Our Code of Ethics

General

  • The following Code of Ethics are Pursuant to the regulations as determined and issued by the Securities Commission.  
  • Our group of companies; will adhere to a strict code of ethics to ensure that all members of the company operate and work within these ethics. 
  • Sure Holdings operates, within the jurisdiction of the  Labuan FSA. 
  • These specific code of ethics will be adhered to in its strictest terms and under continued scrutiny by the directors and management of the company.
  1. The company and its employees will practice competently and without impairment. 
  2. The company and its employees will maintain knowledge of and comply with all applicable laws, rules, and regulations of any government, regulatory organization, or professional association governing the members’ professional activities. 
  3. The company and its employees will act at all times in the best interests of their clients and not allow their own interests or those of their employer to override the interests of their clients.
  4. The company and its employees will act at all times with due skill, care and diligence in conducting their business. 
  5. The company will at all times preserve client confidentiality.
  6. The company will respect the intellectual property rights of others 
  7. The company will endeavor at all times to protect and promote the integrity of the market. 
  8. The company will endeavor at all times avoid and or disclose any real or perceived conflicts of interest. 
  9. The company will endeavor at all times be true to their word. 
  10. The company will endeavor at all times to respect the dignity of others. 
  11. The company will endeavor at all times never knowingly mislead or deceive others. 
  12. The company will endeavor to recognize our limitations and the competence of others and when indicated, recommend that additional opinions and services be sought. 
  13. The company will ensure that its employees engage in lifelong learning to maintain and improve their professional knowledge, skills and attitudes. 

Responsibilities to the Client

  1. The company will not discriminate against any client on such grounds as age, gender, marital status, national or ethnic origin.
  2. The company will exercise diligence and thoroughness in sourcing and researching the property market, having a reasonable and adequate basis, supported by appropriate research and investigation for such recommendation. 
  3. The company will exercise diligence in avoiding any material misrepresentation in any property development acquisition.
  4. The company will use particular care in determining applicable fiduciary duty. The company will act on behalf of our clients and place our clients’ interests before our own. 
  5. The company will preserve the confidentiality of information communicated by clients and prospects. 
  6. The company will not make any oral or written statements that misrepresent the services that the company is capable of performing. The Company will not make or imply any assurances regarding any investment except to communicate accurate information regarding the investment. 
  7. The company will disclose to our clients and prospects all matters, including beneficial ownership of securities or other investments, which reasonably could be expected to impair the member’s ability to make unbiased and objective recommendations. 
  8. The Company will not make any oral or written statements that misrepresent the investment performance that the company have accomplished or can reasonably accomplish. 
  9. The Company will, having accepted professional responsibility for a client, continue to provide services until they are no longer required or wanted; until another suitable professional has assumed responsibility for the client, or until the client has been given adequate notice that the client intend to terminate the relationship.