– Setting a high ethical standard of business conduct reflecting adviser’s fiduciary obligations;
– Compliance with securities laws;
– Access persons to periodically report personal securities transactions and holdings, with limited exceptions;
– Prior approval for any IPO or private placement investments by access persons;
– Reporting of violations;
– Delivery and acknowledgement of the Code of Ethics by each supervised person;
– Reviews and sanctions;
– Timely record keeping;
– Acting with integrity, competence, diligence, respect and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets;
– Place the integrity of the investment profession and the interests of clients above their own personal interests;
Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities;
– Practice and encourage others to practice in a professional and ethical manner that will reflect credit on themselves and the profession;
– Promote the integrity and viability of the global capital markets for the ultimate benefit of society;
– Maintain and improve their professional competence and strive to maintain and improve the competence of other investment professionals;
– An investment adviser’s Code of Ethics and related policies and procedures represent a strong internal control with supervisory reviews to detect and prevent possible insider trading, conflicts of interest and potential regulatory violations.-