ZYC-ETH-001 Code of Conduct & Ethics Policy
Purpose
To define the standards of behaviour expected from everyone working at Zeyro, ensuring our actions align with our values and with the FCA’s Conduct Rules (COCON).
Scope
Applies to all directors, employees, and contractors of Zeyro. It sets expectations for integrity, professionalism, and accountability in all business dealings and relationships.
Policy Statement
Zeyro’s culture is built on openness, fairness, and respect. We operate calmly, think critically, and act with integrity — doing what is right, not merely what is permitted. All staff must uphold the spirit as well as the letter of FCA rules and internal policies.
We expect every employee to:
Act with integrity and honesty.
Treat clients and colleagues fairly and with respect.
Use sound judgment — escalate concerns early, ask questions, and seek clarity.
Maintain confidentiality of business and client information.
Avoid conflicts of interest and disclose potential issues to the MLRO.
Comply with all laws, regulations, and internal policies.
Champion diversity, inclusion, and transparency in every interaction.
These standards apply at all times, including when representing Zeyro externally or on social media.
Conduct Principles (FCA COCON Alignment)
FCA Rule
Zeyro Expectation
Act with integrity.
Be honest and transparent in all dealings.
Act with due skill, care, and diligence.
Be accurate, thorough, and mindful of risk.
Be open and cooperative with regulators.
Engage with the FCA promptly and fully.
Treat customers fairly.
Ensure promotions and interactions are clear, not misleading.
Observe proper standards of market conduct.
Uphold the reputation and trust of Zeyro and the industry.
Decision-Making Framework
When facing uncertainty, staff should pause and ask:
Is it legal?
Is it honest?
Is it consistent with our policies and values?
Would I be comfortable if this appeared in the public domain?
If the answer to any of these is no, the action should not proceed without further guidance from the MLRO or Board.
Roles and Responsibilities (RACI)
Role
Responsibility
Accountability
Consulted / Informed
All Staff
Follow this policy and the FCA Conduct Rules; raise concerns where appropriate.
MLRO
Line manager / MLRO
MLRO (SMF 16 & 17)
Provide guidance on conduct issues; maintain conflicts and gifts registers; escalate breaches.
Board
All staff
Board
Approve policy; set ethical tone; review conduct breaches quarterly.
—
MLRO
Non-Executive Director (Giles Swan)
Provide independent challenge on culture and ethical standards.
Board
MLRO
Controls risk: aligns behaviour with FCA COCON and ensures escalation channels for ethical concerns.
Review
This policy is reviewed annually or sooner if the FCA updates COCON guidance or our business changes materially.
Document Control
Field
Details
Policy Code
ZYC-ETH-001
Policy Title
Code of Conduct & Ethics Policy
Document Owner
Gareth Malna – MLRO (SMF 16 & 17)
Responsible Reviewer(s)
Zeyro Board
Version
v 1.0
Date Approved
October 2025
Next Scheduled Review
October 2026
Change History
v 1.0 (Oct 2025): Initial publication combining behavioural expectations and FCA COCON standards.
Classification
Internal policy – distributed to all staff; available to regulators on request.
Last updated