Managers have thefollowing 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 andaccurate manner.

6. Uphold the applicable rules governing capitalmarkets.


Asset Manager Code of Professional Conduct

A. Risk Management,Compliance, and Support Managers must:

1. Ensurethat portfolio information provided to clients by the Manager is accurate and completeand arrange for independent third-partyconfirmation or review of such information.

2.Employ qualified staff and sufficienthuman and technological resources to thoroughly investigate, analyze,implement, and monitor investment decisions and actions.

3.Establish a business-continuity plan toaddress disaster recovery or periodicdisruptions of the financial markets.

4.Establish a firmwide risk management process that identifies, measures, and manages therisk position of the Manager and its investments, including the sources, nature, and degree of riskexposure.

B. Performance andValuation Managers must:

Use fair-market prices to value client holdings andapply, in good faith, methods to determine the fair value of any securities for which no independent, third-party marketquotation is readily available.

C. Disclosures Managersmust:

Disclose the following:

a) Regulatoryor disciplinary action taken against the Manager or its personnel related to professional conduct.

b) The investment process, includinginformation regarding lock-up periods,strategies, risk factors, and use ofderivatives and leverage.

c) Management fees and other investment costs charged to investors, including whatcosts are included in the fees andthe methodologiesfor determining fees

and costs.

d) Theamount of any soft or bundled commissions, the goodsand/or services

received in return, and how those goods and/or services benefit the client.

e) Valuation methods usedto make investment decisions andvalue client holdings.

f) Results of the reviewor audit of the fund or account.

g) Significant personnel ororganizational changes that have occurred at the Manager.

h) Risk managementprocesses.

来自：金程CFA