FSRankings has adopted the CFA Institute Asset Manager Code to guide its decision making. While the code was specifically designed for companies that directly manage money, FSRankings believes that the same basic principles, and indeed many of the rules, are applicable.

For more information about the CFA Institute Asset Manager Code, please visit this link.

All information provided at FSRankings has been reviewed by a CFA Charterholder. The CFA Charter is the most respected and recognized investment management designation in the world, per the CFA Institute.

https://www.cfainstitute.org/learning/products/publications/contributed/Pages/asset_manager_code.aspx

|Text of the CFA Institute Asset Manager Code|FSRankings Comments|
|–|–|
|ASSET MANAGER CODE OF PROFESSIONAL CONDUCT| |
The Asset Manager Code of Professional Conduct outlines the ethical and professional responsibilities of firms (“Managers”) that manage assets on behalf of clients. By adopting and enforcing a code of conduct for their organizations, Managers demonstrate their commitment to ethical behavior and the protection of investors’ interests.|

GENERAL PRINCIPLES OF CONDUCT
Managers have the following responsibilities to their clients.
Managers must:
1. Act in a professional and ethical manner at all times.
2. Act for the benefit of clients.
3. Act with independence and objectivity.
4. Act with skill, competence, and diligence.
5. Communicate with clients in a timely and accurate manner.
6. Uphold the applicable rules governing capital markets.
A. LOYALTY TO CLIENTS
Managers must:
1. Place client interests before their own.
2. Preserve the confidentiality of information communicated by
clients within the scope of the Manager–client relationship.
3. Refuse to participate in any business relationship or accept any
gift that could reasonably be expected to affect their independence,
objectivity, or loyalty to clients.
B. INVESTMENT PROCESS AND ACTIONS
Managers must:
1. Use reasonable care and prudent judgment when managing
client assets.
2. Not engage in practices designed to distort prices or artificially
inflate trading volume with the intent to mislead
market participants.
3. Deal fairly and objectively with all clients when providing investment
information, making investment recommendations, or taking
investment action.
4. Have a reasonable and adequate basis for investment decisions.
ASSET MANAGER CODE OF PROFESSIONAL CONDUCT
5. When managing a portfolio or pooled fund according to a specific
mandate, strategy, or style:
a. Take only investment actions that are consistent with the
stated objectives and constraints of that portfolio or fund.
b. Provide adequate disclosures and information so investors can
consider whether any proposed changes in the investment
style or strategy meet their investment needs.
6. When managing separate accounts and before providing investment
advice or taking investment action on behalf of the client:
a. Evaluate and understand the client’s investment objectives,
tolerance for risk, time horizon, liquidity needs, financial
constraints, any unique circumstances (including tax considerations,
legal or regulatory constraints, etc.) and any other
relevant information that would affect investment policy.
b. Determine that an investment is suitable to a client’s
financial situation.
www.cfainstitute.org
C. TRADING
Managers must:
1. Not act or cause others to act on material nonpublic information
that could affect the value of a publicly traded investment.
2. Give priority to investments made on behalf of the client over those
that benefit the Managers’ own interests.
3. Use commissions generated from client trades to pay for only
investment-related products or services that directly assist the
Manager in its investment decision making process, and not in the
management of the firm.
4. Maximize client portfolio value by seeking best execution for all
client transactions.
5. Establish policies to ensure fair and equitable trade allocation
among client accounts.
D. RISK MANAGEMENT, COMPLIANCE, AND SUPPORT
Managers must:
1. Develop and maintain policies and procedures to ensure that their
activities comply with the provisions of this Code and all applicable
legal and regulatory requirements.
2. Appoint a compliance officer responsible for administering the policies
and procedures and for investigating complaints regarding
the conduct of the Manager or its personnel.
3. Ensure that portfolio information provided to clients by the
Manager is accurate and complete and arrange for independent
third-party confirmation or review of such information.
4. Maintain records for an appropriate period of time in an easily
accessible format.
5. Employ qualified staff and sufficient human and technological
resources to thoroughly investigate, analyze, implement, and
monitor investment decisions and actions.
6. Establish a business-continuity plan to address disaster recovery
or periodic disruptions of the financial markets.
7. Establish a firmwide risk management process that identifies,
measures, and manages the risk position of the Manager and
its investments, including the sources, nature, and degree of
risk exposure.
E. PERFORMANCE AND VALUATION
Managers must:
1. Present performance information that is fair, accurate, relevant,
timely, and complete. Managers must not misrepresent the performance
of individual portfolios or of their firm.
2. Use fair-market prices to value client holdings and apply, in
good faith, methods to determine the fair value of any securities
for which no independent, third-party market quotation is
readily available.
F. DISCLOSURES
Managers must:
1. Communicate with clients on an ongoing and timely basis.
2. Ensure that disclosures are truthful, accurate, complete, and
understandable and are presented in a format that communicates
the information effectively.
3. Include any material facts when making disclosures or providing
information to clients regarding themselves, their personnel,
investments, or the investment process.
4. Disclose the following:
a. Conflicts of interests generated by any relationships with
brokers or other entities, other client accounts, fee structures,
or other matters.
b. Regulatory or disciplinary action taken against the Manager or
its personnel related to professional conduct.
c. The investment process, including information regarding
lock-up periods, strategies, risk factors, and use of derivatives
and leverage.
d. Management fees and other investment costs charged to
investors, including what costs are included in the fees and the
methodologies for determining fees and costs.
e. The amount of any soft or bundled commissions, the goods
and/or services received in return, and how those goods and/or
services benefit the client.
f. The performance of clients’ investments on a regular and
timely basis.
g. Valuation methods used to make investment decisions and
value client holdings.
h. Shareholder voting policies.
i. Trade allocation policies.
j. Results of the review or audit of the fund or account.
k. Significant personnel or organizational changes that have
occurred at the Manager.
l. Risk management processes.
NOTIFICATION OF COMPLIANCE
Managers must notify CFA Institute of their claim of compliance
through the Asset Manager Code of Professional Conduct claim of
compliance form at www.cfainstitute.org/assetcode. This form is
for communication and information-gathering purposes only and
does not represent that CFA Institute engages in enforcement or
quality control of an organization’s claim of compliance. CFA Institute
does not verify either the Manager’s claim of compliance or actual
compliance with the Code.
For additional information on complying, please visit
www.cfainstitute.org/assetcode.
© 2015 CFA Institute. All rights reserved.
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