XXX公司业务行为准则Code of Business Conduct目录Table of Contents总则/General Provisions (3)合法合规/ Compliance with Laws and Regulations (4)利益冲突/Conflict of Interest (4)礼品与利益/Gifts and Favors (5)外部行为和董事任职/Outside Offices and Directorships (5)内幕信息/Insider Information (6)保密信息/Confidential Information (7)隐私权指引/Right to Privacy Guidelines (7)计算机系统安全/ Computer Systems Security (8)雇用实践/Employment Practices (9)环境/Environment (10)交易实践/Trade Practices (10)保险实践/Insurance Practice (10)及时沟通/Prompt Communications (10)外部人员与机构关系处理/Dealings with Outside Persons and Organizations (11)记录和报告/Records and Reporting (11)公司资金/Company Funds (12)遵守准则/Compliance with the Code (12)总则/General Provisions本准则广泛陈述了能使xxx（以下统称“XXX”）持续成为最佳诚信公司的商业行为和个人道德类型。
如大家所知，公司是所有员工行为的共同载体。
本准则提供了全体员工需遵守的正式行为指引。
The Code sets out, in very broad terms, the type of business conduct and personal ethics which is required of you in order for XXX (hereinafter ‘XXX’) to continue to be regarded as a company of the utmost integrity. As you well know, the company is a reflection of the conduct of all of us who manage its affairs. The Code is a means of providing formal guidelines on the behavior which is expected of all our staff.XXX在业务行为方面致力于达到法律和道德标准的最高准绳，希望成为并被认可为良好的企业法人和能够公平、公正地对待客户与员工的企业。
本准则的目的是帮助每一位员工了解应遵循什么样的行为方式，以及建立最低行为标准。
本准则适用于全体员工以及代理人员（以下统称“员工”）。
"直系亲属”包括配偶、父母、岳父岳母和子女。
所有员工要认真学习准则，依据准则行事，这样，XXX才能持续地获得广大客户与公众的普遍信任和信心。
XXX is committed to the highest level of legal and ethical standards in the conduct of its business and wishes to be and be known as a good corporate citizen and a company which deals fairly and equitably with its clients and employees. This Code of Business Conduct is intended to assist each member of the organization to know what is expected, and it sets out our minimum standards of behavior. The Code applies to all employees of XXX and agents (hereafter “employee”). The words “immediate family” includes spouse, parents and children. All employees are required to study the Code carefully and to be guided by its principles so that XXX may continue to earn the trust and confidence of its clients and the public at large.以下是本准则的基本原则：The following is the general provisions of the Code:1. 遵守当地法律法规和职业行为标准；We will comply with all applicable laws, regulations and professional conduct standards in every district in which we operate.2. 为客户提供高标准的服务，尊重他们的利益，力求通过我们的服务来满足客户需要；We will provide high standards of service to all of our customers, respecting their interests and aiming to meet their needs with the services we provide to them.3. 避免个人或财务的利益冲突，诚实道德地处理冲突并进行恰当披露；We will avoid personal or financial conflicts of interest and handle actual or perceived conflicts honestly and ethically, making all appropriate disclosure.4. 不会因为给予或接受客户、供应商及其他与我们打交道的人的任何优惠待遇而妥协；We will not be compromised through any preferential treatment given to or accepted from customers, suppliers or other people with whom we deal.5. 诚实、准确地与利益相关者沟通；We will communicate honestly and accurately with all of our stakeholders.6. 对我们所在地区的社会与经济做出贡献。
We will contribute to the social and economic wellbeing of the communities where we have operations.7. 公平对待员工，支持他们持续学习和不断发展。
We will treat our people fairly and support their ongoing learning and development.合法合规/ Compliance with Laws and RegulationsXXX及其员工必须遵守中国的法律法规。
XXX业务需遵守非常复杂及多变的法律法规，任何员工在无法确定法律法规的适用性和解释时，应从合规与运营风险部或法务部获得帮助。
XXX and its employees must comply with all laws and regulations governing XXX's business in China in which we operate. Our operations are subject to very complex and changing laws and regulations and, if an employee is in doubt about the application or interpretation of any legal and regulatory requirement, the matter should be referred to the Compliance & Operational Risk and Legal.利益冲突/Conflict of Interest员工需要注意，在其职权范围内采取的行动或做出的决定不能与XXX及其客户的利益相冲突。
Employees are required to see that actions taken and decisions made by them within their jurisdiction are free from the influence of any interest which might reasonably be regarded as conflicting with the interests of XXX and its clients.相应地，必须恪守以下原则：In this connection the following principles must be adhered to:1. 个人或外部活动不能直接或者间接与员工在XXX的职责相冲突。
因此，员工应该避免任何与其工作职责发生或可能发生利益冲突的情形。
Personal or outside activities must not conflict, either directly or indirectly, with an employee's duties to XXX. Employees should, therefore, avoid situations in which their personal interests conflict, or are likely to conflict, with their duties to XXX.2. 员工不得参与可能导致以下情形的XXX外部的个人、商业及投资活动：No employee should participate in a personal, business or investment activity outside XXX which would tend(1) 花费过多的时间和注意力从而无法以最佳状态为其在XXX的岗位服务；To create an excessive demand upon his or her time and attention and thus depriveXXX of his or her best efforts on the job; or(2) 造成利益冲突- 这是指，可能妨碍其做出对XXX利益最大化的独立判断的义务，利益或其他干扰事项。