Our Standards of Conduct

Our Standards of Professional Conduct for Employees and Staff

PROFESSIONALISM

Knowledge of the Law. Must understand and comply with all applicable laws, rules, and regulations of any government, regulatory organization, licensing agency, or professional association governing their professional activities. In the event of a conflict, employees and staff must comply with the more strict law, rule, or regulation. Employees and staff must not knowingly participate or assist in and must dissociate from any violation of such laws, rules, or regulations.

Independence and Objectivity. Employees and staff must use reasonable care and judgment to achieve and maintain independence and objectivity in their professional activities. Employees and staff must not offer, solicit, or accept any gift, benefit, compensation, or consideration that reasonably could be expected to compromise their own or another’s independence and objectivity.

Misrepresentation. Employees and staff must not knowingly make any misrepresentations relating to investment analysis, recommendations, actions, or other professional activities.

Misconduct. Employees and staff must not engage in any professional conduct involving dishonesty, fraud, or deceit or commit any act that reflects adversely on their professional reputation, integrity, or competence.

INTEGRITY OF CAPITAL MARKETS

Material Non-public Information. Employees and staff who possess material non-public information that could affect the value of an investment must not act or cause others to act on the information.

Market Manipulation. Employees and staff must not engage in practices that distort prices or artificially inflate trading volume with the intent to mislead market participants.

DUTIES TO CLIENTS

Loyalty, Prudence, and Care. Employees and staff have a duty of loyalty to their clients and must act with reasonable care and exercise prudent judgment. Employees and staff must act for the benefit of their clients and place their clients’ interests before their employers or their interests.

Fair Dealing. Employees and staff must deal fairly and objectively with all clients when providing investment analysis, making investment recommendations, taking investment action, or engaging in other professional activities.

Suitability. When employees and staff are in an advisory relationship with a client, they must:

Make a reasonable inquiry into a client’s or prospective client’s investment experience, risk and return objectives, and financial constraints prior to making any investment recommendation or taking investment action and must reassess and update this information regularly.
Determine that an investment is suitable to the client’s financial situation and consistent with the client’s written objectives, mandates, and constraints before making an investment recommendation or taking investment action.
Judge the suitability of investments in the context of the client’s total portfolio.

When employees and staff are responsible for managing a portfolio to a specific mandate, strategy, or style, they must make only investment recommendations or take only investment actions that are consistent with the stated objectives and constraints of the portfolio.

Performance Presentation. When communicating investment performance information, employees and staff must make reasonable efforts to ensure that it is fair, accurate, and complete.

Preservation of Confidentiality. Employees and staff must keep information about current, former, and prospective clients confidential unless:

The information concerns illegal activities on the part of the client or prospective client,
Disclosure is required by law, or
The client or prospective client permits disclosure of the information.

DUTIES TO EMPLOYERS

Loyalty. In matters related to their employment, employees and staff must act for the benefit of their employer and not deprive their employer of the advantage of their skills and abilities, divulge confidential information, or otherwise cause harm to their employer.

Additional Compensation Arrangements. Employees and staff must not accept gifts, benefits, compensation, or consideration that competes with or might reasonably be expected to create a conflict of interest with their employer’s interest unless they obtain written consent from all parties involved.

Responsibilities of Supervisors. Employees and staff must make reasonable efforts to ensure that anyone subject to their supervision or authority complies with applicable laws, rules, regulations, and the Code and Standards.

INVESTMENT ANALYSIS, RECOMMENDATIONS, AND ACTIONS

Diligence and Reasonable Basis. Employees and staff must:

Exercise diligence, independence, and thoroughness in analyzing investments, making investment recommendations, and taking investment actions.
Have a reasonable and adequate basis, supported by appropriate research and investigation, for any investment analysis, recommendation, or action.

Communication with Clients and Prospective Clients. Employees and staff must:

Disclose to clients and prospective clients the basic format and general principles of the investment processes they use to analyze investments, select securities, and construct portfolios and must promptly disclose any changes that might materially affect those processes.
Disclose to clients and prospective client’s significant limitations and risks associated with the investment process.
Use reasonable judgment in identifying which factors are important to their investment analyses, recommendations, or actions and include those factors in communications with clients and prospective clients.
Distinguish between fact and opinion in the presentation of investment analysis and recommendations.

Record Retention. Employees and staff must develop and maintain appropriate records to support their investment analyses, recommendations, actions, and other investment-related communications with clients and prospective clients.

CONFLICTS OF INTEREST

Disclosure of Conflicts. Employees and staff must make full and fair disclosure of all matters that could reasonably be expected to impair their independence and objectivity or interfere with respective duties to their clients, prospective clients, and employer. Employees and staff must ensure that such disclosures are prominent, are delivered in plain language, and communicate the relevant information effectively.

Priority of Transactions. Investment transactions for clients and employers must have priority over investment transactions in which an employee and staff is the beneficial owner.

Referral Fees. Employees and staff must disclose to their employer, clients, and prospective clients, as appropriate, any compensation, consideration, or benefit received from or paid to others for the recommendation of products or services.