A.    Loyalty to Clients Managers must:

1.      Placeclient interests before their own.

I.       Client interests are paramount. Managers should institute policies and procedures to ensure thatclient interests supersede Manager interests in all aspects of the Manager–clientrelationship, including (but not limitedto) investment selection, transactions, monitoring,and custody.

II.      Managers should take reasonable steps to avoid situations inwhich the Manager’s interests andclient interests conflict and should institute operational safeguards to protect client interests.

III.    Managers should implement compensation arrangements that align the financial interests of clients andManagers and avoid incentives that could result in Managers taking actionin conflict with client interests.

2.      Preservethe confidentiality of information communicated by clients within the scope ofthe Manager–client relationship.

I.         As part of their ethical duties,Managers must hold information communicated to them by clients or other sourceswithin the context of the Manager–client relationship strictly confidential and must take all reasonable measures topreserve that confidentiality. This duty applies when Managers obtaininformation on the basis of theirconfidential relationship with the client or their special ability to conduct a portion of the client’s businessor personal affairs.

II.      Managers should create a privacy policy that addresses how confidential client information will becollected, stored, protected, and used.

III.    The duty to maintain confidentialitydoes not supersede a duty (and insome cases the legal requirement) to report suspected illegal activitiesinvolving client accounts to the appropriateauthorities. Where appropriate, Managers should consider creating and implementinga written anti-money-laundering policyto prevent their organizations from being used for money laundering or the financing of any illegal activities.

3.      Refuse toparticipate in any business relationship or accept any gift that could reasonablybe expected to affect their independence, objectivity, or loyalty to clients.

I.         As part of holding clients’interests paramount, Managers must establish policies for accepting gifts or entertainment in a variety of contexts.

II.      To avoid the appearance of a conflict, Managers must refuse to accept gifts or entertainment from service providers, potential investmenttargets, or other business partnersof more than a minimal value. Managers should define what the minimum value is and should confer withlocal regulations which may also establish limits.

III.    Managers should establish a writtenpolicy limiting the acceptance of gifts and entertainment to items of minimalvalue.

IV.    Managers shouldconsider creating specific limits for accepting gifts (e.g., amount per time period per vendor) andprohibit the acceptance of any cashgifts.

V.      Employees should be required to document and disclose to the Manager,through their supervisor, the firm’scompliance office, or senior management, the acceptance of any gift or entertainment.

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