About company 24GLO Global Local Online

24GLO.com offers proactive, efficient and dependable services for global customers and businesses. 24GLO.com has experience since 2004 offering high-touch services to individuals and companies worldwide.

Our expertise, relationships and proximity to the embassies in 24GLO.com, and the special care and service we provide to our clients have enabled us to successfully serve many customers.

Our clients feel respect and goodwill regardless of the size of the wealth.

Each client is unique.

Confidentiality and disposal of “personal identifying information”

24GLO.com shall do everything possible to maintain the utmost confidentiality in its performance of services. All emails, messages, texts, the nature of the work performed, the personal data of the client and any “personal identifying information” (e.g., home address or telephone number, e-mail address, identification name or password) transmitted by the client to 24GLO.com are subject to the strictest confidentiality and the personal data collected shall be processed in accordance with Article 6 of the GDPR.

In particular, 24GLO.com shall use the information provided for the execution of the contract (and for the eventual implementation of pre-contractual measures) and such information can not — without the prior written consent of the client — be disclosed publicly or to third parties, except to its authorized employees or their authorized subcontractors, should their operational or advisory intervention require knowledge of such information. The above guarantees do not apply if 24GLO.com is obliged by law to disclose such information.

Confidential information will not be sought from a client unless expressly in the interests of that client, i.e. to enable a better service delivery.

In no circumstances should details of a client be discussed by anyone outside of the organization or in an open plan area in such a manner that it is possible to identify the client.

Vision and Corporate Principles

We’ve been busy making sure we’re compliant, transparent and adhere to protect the privacy of all our customers, vendors and associates around the world and wherever you’re located.

General Data Protection Regulation (GDPR)

We don't collect any information online.
We don't use cookies.
We don't share information about you.

24GLO educational institution

We provide educational services throught internet.
24GLO educational institution is a place where people of various ages gain an education.
We provide fully accredited courses for learning languages, in particular Russian, English and Greek
You can use our educational materials free of charge.

The main courses can be found here.

What instruction do we follow ?

We are guided by the universal moral principles as well as the Bible.

Code of Conduct

Introduction

Each of the principles of the Code is supported and explained by a number of recommendations, which in most cases will represent the practice to be followed in order to implement the Code's principles.

The recommendations underpinning the ten principles of the Code have been reviewed to take account, in particular, of the increased focus on the management of conflicts of interest, risk management and internal controls, which have been major features of new regulations and development in practice over the last years.

The purpose of the Code of Conduct is to provide members of the board of directors with a framework of high-level principles and best practice recommendations for the governance of funds and of the management company where appropriate.

The Code is ‘principles’ rather than ‘rules’ based in that it relies upon good judgment rather than prescription. As such, the recommendations recognise that the ‘right approach’ for many issues depends on the circumstances.

The Code is not designed to supersede applicable law and regulations.

References in the Code to the ‘Board’ are to the body responsible by law for managing, administering and supervising the relevant branch or the supervisory function responsible for the management company. Unless otherwise specified or the context otherwise requires, all references to the Board in the Code shall therefore include, as appropriate, the boards of both head office and the management of any branch of the company.

Principles and Recommendations

1. The Board should ensure that high standards of corporate governance are applied at all times. • The Board is accountable to the shareholders for good governance.
• The Board should ensure that sound management is in place.
• The Board should discharge its functions soundly, honestly and professionally.
• The Board should place emphasis on promoting transparency, good practices and conduct of business rules and efficiently manage conflicts of interest.
• The Board should provide independent review and oversight, including effective oversight of delegated functions.
• The Board should demonstrate leadership, integrity, ethical behaviour and expertise.

2. The Board should have good professional standing and appropriate experience and ensure that it is collectively competent to fulfil its responsibilities.
• The composition of the Board should be balanced and diverse so it can make well-informed decisions. Members of the Board should therefore have appropriate experience, with complementary knowledge and skills, relative to the size, complexity and activities of the compnany.
• Consideration should be given to the inclusion in the Board of one or more members that are, in the opinion of the Board, independent.
• The Chairperson, whether appointed on a permanent, ad hoc or rotating basis, should demonstrate leadership during as well as outside meetings. The Chairperson's duties should include setting the agenda, managing the meeting, steering the discussions and ensuring that effective and fair conclusions are reached.
• The Board should ensure that it keeps abreast of relevant laws and regulations and that it remains vigilant about evolving risks and market developments.
• The Board may call upon expert assistance and/or create Board committees for the proper fulfilment of its duties. The establishment of Board committees should not affect the collective responsibility of the Board.
• The members of the Board are expected to understand the activities of the company and devote sufficient time to their role.
• The Board should conduct a periodic review of its performance and activities.

3. The Board should act fairly and independently in the best interests of the clients.
• The Board should at all times put the interests of the clients first.
• The Board is expected to act fairly and independently irrespective of any Board member's affiliation.
• The Board should arrive at decisions taking into consideration, where possible, any broader potential impact of such decisions on market integrity and on the wider community.
• Company expenses and their impact on company returns should be subject to scrutiny by the Board. The Board should ensure that the expenses charged to the company are reasonable, fair and appropriate.

4. The Board should act with due care and diligence in the performance of its duties.
• Board members should regularly attend and participate actively at Board meetings.
• The Board should meet as often as required in order to oversee effectively the company's activities and all Board meetings should be formally minuted.
• The Board is responsible for approving the company's strategy and for ensuring that the company consistently follows its stated activity objectives.
• The Board is responsible for the appointment of delegated parties and should oversee their activities and performance.
• The Board should ensure it acts on a fully informed basis.
• Where required, the Board should seek external professional advice or information to assist it in its duties.

5. The Board should ensure compliance with all applicable laws, regulations and with the company's constitutional documents.
• The Board should verify that adequate organisation, procedures and safeguards are established to ensure compliance with all relevant laws and regulations and with the company's constitutional documents.
• The Board should verify that regular monitoring of such compliance is in place and that it receives regular reports to that effect.

6. The Board should ensure that clients are properly informed, fairly and equitably treated, and receive the benefits and services to which they are entitled.
• The Board should ensure that the information provided to clients about the company particularly with regard to the company's activity objectives, risks and costs, is true, fair, timely and not misleading.
• The Board should ensure that clients are kept informed of matters relevant to their activity in a form and language that is clear and easy to understand.
• The Board should ensure that information relating to the company's financial situation and performance be prepared and disclosed in accordance with relevant accounting standards (e.g. GAAP, IFRS) and applicable legal and regulatory requirements.
• The Board should take into account the interest of all clients, in particular where Board decisions may affect client groups differently.
• The Board should ensure each client complaint is reviewed and, if it is upheld, that a redress is provided within a reasonable time.
• The Board should ensure that clients receive the benefits and level of services to which they are entitled as defined by law, contractual arrangements and the company's constitutional documents.
• The Board should ensure that there is adequate disclosure to clients of the company's policies on complaint handling, proxy voting, best execution and conflicts of interest.

7. The Board should ensure that an effective risk management process and appropriate internal controls are in place.
Risk management
• The Board should ensure that an adequate and documented risk management policy is established, implemented and maintained which identifies the risks to which the company is exposed and how such risks are managed.
• The Board should ensure that the permanent risk management function is adequately staffed or properly managed when provided on any outsourced basis, and that it is independent of the activity and operational processes.
• The Board should ensure that the risk management policy enables the proper identification, measurement and assessment of the company's exposure to market, liquidity and counterparty risks, and exposure to all other risks including operational risks.
• The Board should ensure that it receives regular risk management reporting and that it regularly assesses the adequacy and effectiveness of the risk management policy and processes.

Internal controls
• The Board should seek assurance that delegated parties comply with relevant and adequate Compliance and Internal Audit obligations.
• The Board should ensure that Compliance and Internal Audit functions are independent of the activity and operational processes.
• The Board should require direct and timely reporting of any material internal control and compliance issues, and ensure that they are appropriately addressed.
• The Board should ensure that appropriate business continuity plans are in place, including for delegated parties.

8. The Board should identify and manage fairly and effectively, to the best of its ability, any actual, potential or apparent conflict of interest and ensure appropriate disclosure.
• The Board should identify the circumstances which constitute or may give rise to a conflict of interest which may entail a material risk of damage to the interests of clients.
• The Board should establish, implement and maintain an effective conflict of interest policy (i) to identify such conflicts of interest and (ii) to provide for procedures to be followed and measures to be adopted in order to prevent them where possible and to manage such conflicts in an independent manner.
• The Board should make all reasonable efforts to resolve conflicts of interest but in cases where a conflict of interest is unavoidable, the Board should seek to address it on an arm's length basis and to disclose it adequately to interested parties.
• The Board should keep an updated record of the situations where conflicts of interest entailing a material risk of damage to clients may arise, have arisen and how they have been addressed.

9. The Board should ensure that shareholders rights are exercised in a considered way and in the best interests of the company.
• The Board should ensure that a policy on proxy voting is in place and adequately disclosed.

10. The Board should ensure that the remuneration of Board members is reasonable and fair and adequately disclosed.
• The Board should ensure that where appropriate a policy on remuneration of Board Members is in place and is adequately disclosed.
• The remuneration of Board members should reflect the responsibilities of the Board, the experience of the Board as a whole and be fair and appropriate given the size, complexity and activity objectives of the company.
• The remuneration of Board members charged to the company should be separately disclosed in the annual financial statements either individually or collectively.

Conflicts of Interest Policy

1. Introduction
Following the Commission Directive 2010/43/EU of 1 July 2010 implementing Directive 2009/65/EC of the European Parliament and of the Council as regards organisational requirements, conflicts of interest, conduct of business, risk management and content of the agreement between a client and a management company, the European Commission took measures concerning rules of conduct and organisational requirements for companies.

Where arrangements are not sufficient to ensure, with reasonable confidence, that the risk of damage to clients will be prevented, a compnay must clearly disclose the conflicts to the clients before undertaking business on their behalf, and develop appropriate policies and procedures. A company must have and maintain a written conflicts of interest policy, which must identify the circumstances which constitute or may give rise to a conflict of interest as well as procedures to be followed to prevent, manage and monitor such conflicts.

The procedure adopted by the Management Company for the management of conflicts of interest is based on four basic principles:
1) Identification
With reference to the services and the activities and the services ancillary to them, the Management Company shall identify the circumstances that generate or could generate a conflict of interest that could seriously harm interests of a company or its shareholders;

2) Organisation
The Management Company shall define the procedures to follow and adopt organisational measures in order to manage the conflicts that were identified;

3) Declaration
In the event that the Management Company considers that the organisational and administrative measures adopted to manage certain types of conflicts of interest do not sufficiently ensure, with reasonable certainty, that the risk of harming interests is averted, they shall clearly inform those affected , where required, prior to acting on their behalf, of the nature and the sources of the conflict of interests, so that they can make an informed decision on the services provided given the context in which the conflict situations arise.

4) Good faith Given their duty to act honestly and fairly, in providing services the Management Company shall act in a correct, fair and professional manner to serve the interests of its customers.

2. Regulatory references
The Management Company put in place procedures for the effective identification and handling of conflicts of interest following regulation CSSF 10-4, CSSF Circular 18/698, Art. 17-21 of the Commission Directive 2010/43/EU, Art. 109 of the Law of December 17, 2010 (UCITS) and Art. 11 / 13 of the Law of 12th July 2013.

3. Our policy
As a general principle, the Board and the Officers have always to act in the best interest of the clients of the company managed by the Management Company.

Management companies are obliged to define in writing an effective policy as regards conflict of interest, which preserves the independence of the relevant persons.

Directive 2010/43/EU identifies as “Relevant Persons” who are:
a) a director, partner or equivalent, or manager of the management company;
b) an employee of the management company, as well as any other natural person whose services are placed at the disposal and under the control of the management company;
c) a natural person who is directly involved in the provision of services to the management company under a delegation arrangement to third parties.

In general, each relevant person is obligated to disclose to the manager of the operating department to which he/she belongs any situation that could even potentially generate a conflict of interest, modify the conflict map identified by the Management Company or indicate incomplete efficiency of the protection and management measures set up by the Management Company.

In general, each relevant person is obligated to disclose to the manager of the operating department to which he/she belongs any situation that could even potentially generate a conflict of interest, modify the conflict map identified by the Management Company or indicate incomplete efficiency of the protection and management measures set up by the Management Company.

Conflicts of interest may exist or arise in relation to various activities and our conflicts policy sets out how:
• to identify circumstances which may give rise to conflicts of interest including a material risk of damage to the company interests; and
• to established and maintain appropriate mechanisms and systems to manage those conflicts.

When a conflict of interest arises, measures shall be taken to manage it in order not to damage Company’s interests. Conflict of interest shall always be managed in a reliable and consistent manner.

The main measure to prevent conflicts of interest from adversely affecting a client is to ensure that actions taken in respect of the Company are based solely on the Company’s interests, and are taken independently of the interests of any of the Management Companies other clients, other services or activities, or Director’s or Conducting Officer’s personal interests.

4. Areas of conflict of interest
The following situations may lead to conflicts of interest, where:
• the management company is likely to make a financial gain, or avoid a financial loss, at the expense of the client;
• the management company has an interest in the outcome of a service provided to the client or another client which does not share the interests of the client;
• the management company has an incentive to favor the interest of another client;
• the management company carries out the same activities for the client as for another client;
• the management company receives money, goods or services illegally.

The Management Company will take into account conflict of interest that may arise in the course of managing the client between:
• the Management Company, including its managers, employees or any person directly or indirectly linked to the Management Company by control, and the client managed by the Management Company;
• the client and another client;
• the client and another client of the Management Company;
• the client and another client managed by the Management Company; or
• two clients of the Management Company.

Within the Management Company, conflicts of interest may arise in a variety of situations. These situations include, but are not limited to:
• dual roles of Directors as employees of service providers to the Management Company;
• the fact that a service provider or manager conducts the same type of business as the Management Company;
• the fact that there might be several managers managing different clients;
• distribution of costs between the clients and
• personal transactions of personnel or other relevant persons (e.g. independent board members, external compliance officer, external members of an committee, if existing)).

Dual roles of Directors
In order to manage and mitigate possible conflicts of interest relating to the dual roles of Directors as employees of service providers to the Management Company, a Director who is also employed by a service provider and is taking part in the service provider’s daily operations and its delivery of services to the Management Company, shall not take part in decisions by the Board of Directors relating to such service provider.

Distribution of costs between clients
In order to manage and mitigate possible conflicts of interest relating to the distribution of costs between clients, the Management Company has established a principle according to which the distribution of costs which are joint between clients shall be made proportionally between clients by net asset value at the time of invoice payment, to the effect that a client with a smaller net asset value shall take on a lower amount of common costs than a client with a higher value.

This principle applies in cases where costs are not clearly attributable to a particular client.

5. Management of conflicts
This Policy adopts standards and procedures to manage conflicts of interests. These policies and procedures are subject to our normal monitoring and review processes and include, but are not limited to the following:

5.1. Separation of functions
If a business with two functions would lead to conflicts of interest, it may separate the functions into two separately managed businesses or ensure that they are managed by different senior members of staff.

5.2. Pay
Pay and bonuses may be linked, directly or indirectly, to the profits of the 24GLO Group or the business or department in which the member of staff works. In dealing with compensation, the Management Company has put into effect its own policy, to which reference is made.

5.3. Gifts and inducements The giving and receiving of gifts or inducements has the potential to create conflicts of interest. Employees must not solicit or provide anything of value directly or indirectly to or from anyone, except under limited circumstances, which would impair the duty to act in the best interest of the client or its shareholders.

5.4. Step aside
People may be required to refrain from certain actions.

5.5. Chinese Walls
Implementation of Chinese Walls (information barrier within an organization that was erected to prevent exchanges or communication that could lead to conflicts of interest) or other additional information segregation methods following consideration of all of the facts available to management.

5.6. Escalation
Escalation to senior management or the Board which has responsibility for the strategy and an appreciation of the relationship and reputation risks that may arise.

5.7. Declining to act
Where the Management Company considers that the conflict of interest cannot be managed in any other way, it may decline to act for a client or carry out a specific transaction.

5.8. Review
There is a periodic review of the adequacy of this policy.

6. Record keeping and reporting of services and activities giving rise to conflicts of interest
The Board shall ensure that:
• in the event that it identifies an actual or potential conflict of interest which could entail a material risk of damage to the interests of the Management Company or any of its clients or its shareholders, such actual or potential conflict is reported to the Conducting Officers and the Compliance Officer of the Management Company,
• record is kept of all conflicts of interest identified, through reports submitted by the Conducting Officers, the Compliance Officer or otherwise, and
• a review to identify the potential conflicts of interest that could entail a material risk of damage to the interests of a client or its shareholders is carried out at least on an annual basis that the provisions which it has put in place pursuant to this Policy remain adequate.

The Conducting Officers shall ensure that:
• conflicts of interest handling is duly reported to the Board of Directors of the Management Company, i.e. on an annual basis and when needed.

In accordance with principles above, the Management Company has put in place a conflicts of interest register. In particular, the register will record the following information:
• activity that have given or might give rise to a conflict,
• type of conflict,
• names of relevant persons or business unit / department and the date when this situation arose or was discovered,
• risk and impact analysis,
• measures taken to resolve the (potential) conflict,
• additional comments.

Such register is updated by the Compliance officer, who keeps the Conducting Persons informed about such updates and submits the register, together with explanatory information, if necessary, to the Board of Directors at least on a yearly basis.

7. Disclosure of conflicts of interest and information to clients
Where the organizational or administrative arrangements made by the Management Company, despite procedures a priori appearing adequate, are not sufficient to ensure with reasonable confidence, that risks of damage to the interests of the clients will be prevented, it is immediately to be escalated in order to take any necessary decision or action to ensure that the Management Company acts in the best interests of the clients.

The Management Company may report situations referred to above to clients by any appropriate durable medium, e.g. report to the clients, to enable the clients to make an informed decision.

Whistleblowing Policy

1. Whistleblowing
Anyone can inform the Management Company securely, confidentially and in good faith of any misconduct or violations to supervisory regulations.

However, the whistleblowing procedure should not be used to report actions that are of a clearly criminal nature, such as unlawful dealings by the financial sector.
Persons who discover actions that fall within the scope of criminal law (a crime or an offence) are requested to notify the police promptly.

Although the whistleblowing procedure is intended primarily for employees and former employees of the Management Company, it can also be used by companies engaged by the Management Company and by their employees.

However, if a customer has a conflict with the Management Company over the performance of contractual services, he should use the customer complaints procedure instead.

2. Legal bases
2.1. Whistleblowing, is a term which has been developed in the 1970s in the US and is the process of reporting wrongful, unethical or unlawful behaviour, misconduct internally or externally.

A company may be seen as being more transparent and trust worthy by having a robust process and protections for people who wish to report misconduct.

It has become an increasingly relevant issue at work as it implies labour law issues, data protection issues and regulatory since management companies are required to have appropriate whistleblowing procedures in place.

One of the main objectives is to achieve greater retail client protection.
It also implements remuneration rules for management companies at European level that are broadly similar to the remuneration rules in the AIFMD.

Retail client protection is also strengthened by means of a harmonised system of sanctions including the implementation of a whistleblowing mechanism.

Whistleblowing constitutes a hot topic and has been formally enacted as described above.

This legislation is not dedicated solely to whistleblowing protection but does include corresponding provisions.

3. Reporting to the Management Company
3.1. Reporting Channels
In principle, the Management Company only accepts written reports, which should be sent to the following email address: i@24glo.com

If this is not possible or you do not wish to establish first contact in this manner, you may instead contact the Head Office representative.

The Management Company provides no legal advice regarding the information provided.

3.2. Contents of the Report
You should be reasonably certain that the information you are providing to the Management Company is true.
You may of course also back your report with evidence in the form of documents, if you have any in your possession.

4. Protecting the Whistleblower‘s Identity
We are committed to protecting the whistleblower‘s identity as well as the binding rules of law allow.

The whistleblower’s identity will only be disclosed in the cases permitted by law (e.g. when under an obligation to report circumstances that may be a possible breach of criminal law, such as a crime or offence), or during a criminal case in which the whistleblower is obliged to testify.

Although, despite all precautions, disclosure of the whistleblower’s identity cannot be completely ruled out, the Management Company will make every effort to protect it.

5. Information on Subsequent Measures
Due to statutory duties of confidentiality, the whistleblower will not be informed of the outcome of investigations or of any measures undertaken.