Sunshine Profits' Code of Ethics

Our Mission

We help people grow their capital through effective trading and investment, so that they can gain financial safety, and live their dreams.

Every day, taking care of our Clients we realize the Mission of Sunshine Profits. It is an inspiration and a synthesis of our values.

Our Values

Care, Commitment, Transparency, Integrity and Responsibility make a solid foundation on which we build the future of our company and from which we earn the satisfaction of our Clients and Co-workers. We require our whole Team to respect these Values in both the business relationships and after working hours as well.

• Care – The critical value behind Sunshine Profits is care. Our customers share this value with us. They care about their families and their financial standing. They care about their savings. Our customers know that we care about them.
• Commitment – The business of our Clients is our business. We make every effort, using the best of our knowledge and expertise, in order to tailor offered services to the needs and high expectations of our Clients. We are 100% committed because we know that the profit of the Client is also our profit.
• Transparency – We make sure that our rules of cooperation are always clear for our Clients, Team Members, and Co-workers.
• Integrity – We offer fair contractual conditions, always in accordance with applicable law. Our Team Members provide reliable and complete information.
• Responsibility – “With great power, comes great responsibility.” Since we aim to help our clients in such an important area of their lives, we pledge to conduct research thoroughly and feature only those products / essays that are well-researched and followed by rigorous testing procedures. We are also partly responsible for the world around us and we do our best contribute to its sustainable growth.

Introduction

According to popular opinion, ethics in the financial world are viewed as something "artificial" or even "obsolete". We aim to prove that there are still companies that really care about ethics.

Personally, I believe that no true success or pride based on being part of a profitable company can result from businesses that are successful without paying attention to ethics. I'm sure everyone can easily come up with a few examples of "business activities" that are unethical (often illegal) and are also very profitable. Would engaging in any of them cause true satisfaction? No. Do you think that people who engage in them are happy when they look into a mirror? No. We are not in this particular business because it's easy. We're operating in a constantly changing environment (markets) that makes it impossible to make our clients satisfied each and every time. We strive to create something great over and over again even though it's very hard to do so given these changing circumstances. This makes our business one of the most difficult out there.

But, when a new tool is published, when someone sends a "great essay!" or "thank you so much!" e-mail (just look at the testimonials section on the new website - they are all real), when we nail it by predicting a market bottom right when it bottoms, we know that it was no coincidence – we earned it through hard work, and we know that we can be happy with the results. We can feel good about them.

Now, if our approach was not ethical right from the beginning, the last part would not apply. We could never say that it was because of our hard work that we were successful – it might have been the "unethical part" that made us look good and that's it. So since, without being ethical, we cannot feel good about good results – what's the point of achieving them anyway?

Ethics are that important because without paying attention to them none of us can truly feel good about what we do – and there's nothing with which you can substitute that awareness. Ethics are efficient as they build trust and trust makes most processes much simpler and shorter. Finally, ethics are the only thing that allows us to be proud of our achievements.

If you (readers, clients, employees, other stakeholders) ever encounter any violations of this Code of Ethics, or it is unclear whether a violation occurred or not, please contact the company's CEO at the following e-mail address: [email protected]. It is important to report any ethical issue or potential issue as soon as possible.

We will investigate all reported issues, and those who are found guilty of unethical behavior will face consequences based on a particular issue’s severity.

Przemysław Radomski
CEO of Sunshine Profits

Rules

Services quality and Clients’ safety – Highest quality of services which ensures safety of our Clients and their transactions is our priority. Bearing this in mind and being willing to help the Clients we have created a special educational section on the Sunshine Profits (SP) website which is dedicated to principles of safety and privacy on the Internet.

• SP Team Members are loyal to their clients whose benefit and interests are always placed before the interests of their employer’s or their own.
• SP Team Members are expected to deal objectively and fairly with all clients when making investment recommendations, providing investment analysis, or engaging in other professional activities. Analysis must always be prepared fairly and independently in accordance with best knowledge of the Analyst, regardless of the market 'popularity' contained in the views and expectations of customers or the employer.
• SP Team Members are prohibited from trading on their own or other Sunshine Profits' employee or co-worker's market calls until the change in the outlook is communicated to our Clients. Such information may not be shared with any third party without obtaining company's CEO written consent and only after it is disseminated to Clients.
• It is strictly forbidden to SP Team Members, who have free access to tools/charts/signals/updates/etc., to share that premium content with anyone without the written permission of company’s CEO. Acting against this rule may result in increasing the odds that someone other than our Clients will act on these signals before them.
• SP Team Members are obliged to immediately notify the company’s CEO about any incidents (both: real or potential) where Client's interest should come before company's interests and it has not

Transparent sales and marketing – We provide thorough and complete description of features of our services and products, together with a transparent pricing system and customer-friendly conditions of returns and complaints. We make sure that our products and services always undergo extensive tests before they are offered to our Clients in order to ensure the highest quality and best possible performance of a given product or service.

• SP Team Members are expected to proactively make proper efforts in order to inform their Clients in a timely manner about any changes or problems which may appear with their subscriptions.

Moreover, SP Team Members are prohibited from:

• practices restricting free competition by agreements, contracts or arrangements with content that violates the principle of unlimited competition;
• sharing confidential information which can influence the competitors/competition and engaging in discussions that could lead to co-ordinate actions by competitors;
• providing competitors with information that may affect their price or pricing practices.

Development and equal treatment of employees – We support continuous development of our Team Members and promote learning at the level of the whole organization. We believe that respect for the individual should be a core value for any successful organization. Our Team Members actively contribute to the company’s development with their knowledge and experience, and are involved in the decision making processes on a voluntary and non-discriminatory basis. Flexible working time provides work-life balance for our Team Members.

• New SP Team Members are introduced to the company operations and their duties by more experienced colleagues in the framework of our internal mentoring program;
• SP Team Members are encouraged to improve their professional knowledge during their work time;
• Work time of SP Team Members is regulated and agreed upon according to their individual preferences;
• Internal communication and the knowledge management platform is available to each Team Member;
• The bonus system is based upon the extraordinary contributions of each SP Team Member and is equal and non-discriminatory.

Conflicts of interest – Co-workers and representatives of Sunshine Profits must be loyal to the company and cooperate with suppliers, customers and other persons doing business with the company by avoiding conflicts between personal interests and the interests of the company (including the appearance thereof). Transparency is the highest value for us – we do not advertise other companies nor their services and do not accept any commercials on the Sunshine Profits website because we want to deliver only solutions that are proven and beneficial for our Clients.

• Sunshine Profits does not accept (and has never done so) any payments for the publication of favorable analysis of companies, especially in the form of shares, options or warrants. All our published analyses are always written objectively, fairly and according to our best expertise.
• Secondary activities of SP Team Members, as well as their shares in companies that are business partners of SP and/or companies in competition with SP require the written consent of Sunshine Profits’ CEO. There is no obligation to report such activities as the acquisition of securities, or in the case of common capital investments in small quantities.
• It is forbidden for SP Team Members to get involved in a relationship that could lead to conflicts of interest between the company and a third party, including transactions involving equity, a partner, a member of the immediate family or a company in which the Team Member has an interest or business relationship.

Security of information – We understand how important it is to ensure the security of sensitive information. We want to protect our assets and entrusted information to prevent unauthorized disclosure of confidential information. We protect interests of our Clients, Team Members and business partners by opposing the transactions carried out on the basis of undisclosed information.

• SP Team Members are obliged to keep information about former, current and prospective Clients confidential.
• Information about current and prospective Clients can be disclosed only in case that it concerns client’s illegal activities, is required by law or Client has agreed to the disclosure of information.

Bribery and corruption – We do not accept any manifestation of bribery and corruption in the structures of SP since Transparency, Integrity and Responsibility are our values.

• It is strictly forbidden for SP Team Members to provide or to promise illegal benefits to the contractors, their employees and agents or other third parties;
• SP Team Members are not allowed to require or accept any illegal benefits from SP business partners, competitors, Clients or other third parties;
• It is unacceptable to use third parties (e.g. consultants, banks, brokers, lobbyists, sponsors, agents or other intermediaries) to circumvent the rules regarding bribery and corruption. Violation of this rule will be dealt with by termination of employment contract or termination of any other existing contractual relationship.

Protection of the company’s interest – Our co-workers should have in mind the interests of the company and thus its Clients and business partners while performing their duties. All SP Team Members must act for the benefit of the company by utilizing the resources they have at their disposal as well as their personal skills, experience, knowledge and abilities. This does not require SP Team Member so make public or disclose the information that they received as confidential. In this case, however, it is important to check if any ethical misconduct has taken place and report it accordingly.

SP Team Members are expected:

• to notify the company’s CEO about any changes in mutual professional relations with as much advance as possible where one month of advance is perceived as the absolute minimum (unless their contract requires otherwise);
• to use their working time efficiently;
• to help each other within the Team to solve problems that appear;
• to keep to promised deadlines and to fulfill obligations taken;
• to protect all the confidential information received as an SP Team Member and treat it as such – without disclosing it without written permission from the company’s CEO.

All the representatives of Sunshine Profits, including CEO and Team Members must act on behalf of Sunshine Profits in a manner consistent with the above Ethical Code.