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THE CORONATION CODE OF ETHICS IN RELATION TO SEI
INTRODUCTION
This Code of ethics applies to all Coronation employees including executive and
non-executive directors.
It is our objective to achieve high levels of growth. We strive for a learning
environment where there is an ongoing commitment to improve productivity,
quality and profitability.
There is a danger that unrealistic expectations can lead to inappropriate risk
being taken or integrity being undermined. It is therefore important that these
risks be mediated by a realistic acceptance of failures and set-backs. We strive
to realise and maximise potential, but the sun still rises if these goals are
not met. To the external environment we prefer to undersell and overdeliver.
Working structures are designed to encourage independence, responsibility and
performance. We wish to conduct our affairs with honesty, integrity, diligence
and professionalism.
CONFIDENTIALITY OF INFORMATION
Staff may not disclose any information concerning the business or general
affairs of the company or any of its clients to any person or fellow employees
who do not have a business requirement for such information or to whom
disclosure could be detrimental to the company or any of its clients. Such
information includes financial data, contracts, business strategies and any
information designated as confidential.
DISCLOSURE OF CONFLICTS OF INTEREST
Staff are required to disclose any potential conflicts of interest to their
compliance officer in writing. Conflicts of interest are any matters that could
reasonably be expected to interfere with an employee's duty to the company.
Any member of staff who receives monetary or other compensation in addition to
that received as a consequence of his/her employment with the company, should
disclose the details of such arrangement to their compliance officer.
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PRESS STATEMENTS
All dealings with the press are to be directed either through the marketing
department of the company in question, through the company's communications
consultants, or through Coronation Holdings. Staff authorised to make statements
to the press on the company and /or any activity that the company performs must
forward a copy of the returned press statement to the marketing department. At
all times press statements must be requested to be returned from the writer for
review before printing.
SHARE DEALING ACTIVITIES
The nature of the company's business activities demand the utilisation of
financial instruments to maximise returns on the management of client and
company funds. It is therefore a policy of the company not to permit personal
account trading. The objective is to reduce risk of insider trading and to avoid
personal conflicts of interest. Individuals are however allowed to make personal
investments. These investments will be deemed to be of a long-term nature and as
a benchmark, no turnarounds of 365 days or less will be permitted.
CORONATION ASSET MANAGEMENT (PTY) LTD ("CAM"), is confident that its officers,
Directors, and employees act with integrity and good faith. CAM recognizes,
however, that personal interests may conflict with the CLIENT'S interests where
officers, Directors or employees:
- know about the Fund's present or future Fund portfolio transactions; or
- have the power to influence Fund portfolio transactions; and
- engage in SECURITIES transactions for their personal account(s).
In an effort to prevent any conflicts from arising CAM has adopted this Code of
Ethics to address transactions that may create or appear to create conflicts of
interest, and to establish reporting requirements and enforcement procedures.
This Code sets forth specific prohibitions regarding Securities transactions.
All employees and directors of CAM are considered ACCESS PERSONS. As such, all
of the prohibitions and restrictions contained in this Code are universally
applicable.
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STATEMENT OF GENERAL PRINCIPLES.
In recognition of the trust and confidence placed in CAM by the client, and
because CAM believes that its operations should benefit the client, CAM has
adopted the following universally applicable principles:
1. The interest of the client is paramount. You must place the
interest of the client before your own.
2. You must accomplish all personal securities transactions in a
manner that avoids a conflict (or the appearance of a conflict)
between your personal interests and those of the client.
3. You must avoid actions or activities that allow (or appear to
allow) you or your family to benefit from your position with CAM,
or that brings into question your independence or judgment.
PROHIBITIONS AND RESTRICTIONS APPLICABLE TO CAM PERSONNEL.
A. PROHIBITION AGAINST FRAUD, DECEIT AND MANIPULATION.
You cannot, in connection with the purchase or sale, directly
or indirectly, of a SECURITY HELD OR TO BE ACQUIRED by the
Fund (SIT Emerging Markets Portfolio, Mediolanum Top Managers
Emerging Markets Portfolio):
1. Employ any device, scheme or artifice to defraud the Fund;
2. make to the Fund any untrue statement of a material
fact or omit to state to the Fund a material fact
necessary in order to make the statements made, in
light of the circumstances under which they are made,
not misleading;
3. engage in any act, practice or course of business
that operates or would operate as a fraud or deceit
upon the Fund; or
4. engage in any manipulative practice with respect to the
Fund.
B. LIMITS ON ACCEPTING OR RECEIVING GIFTS.
Access persons cannot accept or receive any gift of more than
de minimis value from any person or entity in connection with
the client's fund (or any series thereof), enter into a
contract, development of an economic relationship, or other
course of dealing by or on behalf of the Fund.
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C. BLACKOUT PERIOD ON PERSONAL SECURITIES TRANSACTIONS.
ACCESS PERSONS who in connection with their regular duties,
make, participate in, or obtain information regarding the
purchase or sale of Securities by the Fund and any Natural
Control Persons who obtain information regarding
recommendations of Securities made to the Fund may not
purchase or sell, directly or indirectly, any Security in
which they have (or by reason of such transaction acquire) any
BENEFICIAL OWNERSHIP on the same day as the same (or a
related) Security is being purchased or sold by the Fund (or
any series thereof).
No activity in Coronation Holdings Limited shares, Namibian
Harvest Investments Limited shares or African Harvest Limited
shares is permitted during the period between 30 September and
the final reporting date, and between 31 March and the interim
reporting date.
Activity in Coronation Holdings Limited, Namibian Harvest
Investments Limited and African Harvest Limited shares will be
restricted from time to time when a cautionary or other public
announcement is made. Staff will be notified in these
instances, and prior approval from the Compliance Officer will
be required to trade during the restricted period.
D. PROHIBITION ON SELLING RECENTLY-ACQUIRED SECURITIES.
ACCESS PERSONS who, in connection with their regular duties,
make, participate in, or obtain information regarding THE
PURCHASE OR SALE OF SECURITIES by the Fund; and Natural
CONTROL Persons who obtain information concerning
recommendations of SECURITIES made to the Fund may not sell a
SECURITY within 365 days of acquiring that SECURITY.
E. PRE-APPROVAL OF INVESTMENTS IN IPOS AND LIMITED OFFERINGS.
Access persons who, in connection with their duties, make or
participate in making recommendations regarding the purchase
or sale of securities by a Fund or Natural Control Persons who
obtain information concerning recommended securities must
obtain approval from the Compliance Officer, before directly
or indirectly acquiring beneficial ownership of any securities
in an IPO or limited offering.
F. DERIVATIVE INSTRUMENTS
Futures and options may not be traded.
G. SHARE DEALING ENTITIES OR ARRANGEMENTS
This code of ethics applies equally to any close
corporation, syndicates or informal arrangements which a member of
staff is involved in where the principal business is share dealing
and the employee is involved in the investment decisions i.e.
investment clubs.
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REPORTING REQUIREMENTS.
All access persons must comply with the reporting requirements set
forth in Part A.
REVIEW AND ENFORCEMENT OF CAM'S CODE.
APPOINTMENT OF A COMPLIANCE OFFICER.
A compliance officer has been appointed by CAM to perform inter alia
the duties described below.
THE COMPLIANCE OFFICER'S DUTIES AND RESPONSIBILITIES.
1. The Compliance Officer shall notify each person who becomes an
ACCESS PERSON of CAM and who is required to report under this
Code of Ethics and their reporting requirements no later than
10 days before the first quarter in which such person is
required to begin reporting.
2. The Compliance Officer will, on a quarterly basis, compare all
reported personal securities transactions with the client's
completed portfolio transactions and a list of SECURITIES that
were BEING CONSIDERED FOR PURCHASE OR SALE by the client's
investment adviser(s) during the period to determine whether a
Code violation may have occurred. Before determining that a
person has violated the Code, the Compliance Officer must give
the person an opportunity to supply explanatory material.
3. If the Compliance Officer finds that a Code violation may have
occurred, or believes that a Code violation may have occured,
the Compliance Officer must submit a written report regarding
the possible violation, together with the confidential report
and any explanatory material provided by the person, to the
Managing Director ("MD") of CAM. The MD will independently
determine whether the person violated the Code.
4. No person is required to participate in a determination of
whether he or she has committed a Code violation or discuss
the imposition of any sanction against himself or herself.
5. The Compliance Officer will submit his or her own reports, as
may be required pursuant to Part A hereof, to an Alternate
Compliance Officer who shall fulfill the duties of the
Compliance Officer with respect to the Compliance Officer's
reports.
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6. The Compliance Officer will create a written report detailing
any approval(s) granted to access persons for the purchase of
securities offered in connection with an IPO or a LIMITED
OFFERING. The report must include the rationale supporting any
decision to approve such a purchase.
RESOLUTION; SANCTION(S).
If the MD finds that a person has violated the Code, the MD will
approve a proposed resolution of the situation or, if appropriate,
impose upon the person sanctions that the MD deems appropriate and will
report the violation and the resolution and/or sanction imposed to the
Fund's Board of Trustees at the next regularly scheduled board meeting
unless, in the sole discretion of the MD, circumstances warrant an
earlier report.
At least once a year, CAM will provide the Fund's Board of Trustees
with a WRITTEN report that includes:
1. ISSUES ARISING UNDER THE CODE. The reports must describe any
issue(s) that arose during the previous year under the codes
or procedures thereto, including any material code or
procedural violations, and any resulting sanction(s);
2. The Compliance Officer, MD and principal underwriter(s) may
report to the Board more frequently as they deem necessary or
appropriate and shall do so as requested by the Board; and
3. CERTIFICATION. Each report must be accompanied by a
certification to the Board that the Fund, CAM, and principal
underwriter(s) have adopted procedures reasonably necessary to
prevent their access persons from violating their code of
ethics.
INTERRELATIONSHIP WITH THE FUND'S (CLIENT) CODE OF ETHICS.
1. GENERAL PRINCIPLE.
A person who is BOTH an officer and/or Trustee of the Fund AND
an officer, Director, and/or employee of CAM, is only required
to report under this Code of Ethics.
2. PROCEDURES. The MD of CAM shall:
1. Submit to the Board of Trustees of the Fund a copy of this
Code of Ethics;
2. Promptly furnish to the Fund, upon request, copies of
any reports made under this Code of Ethics by any
person who is also covered by the Client's code;
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3. Promptly report to the Fund in writing any material
amendments to this Code of Ethics; and
4. Immediately furnish to the Fund, without request, all
material information regarding any violation of this
Code of Ethics by any person.
RECORD KEEPING.
CAM will maintain records as set forth below. They will be available for
examination by representatives of the regulatory agencies.
1. A copy of this Code and any other code adopted by CAM, which
is, or at any time within the past five years has been, in effect
will be preserved in an easily accessible place.
2. A record of any Code violation and of any sanctions taken will be
preserved in an easily accessible place for a period of at least
five years following the end of the fiscal year in which the
violation occurred.
3. A copy of each Quarterly Transaction Report, Initial Holdings
Report, and Annual Holdings Report submitted under this Code,
including any information provided in lieu of any such reports
made under the Code, will be preserved for a period of at least
five years from the end of the fiscal year in which it is made,
for the first two years in an easily accessible place.
4. A record of all persons, currently or within the past five years,
who are or were required to submit reports under this Code, or
who are or were responsible for reviewing these reports, will be
maintained in an easily accessible place.
5. A copy of each annual report required in terms of this Code must
be maintained for at least five years from the end of the fiscal
year in which it is made, for the first two years in any easily
accessible place.
6. CAM must maintain a record of any decision, and the reasons
supporting the decision, to approve the acquisition of securities
acquired in an IPO or LIMITED OFFERING, for at least five years
after the end of the fiscal year in which the approval is granted.
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MISCELLANEOUS.
1. CONFIDENTIALITY. All reports and other information submitted
to the Fund pursuant to this Code will be treated as
confidential, provided that such reports and information may
be produced to the regulatory agencies.
2. INTERPRETATION OF PROVISIONS. The MD may from time to time
adopt such interpretations of this Code, as it deems
appropriate.
3. COMPLIANCE CERTIFICATION. Within 10 days of becoming an ACCESS
PERSON of CAM, and each year thereafter, each such person must
complete the Compliance Certification that can be obtained
from the Compliance Officer.
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PART A
ACCESS PERSONS AND EMPLOYEES WITH INFORMATION ACCESS
I. LIST OF SECURITIES HOLDINGS
A. INITIAL HOLDINGS REPORT.
You must submit a listing of all SECURITIES you BENEFICIALLY
OWN, as well as all of your securities accounts, as of the
date you first become subject to this Code's reporting
requirements. You must submit this list to the Compliance
Officer within 10 days of the date you first become subject to
this Code's reporting requirements.
B. QUARTERLY HOLDINGS REPORT.
Each quarter, you must submit to the Compliance Officer a
listing of all SECURITIES you BENEFICIALLY OWN, as well as all
of your securities accounts. Your list must be current as of a
date no more than 30 days before you submit the report.
II. REQUIRED TRANSACTION REPORTS
All transactions are to be reported to the Compliance Officer on a
deal by deal basis.
A. QUARTERLY TRANSACTION REPORTS.
1. Each quarter, you must report all of your SECURITIES
transactions effected, as well as any securities
accounts you established, during the quarter. Access
persons are only allowed to have accounts with
Coronation Securities Limited. You must submit your
report to the Compliance Officer NO LATER THAN 10
days after the end of each calendar quarter.
2. If you had no reportable transactions and did not
open any securities accounts during the quarter, you
are still required to submit a report. Please note on
your report that you had no reportable items during
the quarter, and return it, signed and dated.
3. You need not submit a quarterly report if the report
would duplicate information contained in broker trade
confirmations or account statements received by the
Fund, provided that all required information is
contained in the broker trade confirmations or
account statements and is received by the Compliance
Officer NO LATER THAN 10 days after the end of the
calendar quarter. Please see the Compliance Officer
for more information about this reporting mechanism.
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B. WHAT SECURITIES TRANSACTIONS AND ACCOUNTS ARE COVERED UNDER THE
QUARTERLY REPORTING OBLIGATION?
You must report all transactions in SECURITIES that: (i) you
directly or indirectly BENEFICIALLY OWN; or (ii) because of
the transaction, you acquire direct or indirect BENEFICIAL
OWNERSHIP. You must also report all of your accounts in which
any securities were held for your direct or indirect benefit.
C. WHAT SECURITIES AND TRANSACTIONS MAY BE EXCLUDED FROM THE REPORT?
You are not required to detail or list the following items on
your reports:
1. Purchases or sales effected for any account over which you
have no direct or indirect influence or control;
2. Purchases you made solely with the dividend proceeds
received in a dividend reinvestment plan or that are part of
an automatic payroll deduction plan, where you purchased a
SECURITY issued by your employer;
3. Purchases effected on the exercise of rights issued by an
issuer PRO RATA to all holders of a class of its SECURITIES,
as long as you acquired these rights from the issuer, and
sales of such rights;
4. Purchases or sales which are non-volitional, including
purchases or sales upon the exercise of written puts or calls
and sales from a margin account pursuant to a BONA FIDE
margin call; and
5. Purchases or sales of any of the following securities:
- Banker's acceptances, bank certificates of deposit,
commercial paper and HIGH QUALITY SHORT-TERM DEBT
INSTRUMENTS, including repurchase agreements; and
- Shares issued by registered, open-end investment companies.
