BBRM Code of Conduct & Vision

Blue Bear Risk Management (“Blue Bear”) is committed to our clients and our clients’ best interests first and foremost.

Representing our clients’ best short and long term interests is our vision.

Blue Bear’s Board of Directors, senior management, employees and staff, (collectively “Associates”) are committed to this vision. We seek to provide the highest personal and professional standards in our business. Our Board of Directors and senior management encourage our employees and staff to maintain compliance with the highest ethical standards and integrity. To implement our commitment to integrity in the conduct of our business, we have adopted this Code of Conduct & Vision (Blue Bear Code) to ensure that our clients’ interests and goals are and remain our driving force and our paramount concern.

We have attempted to put into place  policies, procedures and systems that are designed to facilitate the highest ethical standards and integrity amongst our employees and staff, while attempting to prevent and detect violations of law and/or our Code of Conduct & Vision, and to be able to respond appropriately to any violations and to prevent further violations. These policies, procedures and systems are contained in a variety of documents, manuals and software/hardware related to our business. Such documents and manuals include the Blue Bear Employee Manual, the Blue Bear Policies & Procedures Manual and software/hardware systems related to the operational and financial performance of our business. The Blue Bear Code is a combination of its summary parts.

Each Associate is responsible for his or her own actions, and is required to perform client service in a manner which is legally, ethically and morally irreproachable. The Blue Bear's standards are clear: simply complying with laws or following widespread business practices may not be sufficient.

The Blue Bear Code identifies conduct which is never acceptable and which will always be considered outside the scope of employment. The Code describes the ethical principles that Blue Bear has set for the conduct of its business, and outlines certain key legal requirements of which all Associates should be aware. Compliance with these requirements is mandatory. Therefore, it is crucial that each Associate read and understand the information presented in this Code.
To assist Associates in complying with these principles, more detailed policy statements and standards on some of the topics addressed below may be set forth in the Blue Bear Employee Handbook or the Blue Bear Policies & Procedures manual, both of which are incorporated herein and made part hereof, as the same may be adopted or amended from time to time.

All Associates are responsible to conduct themselves in a manner that will reflect positively on Blue Bear's reputation. As representatives of Blue Bear, it is essential that Associates' actions are legal and ethical. It is equally important that no actions taken by an Associate appearto others to be inconsistent with these high standards. As a practical matter, we cannot define all situations in which an ethical dilemma may arise. As such, in every case, an Associate should ask himself or herself if the conduct being contemplated would comply with the law and the Blue Bear Code, and would it withstand public disclosure and scrutiny. By doing business in this manner, we can ensure the respect of our clients, shareholders, fellow Associates, regulatory authorities, governments, competitors and neighbors.

The Blue Bear Code also addresses other matters such as:

Protecting Our Clients
Protecting Blue Bear Risk Management
Licensing & Regulatory Matters
Integrity of Books & Records-Audit Trails
Privacy & the Protection of Proprietary, Confidential & Personal Information
Anti-trust & Competition
Entertainment, Gifts & Related Considerations
Public Officials
Political Contributions
Employment Matters
Safety & Loss Control
Agents & Representatives (if any)
Prohibitions - Financial Transactions Involving Designated Persons, Countries & Entities
Money Laundering
Intellectual Property
Reporting & Retaliation Protection
Procedures Regarding Waivers
Acknowledgement - Certification

Contact: Phone: 212-269-0180