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CODE OF ETHICS
An investment professional should conduct himself with integrity and dignity and
act in an ethical manner in his dealings with the public, clients, customers,
employers, employees, and fellow investment professionals.
An investment professional should conduct himself and should encourage others to
practice investment analysis in a professional and ethical manner that will
reflect credit on him and his profession.
An investment professional should act with competence and should strive to
maintain and improve his competence and that of others in the profession.
An investment professional should use proper care and exercise independent
professional judgment.
STANDARDS OF PROFESSIONAL CONDUCT
COMPLIANCE WITH GOVERNING LAWS/REGULATIONS AND THE CODE AND STANDARDS
REQUIRED KNOWLEDGE AND COMPLIANCE. The investment professional shall maintain
knowledge of and shall comply with all applicable laws, rules, and regulations
of any government, governmental agency, and regulatory organization governing
his professional, financial, or business activities, as well as with these
Standards of Professional Conduct and the accompanying Code of Ethics.
PROHIBITION AGAINST ASSISTING LEGAL AND ETHICAL VIOLATIONS. The investment
professional shall not knowingly participate in, or assist, any acts in
violation of any applicable law, rule, or regulation of any government,
governmental agency, or regulatory organization governing his professional,
financial, or business activities, nor any act which would violate any
provision of these Standards of Professional Conduct or the accompanying Code
of Ethics.
PROHIBITION AGAINST USE OF MATERIAL NONPUBLIC INFORMATION. The investment
professional shall comply with all laws and regulations relating to the use and
communication of material nonpublic information. The investment professional's
duty is generally defined as to not trade while in possession of, nor
communicate, material nonpublic information in breach of a duty, or if the
information is misappropriated. Duties under the Standard include the following:
(1) If the investment professional acquires such information as a result of a
special or confidential relationship with the
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issuer or others, he shall not communicate the information (other than within
the relationship), or take investment action on the basis of such information,
if it violates that relationship. (2) If the investment professional is not in
a special or confidential relationship with the issuer or others, he shall not
communicate or act on material nonpublic information if he knows, or should have
known, that such information (a) was disclosed to him, or would result in a
breach of a duty; or (b) was misappropriated. If such a breach of duty exists,
the investment professional shall make reasonable efforts to achieve public
dissemination of such information.
RESPONSIBILITIES OF SUPERVISORS. An investment professional with supervisory
responsibility shall exercise reasonable supervision over those subordinate
employees subject to his control, to prevent any violation by such persons of
applicable statutes, regulations, or provisions of the Code of Ethics or
Standards of Professional Conduct. In so doing, the investment professional is
entitled to rely upon reasonable procedures established by his employer.
RESEARCH REPORTS, INVESTMENT RECOMMENDATIONS AND ACTIONS
REASONABLE BASIS AND REPRESENTATIONS.
1. The investment professional shall exercise diligence and thoroughness in
making an investment recommendation to others or in taking an investment action
for others.
2. The investment professional shall have a reasonable and adequate basis for
such recommendations and actions, supported by appropriate research and
investigations.
3. The investment professional shall make reasonable and diligent efforts to
avoid any material misrepresentation in any research report or investment
recommendation.
4. The investment professional shall maintain appropriate records to support the
reasonableness of such recommendations and actions.
RESEARCH REPORTS
1. The investment professional shall use reasonable judgment as to the inclusion
of relevant factors in research reports.
2. The investment professional shall distinguish between facts and opinions in
research reports.
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PORTFOLIO INVESTMENT RECOMMENDATIONS AND ACTIONS
1. The investment professional shall, when making an investment recommendation
or taking an investment action for a specific portfolio or client, consider its
appropriateness and suitability for such portfolio or client. In considering
such matters, the investment professional shall take into account (a) the needs
and circumstances of the client, (b) the basic characteristics of the investment
involved, and (c) the basic characteristics of the total portfolio. The
investment professional shall use reasonable judgment to determine the
applicable relevant factors.
2. The investment professional shall distinguish between facts and opinions in
the presentation of investment recommendations.
3. The investment professional shall disclose to clients and prospective clients
the basic format and general principles of the investment processes by which
securities are selected and portfolios are constructed and shall promptly
disclose to clients any changes that might significantly affect these processes.
PROHIBITION AGAINST PLAGIARISM
The investment professional shall not, when presenting material to his employer,
associates, customers, clients, or the general public, copy or use in
substantially the same form material prepared by other persons without
acknowledging its use and identifying the name of the author or publisher of
such material. The investment professional may, however, use without
acknowledgment, factual information published by recognized financial and
statistical reporting services or similar sources.
PROHIBITION AGAINST MISREPRESENTATION OF SERVICES
The investment professional shall not make any statements, orally or in writing,
which misrepresent (1) the services that the investment professional or his
firm is capable of performing for the client, (2) the qualifications of such
investment professional or his firm or (3) the expected performance of any
investment.
The investment professional shall not make, orally or in writing, explicitly
or implicitly, any assurances about or guarantees of any investment or its
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return except communication of accurate information as to the terms of the
investment instrument and the issuer's obligations under the instrument.
PERFORMANCE PRESENTATION STANDARDS
1. The investment professional shall not make any statements, oral or written,
which misrepresent the investment performance that the investment professional
or his firm has accomplished or can reasonably be expected to achieve.
2. If an investment professional communicates directly or indirectly
individual or firm performance information to a client or prospective client,
or in a manner intended to be received by a client or prospective client
("Performance Information"), the investment professional shall make every
reasonable effort to assure that such performance information is a fair,
accurate and complete presentation of such performance.
3. An investment professional presenting Performance Information may use the
following legend on the Performance Information presentation, but only if the
investment professional has made every reasonable effort to assure that such
presentation is in compliance with the Performance Presentation Standards in all
material respects:
THIS REPORT HAS BEEN PREPARED AND PRESENTED IN COMPLIANCE WITH THE PERFORMANCE
PRESENTATION STANDARDS OF THE ASSOCIATION FOR INVESTMENT MANAGEMENT AND
RESEARCH.
FAIR DEALING WITH CUSTOMERS AND CLIENTS
The investment professional shall act in a manner consistent with his obligation
to deal fairly with all customers and clients when (1) disseminating investment
recommendations, (2) disseminating material changes in prior investment advice,
and (3) taking investment action.
PRIORITY OF TRANSACTIONS
The investment professional shall conduct himself in such a manner that
transactions for his customers, clients, and employer have priority over
transactions in securities or other investments of which he is the beneficial
owner, and so that transactions in securities or other investments in which he
has such beneficial ownership do not operate adversely to their interests. If an
investment professional decides to make a recommendation about the purchase or
sale of a security or other investment, he shall give his
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customers, clients, and employer adequate opportunity to act on this
recommendation before acting on his own behalf.
For purposes of these Standards of Professional Conduct, an investment
professional is a "beneficial owner" if he directly or indirectly, through any
contract, arrangement, understanding, relationship or otherwise, has or shares a
direct or indirect pecuniary interest in the securities or the investment.
DISCLOSURE OF CONFLICTS
The investment professional, when making investment recommendations, or taking
investment actions, shall disclose to his customers and clients any material
conflict of interest relating to him and any material beneficial ownership of
the securities or other investments involved that could reasonably be expected
to impair his ability to render unbiased and objective advice.
The investment professional shall disclose to his employer all matters that
could reasonably be expected to interfere with his duty to the employer, or with
his ability to render unbiased and objective advice.
The investment professional shall also comply with all requirements as to
disclosure of conflicts of interest imposed by law and by rules and regulations
of organizations governing his activities and shall comply with any prohibitions
on his activities if a conflict of interest exists.
COMPENSATION
DISCLOSURE OF ADDITIONAL COMPENSATION ARRANGEMENTS
The investment professional shall inform his customers, clients, and employer of
compensation or other benefit arrangements in connection with his services to
them which are in addition to compensation from them for such services.
DISCLOSURE OF REFERRAL FEES
The investment professional shall make appropriate disclosure to a prospective
client or customer of any consideration paid or other benefit delivered to
others for recommending his services to that prospective client or customer.
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DUTY TO EMPLOYER
The investment professional shall not undertake independent practice which could
result in compensation or other benefit in competition with his employer unless
he has received written consent from both his employer and the person for whom
he undertakes independent employment.
RELATIONSHIPS WITH OTHERS
PRESERVATION OF CONFIDENTIALITY
An investment professional shall preserve the confidentiality of information
communicated by the client concerning matters within the scope of the
confidential relationship, unless the investment professional receives
information concerning illegal activities on the part of the client.
MAINTENANCE OF INDEPENDENCE AND OBJECTIVITY
The investment professional, in relationships and contacts with an issuer of
securities, whether individually or as a member of a group , shall use
particular care and good judgment to achieve and maintain independence and
objectivity.
FIDUCIARY DUTIES
The investment professional, in relationships with clients, shall use particular
care in determining applicable fiduciary duty and shall comply with such duty as
to those persons and interests to whom it is owed.
PROFESSIONAL MISCONDUCT
The investment professional shall not (1) commit a criminal act that upon
conviction materially reflects adversely on his honesty, trustworthiness or
fitness as an investment professional in other respects, or (2) engage in
conduct involving dishonesty, fraud, deceit or misrepresentation.
