B1_1

The Asset Manager Code (AMC) applies to investment firms, not individuals

Loyalty to clients

Investment Process and Actions

Trading

Risk Management, Complicance, and Support

Performance and Valuation

Disclosures

Always act ethically aand professionally

Act in the best interest of the client

Act in an objective and independent manner

Perform actions using skill, competence, and diligence

Communicate accurately with clients on a regular basis

Comply with legal and regulatory requirements regarding capital markets

A1 Place the clients interests ahead of the firms in all aspects of the relationship - selecting investments, transacting etc.

A2 Maintain client confidentiality. However, there may be exceptions regarding potentially illegal activities occurring in clien accounts, which may need to be reported

A3 Refuse business relationships and gifta that would compromise independence, objectivity, and loyalty to clients (even in appearance). Only items of nominal value may be accepted. The firm may maintain other (signigicant) business relationships with the same client, assuming potential conflicts are mitigated and disclosed.

B1: Use reasonable care and judgment when managing client assets

B2: Do not manupulate securities prices and volumes to try to mislead market participants, as it damages the integrity of markets to the detriment of all investors

B3: Deal fairly and objectively with all clients when providing information, givind advice and taking actions. Managers may offer higher levels of service to some clients for higher compensation if the service levels are disclosed and available to all clients willing to pay for them. Managers may engage in secondary investment opportunities (that are offered because of other business activities) if the opportunities are fairly allocated to all suitable clients

B4: Have a reasonable and adequate basis for recommendations. Third-Party resarch can be used if reasonable

B5a: For portfolios managed to a specific style or strategy, managers do not have to evaluate the suitability to given client. Managers must provide suitable disclosure so clients can determine if the portfolio is suitable for their needs. 

B5b: Material changes to strategies and styles must be provided to clients as far in advance as possible.

B6a: When managing portfolios of a specific client, understand the clients objectives, constraints and any other pertinent information to be able to take suitable investment actions for that client

B6b: Client portfolios should contain only investments that are suitable for those clients.

C1: Do not acto or cause others to act on material nonpublic information that could affect the value of public securities. However, the use of mosaic theory - material public information and nonmaterial nonpublic information - is acceptable

C2: Managers cannot execute ahead of clients or to the detriment of clients interest

C3: Use client commissions - which belong to the client - only to pay for investment decision making products and services that directly benefit the client not for the management of the firm

C4: Seek best execution for all client trades

C5: Establish policies for fair and equitable trade allocation. All clients for whom the trade is suitable should be given the opportunity to participate.

D1: Develop detailed policies and procedures to comply with the AMC and all legal and regulatory requirements

D2: Appoint a competent, knowledgeable, credible compliance officer with authority to implement the P&Ps

D3: Use an independent third party to verify that information provided to clients is accurate and complete.

D4: Maintain records to document investment actions.

D5: Employ sufficient and qualified staff to meet all AMC requirements. Outsourcing of some tasks is acceptable, but the firm remains ultimately responsible for all outsourced tasks.

D6: Establish a business conitnuity plan.

D7: Establish a firmwide risk management plan to measure and manage the risks taken

E1: Present performance data that is fair, accurate, relevant, timely, and complete. Do not misrepresent performance of accounts or the firm

E2: Use fair market prices when available and commonly used valuation methods in other cases.