARP Members:

2.1 Shall act fairly in all situations and must fully disclose

any actual or potential conflict to all affected parties.

2.2 Shall make full and fair disclosure of all matters that

could reasonably be expected to impair their independ-

ence and objectivity or interfere with their respective

duties to their employer, clients, and prospective clients.

June 23, 2010 GARP Code of Conduct

3. Confidentiality

GARP Members:

3.1 Shall not make use of confidential information for

inappropriate purposes and unless having received

prior consent shall maintain the confidentiality of their

work, their employer or client.

3.2 Must not use confidential information to benefit

personally.

4. Fundamental Responsibilities

GARP Members:

4.1 Shall comply with all applicable laws, rules, and

regulations (including this Code) governing the GARP

Members’ professional activities and shall not knowingly

participate or assist in any violation of such laws, rules,

or regulations.

4.2 Shall have ethical responsibilities and cannot out-source

or delegate those responsibilities to others.

4.3 Shall understand the needs and complexity of their

employer or client, and should provide appropriate and

suitable risk management services and advice.

4.4 Shall be diligent about not overstating the accuracy or

certainty of results or conclusions.

4.5 Shall clearly disclose the relevant limits of their specific

knowledge and expertise concerning risk assessment,

industry practices and applicable laws and regulations.

5. General Accepted Practices

GARP Members:

5.1 Shall execute all services with diligence and perform all

work in a manner that is independent from interested

parties. GARP Members should collect, analyze and

distribute risk information with the highest level of

professional objectivity.

5.2 Shall be familiar with current generally accepted risk

management practices and shall clearly indicate any

departure from their use.

5.3 Shall ensure that communications include factual data

and do not contain false information.

5.4 Shall make a distinction between fact and opinion in

the presentation of analysis and recommendations.

IV. Applicability and Enforcement

Every GARP Member should know and abide by this Code.

Local laws and regulations may also impose obligations on

GARP Members. Where local requirements conflict with the

Code, such requirements will have precedence.

Violation(s) of this Code by may result in, among other

things, the temporary suspension or permanent removal

of the GARP Member from GARP’s Membership roles, and

may also include temporarily or permanently removing

from the violator the right to use or refer to having earned

the FRM designation or any other GARP granted designa-

tion, following a formal determination that such a violation

has occurred.

June 23, 2010 GARP Code of Conduct

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About GARP | The Global Association of Risk Professionals (GARP) is a not-for-profit global membership organization dedicated to preparing professionals and organizations to make better informed risk decisions. Membership represents over 100,000 risk manage- ment practitioners and researchers from banks, investment management firms, government agencies, academic institutions, and corporations from more than 195 countries. GARP administers the Financial Risk Manager (FRM®) and the Energy Risk Professional (ERP®) exams; certifications recognized by risk professionals worldwide. GARP also helps advance the role of risk management via comprehensive professional education and training for professionals of all levels. www.garp.org.