Code of Ethics

Giza Singer Even Ltd. (henceforth “GSE” or “the company”) has an organizational culture that ensures a high level of professionalism while maximizing business results in both the short term and the long term.


All of this is done with a high level of awareness of the management of external and internal risks in order to protect the company and its reputation.


An organizational culture that fulfills these goals involves an ongoing process of organizational learning that includes setting of standards and rules of conduct, implementation of internal control, receipt of feedback, and learning of lessons.

Some of GSE’s activities are supervised by the Israel Securities Authority, and they are subject to its    directives and to the provisions of any relevant law, including the Securities Law, 1968 and the regulations enacted pursuant thereto and the Regulation of Investment Advice, Investment Marketing, and Investment Portfolio Management Law, 1995 and the regulations enacted pursuant thereto.

This code of ethics is part of the fabric of corporate governance and internal regulation at GSE.


The process of formulating high standards for managing the company involves emphasizing the responsibility of the company’s board of directors, its management, and its employees while maintaining principles of integrity; complying with the provisions of the law; accountability and transparency; loyalty to the company and appropriate representation; striving for excellence, leadership, innovation, and professionalism; maintaining human dignity and freedom; and protecting information.


In order to avoid company exposure and personal exposure to unnecessary risks, employees and all officers of GSE are required to read, to familiarize themselves with, and to implement what is written in the company regulations.


Every employee and manager has a high level of personal responsibility, and all are required to sign a document confirming that they have read and understood the regulations.


GSE’s vision is to be the leading company in its field, a powerful brand in the financial community that is highly service oriented, with excellent quality, and is committed to the community.


We believe that adoption of a code of ethics is a cornerstone for realizing our vision.


Below are the rules of conduct required by the code of ethics that applies to GSE managers and employees:


Rules of Conduct

The principles and rules of conduct are intended to guide us on appropriate and necessary conduct during routine work and at any time when there is a need to make a decision about dilemmas and disputes that arise as a result of a particular situation.


On certain issues, there are specific, binding procedures that define the required conduct.


These procedures are not meant to replace what is written below, but to expand and elaborate on it.


The rules listed below are binding on all employees, managers, and officers of GSE.


1. Obeying the Law


GSE is committed to acting in accordance with all the laws applicable to it anywhere that it operates, including the Basic Law: Human Dignity and Liberty, the Basic Law: Freedom of Occupation, labor law, companies law, money-laundering law, securities and anti-trust law, and any law, regulation, provision, or other directive to which its activity is subject.


Acting in contravention of the law is not acceptable no matter what the reasons.


If there is doubt and/or uncertainty regarding the restrictions applicable to a particular action, the CEO or the company’s legal advisors should be consulted.


2.  Loyalty to the Company and Appropriate Representation

We represent GSE in all of our actions, and the public’s perception of the company is directly related to its perception of the people in the company.


Employees should be careful to behave appropriately and to represent the company in a dignified manner, both inside and outside of the company’s offices and in any dealings on behalf of the company.


Comments about GSE or its activities are our real calling card and thus should conform with the spirit of the company.


Dignified representation is also measured by a neat, clean, and respectable appearance that is appropriate to the employee’s position and to the company.


Employees should dress in a manner appropriate to the business world, particularly during contacts with clients and with parties outside the company.


Any action that is not in accordance with the spirit of GSE and that adversely affects loyalty to the company or its reputation will be condemned, including misuse of the company name and company property; fraud; theft; bribery of any kind, whether of representatives of the public or private sector; extracting personal gain, whether by deliberate action or receipt of payment for services, even if it does not directly harm the company; improper business conduct; withholding or tampering with information and incomplete reporting that can, inter alia, harm the reliability of the reporting of the company’s financial results; use of information in a prohibited manner; action involving a conflict of interests with the company; and inappropriate behavior toward clients or toward any party with which contact is made by way of our activities at GSE.


3.  Striving for Excellence, Leadership, Innovation, and Professionalism


GSE aspires to provide its services and products to its clients in an optimal manner while working according to accepted standards and criteria and insisting on innovation, creativity, professionalism, and excellence.


The managers and employees of GSE and their knowledge are the company’s main asset, and therefore, the company will maintain and nurture them from a human and professional point of view while maintaining an organizational climate of joy in creating.


GSE believes in mutual learning and cross-fertilization, consultation, and assistance in carrying out the work in order to achieve the highest professional level as a company and as people.


GSE encourages openness, a supportive environment geared to learning, an open door policy for questions, and a conference table that is available for clarifying professional issues.


Mutual assistance and collaboration are essential for preserving leadership and professionalism.


Translation of the values enumerated here from theory into practice is the basis for implementation and realization of GSE’s values and goals.


4.  Achieving Goals while Maintaining Integrity

GSE is committed to achieving its business goals and objectives while maintaining appropriate conduct and integrity.


The company will act to make decisions and to use the tools at its disposal appropriately and in a manner that is measured, professional, and responsible while maintaining fairness, sincerity, transparency, accountability, honesty, and integrity, with the good of the company being the most important consideration.


GSE has adopted stringent norms of corporate governance and internal regulation beyond the requirements of the law, and it maintains a set of procedures and internal controls in order to ensure legal and ethical conduct and to identify and neutralize any dependence or concern about conflict of interests.


GSE places great importance on service characterized by availability, transparency, and clarity of conduct; listening; and fruitful dialogue, all while maintaining professionalism and integrity.


This approach can be seen in relations with our clients and with other parties such as investors and regulators, including the Israel Securities Authority, the anti-trust commissioner, the supervisor of banks, and the Finance Ministry’s Capital Markets Division.


An action based on extraneous considerations or a conflict of interests, or an action involving preference for personal interests or gain over the good of the company is in contravention of the spirit of the company.


5.  Maintaining Human Dignity and Liberty

GSE is committed to treating every human being with respect, fairness, and openness. The company’s strength lies in its ability to work as a team, with cooperation, mutual responsibility, mutual commitment, friendship, openness, equality, tolerance, patience, and synergy, in order to create a strong and durable chain linking all areas with which it deals.


Therefore, GSE will take all measures necessary in order to provide its employees with a work environment appropriate to their needs, including modifying physical conditions and maintaining the health of employees.


Violence of any kind, verbal or physical; discrimination against a person on the basis of gender, race, or religion, including an employee or an applicant for employment; an unequal approach among equals; oppression, insults, or any injury to a person by a company employee, whether at work or elsewhere, are strictly forbidden.


GSE will act in any way or means at its disposal to prevent such things among its employees, and will ensure compliance with the relevant law, including labor law.


GSE has a strict policy concerning prevention and dealing with sexual harassment.  Sexual harassment includes words and actions that are threatening or offensive or that could create a hostile work environment for an employee. GSE will take all measures against sexual harassment, in advance and after the fact.


6.  Maintaining Information Confidentiality and Insider Information

GSE is committed to protecting the confidentiality of the information to which it is exposed, whether the information relates directly or indirectly to any information concerning its clients or other parties, except in cases in which the law or the regulator permit or require the information to be revealed, or in which information is disclosed to conform to the professional and ethical standards to which the company is committed.


Confidential information concerning company employees, their families, and their private lives should not be disclosed, nor should private or business information concerning the company’s clients or third parties with which it has contact.


Appropriate measures should be taken to protect and maintain information in the company’s possession.


The company makes available to its employees information transfer and communications systems, including telephones and computers.


These systems should not be used for purposes other than company work, and in particular, for transferring materials whose transfer is prohibited by law or by contract.


Information that is based on intellectual property that was developed for the company or for which the company has guaranteed rights received from others will be used only for the benefit of the company.


All intellectual property rights that are derived from secret information or from other materials that have been created and developed by employees of the company belong exclusively to the company.


Any use of information that is not in the public domain, which has become known to the company’s managers and employees in connection with their position or their time in the company and is not the use for which the provision of information was intended, is prohibited.


Such prohibited use is, inter alia, use of information for any personal benefit, trading securities on the basis of insider information, negotiating in bad faith while concealing vital information or providing information to any party without the company’s knowledge.

7.  Social Responsibility and Contributing to the Community

GSE recognizes the importance of social responsibility and is committed to active social involvement in the community.


GSE contributes its resources to promote social goals as they are defined by it from time to time, and it encourages its employees to aid and contribute to the community.


8.  Implementing Rules of Conduct in Practice


Each of the managers and employees at GSE is obligated to read, to behave, to internalize, and to act in accordance with this code and in accordance with the procedures formulated in light of the code.


When a dilemma arises regarding the appropriate course of action, or in the event of a conflict between rules of conduct that represent different values, there are a number of criteria that are designed to help in making decisions regarding appropriate and optimal conduct:


    • Does the action contradict the values of the company as reflected in the rules of conduct derived from it?

    • Is the action likely to damage the company?

    • Are there alternatives to the action, what are they, and do they more faithfully serve the company?

    • Will the reason for the action remain justified with the test of time?

    • What would a person whom we respect think about the choice made?

    • How would we advise a person close to us to act in a similar situation?

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