CONCENTRATED CAPITAL MANAGEMENT, L.P.
Code Of Ethics
Concentrated Capital Management, L.P. ("CCM") has established this Code of
Ethics ("Code") to formalize standards for general personal and professional
conduct while setting forth basic ethical business practices by which every
employee is expected to comply.
A. Statement of Principles
The following principles are intended to guide in the applicability of this Code
of Ethics:
1. CCM is a fiduciary and has a duty to act solely for the benefit of its
clients and shall at all times place the interests of the client
first.
2. CCM holds employees responsible to the highest standards of integrity,
professionalism, and ethical conduct.
3. CCM fosters a spirit of cohesiveness and teamwork while ensuring the
fair treatment of all employees.
B. Conflicts of Interest
As a fiduciary, CCM has an affirmative duty of loyalty and honesty to its
clients and a duty of utmost good faith to act solely in the best interests of
the client. Compliance with this fiduciary responsibility can be accomplished by
avoiding unnecessary conflicts of interest and by fully, adequately, and fairly
disclosing all material facts concerning any conflict which does arise as to
each client. Employees are to actively avoid any existing or potential conflicts
or situations that have the appearance of conflict or impropriety.
The following specific guidelines should not be viewed as all encompassing and
are not intended to be exclusive of others:
1. All securities transactions effected for the benefit of an employee or
an associated person shall be conducted in such a manner as to avoid
any actual or potential conflict of interest or abuse of an
individual's position of trust and responsibility. An associated
person includes an employee's spouse, minor children, and adult
members of their household, or any person or organization with which
the employee has a direct or indirect personal relationship or
beneficial interest, or any trusts of which they are trustees or in
which they have a beneficial interest.
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2. No employee shall take inappropriate advantage of their position with
respect to a client, advancing their own or a related person's
position for self-gain.
3. No employee shall accept any gift for themselves or a related person
of more than de minimis value from any person or entity that does
business with or on behalf of a client (or any of its portfolios) or
any entity that provides a service to CCM. Gifts of an extraordinary
or extravagant nature to an employee are to be declined or returned in
order not to compromise the reputation of CCM or the employee. Gifts
of nominal value, or those that are customary in the industry, are
considered appropriate.
4. No employee or related person shall provide gifts or entertainment of
more than de minimis value to existing clients, prospective clients,
or any entity that does business with or on behalf of the client (or
any of its portfolios) or any entity that provides a service to CCM.
Gifts of nominal value, or those that are customary in the industry,
are considered appropriate.
5. Pre-approval is required for any employee to serve as a director of
any publicly traded company or mutual fund.
C. Confidentiality
All information obtained by any employee regarding any aspect of the client
relationship shall be kept in strict confidence. The employee commits an
unethical business practice by disclosing the identity, affairs, or investments
of any client unless required by the Securities and Exchange Commission or any
other regulatory or self-regulating organization to the extent required by law
or regulation, or unless disclosure is consented to by the client.
D. Insider Trading
No employees may trade, either personally or on behalf of others, while in
possession of material, nonpublic information; nor may any employee communicate
material, nonpublic information to others in violation of the law.
Compliance with this policy is mandatory for all employees. Employees should
refer to the Policy Statement on Insider Trading (copy attached) for detailed
information on CCM's position.
E. Personal Trading Policy
CCM's Personal Trading Policy incorporates the amendments to Rule 17j-1 under
the Investment Company Act of 1940 as adopted and in effect as of October 29,
1999.
Compliance with this policy is mandatory for all employees. Employees should
refer to the Personal Trading Policy (copy attached) for detailed information on
CCM's position.
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F. Treatment of Employees
CCM is committed to treating all employees in a fair and equitable manner.
Employees are encouraged to voice concerns regarding any personal or
professional issue that may impact their ability or the firm's ability to
provide a quality product to our clients while operating under the highest
standards of integrity.
G. Sanctions
Regardless of whether a government inquiry occurs, CCM views seriously any
violation of its Code of Ethics. Disciplinary sanctions may be imposed on any
employee committing a violation, including, but not necessarily limited to,
censure, suspension, or termination of employment.
H. Annual Reviews and Certification of Compliance with the Code
CCM will review the Code of Ethics annually and update any provisions and/or
attachments which the Board of Trustees deems to require revision. An annual
report will be provided which describes issues that arouse during the prior
year, including but not limited to, violations of the Code and sanctions therein
imposed, and which certifies that procedures have been adopted to prevent access
persons from violating said Code.
To insure CCM's certification, upon employment, all new employees will be
required to certify that they have:
1. Received a copy of the Code;
2. Read and understand all provisions of and all attachments to the Code;
and
3. Agreed to serve the client in accordance with the terms of the Code.
Additionally, all employees are required annually to:
1. Certify they have read and understand all provisions of the Code; and
2. Agree to comply with all provisions of the Code.
I. Further Information
If any employee has any questions with regard to the applicability of the
provisions of this Code, generally or with regard to any attachment referenced
herein, (s)he should consult the Compliance Officer.
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