This Code of Conduct ("Code") sets out the standards Thalos Capital Corporation ("Thalos Capital") holds itself to in working with clients, capital sources, and partners. It reflects how we operate as a commercial finance origination and strategic advisory intermediary.
1. Integrity and honesty
We deal honestly and fairly with clients, capital sources, and partners. We do not make misleading statements about financing availability, terms, timelines, or outcomes, and we present information accurately and in context.
2. Client interests
We act in the legitimate interests of the clients we represent. We seek to understand each client’s objectives and to structure and present financing options aligned to those objectives, rather than to a single product or source.
3. Confidentiality
We treat client and counterparty information as confidential and use it only for the purpose of evaluating, structuring, and arranging financing, or as required by law. We handle personal information in accordance with our Privacy Policy.
4. Conflicts of interest
We identify and manage actual and potential conflicts of interest. Where a material conflict exists, we disclose it to the affected parties. We do not allow compensation arrangements to override our duty to deal fairly and transparently.
5. Transparency on our role and compensation
We are transparent about our role as an intermediary, that financing is provided by third-party capital sources subject to their approval, and, where applicable, about how we are compensated in connection with a transaction.
6. Compliance with law
We conduct our business in compliance with applicable laws and regulations, including those governing financial intermediation, privacy, anti-money-laundering, and anti-corruption. We do not knowingly participate in any transaction intended to facilitate unlawful activity.
7. Accurate information and fair dealing with capital sources
We provide capital sources with accurate, complete, and timely information to the best of our knowledge, and we do not misrepresent a deal, a borrower, or supporting information.
8. Professionalism
We communicate clearly, respond promptly, and conduct ourselves professionally and respectfully in all dealings.
9. Accountability
We take responsibility for our conduct. Concerns about a breach of this Code may be raised with us using the contact details below and will be reviewed in good faith.
10. Contact
To raise a question or concern regarding this Code: [email protected] · Thalos Capital Corporation, 5063 North Service Road, Suite 100, Burlington, ON, L7L 5H6, Canada.
