SmartWealth: Purposeful Capitalism

Responsible Digital Financial Services

We share the believe that digital finance services should:
Be Responsible-ethical and ESG considerations should go along with business ones.
Be Inclusive-accessible and affordable for everyone.
Contribute to our collective wellbeing.

Promote the broader social goals of universal access to education, healthcare and other public infrastructure, especially affordable housing, efficient public transportation and reliable power supply.

DUE DELIGENCE

Experienced Investment professionals are involved in the design, development, due diligence checks-coding control procedures and ongoing oversight of all algorithms. The algorithms we use have a basis in generally accepted economic and financial theories.

Testing and control of algorithms are a separate function from compliance and internal audits. They are independently tested by risk professionals whose role is to challenge and advice those responsible for design and operation of the algorithms on an ongoing basis

CONSUMER ADVOCACY

We are advocates of retail investors. We provide and promote fair and transparent pricing. We act with the necessary care and prudence in our dealings with clients and ensure that our recommendations and actions undergo due diligence checks and have reasonable basis.

Our recommendations and actions must also pass a suitability test and we avoid all potential conflicts of interest and provide full disclosures on unavoidable ones. We believe this will engender trust, increase retail adoption of capital market products and services, and improve financial inclusion.

GOVERNANCE STRUCTURE

We follow a stringent and elaborate governance, review and supervisory procedure for the design, development, testing (validity and reliability), of all the software algorithms we use for our services: risk tolerance assessment, asset allocation, portfolio construction, security recommendation, trade execution, and portfolio management.

Ethics first

We strive to adhere to the highest professional & ethical standards, and business practices in our dealings with clients and partners. And we take up a fiduciary responsibility towards our clients, acting solely in their best interests.

We adopt the Code of Ethics (COE) & Standards of Professional Conduct (SOPC), the Research Objectivity Standards (ROS), the Global Investment Performance Standards (GIPS), and the Asset Manager Code of Professional Conduct (AMCOPC) of the CFA Institute. These standards along with the local regulatory requirements guide all of our activities

We ensure that the algorithms, projections and simulations we use are robust and have a sound methodology. And we make sure that the analytical approach used by our algorithms including assumptions about correlations and different market circumstances are consistent. We give due consideration to the following factors in our use of algorithms: transaction costs and termination fees, tax implications-and if so, cost basis of each asset, level of risk appropriate for user-especially if they have limited financial knowledge, and finally, risk tolerance when making security recommendations. Plain language description of our algorithms are available on request.

We follow a robust risk & incident management framework-policies & procedures, reporting and taking remedial actions. Our security and privacy standards are geared towards ensuring that user information is safe and used only for authorised purposes. We only aggregate and share information required to provide service to meet clients’ stated objectives. We follow a rigorous data encryption process (as well as authentication, authorisation and access control). We also have a business continuity and 3rd-party risk contingency plan. The technological, operational and market risks we are exposed to are carefully monitored and managed

We implement an information security program-written policies and procedures, personnel training and user education. We have in place a strategy to prevent, detect and respond to cybersecurity threats and continually assess threats, vulnerabilities and the defensive measures that we currently have in place. We provide clear trading and fee related disclosures and we conduct a periodic and systematic review and evaluation of the quality of execution received from brokers. We also monitor procedures concerning order management and trading errors.