Investment In The Same Securities As Clients
Our firm and our employees may buy or sell securities identical to those we recommend to you. We also own and operate a company owned portfolio with some of the same securities that the firm is recommending to you. The company owned portfolio could be used as a reference to show how the firm’s investment recommendations are performing. We have a policy that no person employed by us may purchase or sell a security in such a way as to disadvantage you. We have established the following procedures to avoid a conflict of interest so that we can meet our fiduciary responsibilities to you:
Our firm and employees shall not buy or sell securities for their portfolios when their decision is derived from information gathered while working at our firm, unless the information is also available to the investing public on inquiry.
- Our firm and employees shall not make any personal gain from the market impact of a trade by our firm on your behalf.
- We maintain a list of securities holdings for everyone associated with our firm. We review employee transactions on a regular basis.
- We require that our employees act in accordance with applicable federal and state laws, and rules and regulations governing registered investment advisory practices.
- Employees not in observance of the above are subject to termination.
Timing Of The Firm’s Or Related Person’s Trading
We allow our firm and employees to trade securities at the same time we trade for you, if the trading is done as part of an allocated trade where clients and the firm/employees are on equal footing. We do not allow the firm and our employees to use trading to take advantage of clients, and we and they cannot knowingly trade before clients.