道德规范

根据《澳门金沙城官方赌城》第204A-1条, 澳门金沙城官方赌城(CIC)采用本道德规范. The rule requires an adviser’s code of ethics to set forth standards of conduct and to require compliance with federal securities laws, and is designed to prevent fraud by reinforcing fiduciary principles that must govern the conduct of advisory firms and their personnel.

 

道德规范程序及描述:

 

A. 行为标准和遵守法律

204规则下的a - 1, CIC sets forth this standard of business conduct that it requires of all its supervised persons, reflecting the fiduciary obligations of the firm and those of its access persons and employees. The purpose of the code of ethics is to impart to employees the importance of their fiduciary responsibility to the client, and to verify compliance with this fiduciary responsibility through review of holdings and transaction reports. CIC will foster a culture of openness and honesty among its employees and reinforce the importance of our duty to always act in the best interests of the client.

 

B. 重大非澳门金沙城官方赌城的保护

CIC的所有员工将受澳门赌城app在线的约束 隐私政策. 员工不会分享, 传播或使用有关中投公司证券推荐的重大非澳门金沙城官方赌城, 客户证券持有及交易, 或任何非公开的客户相关信息, 除非客户和公司都有明确的授权.

 

C. 个人证券交易

Each employee must hold their personal securities accounts and any accounts of immediate family members at CIC, or obtain specific approval to hold these accounts elsewhere and supply duplicate statements to CIC. These accounts will be reviewed by a compliance officer for personal securities transactions and holdings that may reflect improper trades or patterns of trading by access persons.

 

1.个人交易程序

  • CIC will maintain a “restricted list” of issuers about which the advisory firm has inside information, 禁止这些发行人的任何证券交易(个人或客户).
  • CIC will require employees to trade only through brokerage accounts that are reviewed by compliance.
  • CIC will require employees to provide the compliance department with duplicate trade confirmations and account statements.

 

2. “查阅人员”须符合报告规定

204规则下的a - 1, 顾问守则必须要求某些受监督的人, “访问的人,报告其个人证券交易及持有情况. An access person is a supervised person who has access to nonpublic information regarding clients’ purchase or sale of securities, is involved in making securities recommendations to clients or who has access to such recommendations that are nonpublic. A supervised person who has access to nonpublic information regarding the portfolio holdings of affiliated mutual funds is also an access person. CIC将所有员工视为访问人员,因为所有人都有广泛的责任.

 

3. 持有的报告

Each access person’s securities holdings must be available to compliance for review periodically and at least once a year. 这家商行在哪里记账, 该公司将有无限的权限审查这些报告. 当获准持有外部账户时, 该公司必须收到一式两份的报表, 并且必须每年至少收到一份声明,显示账户中的资产.

 

4. 季度交易报告

中投公司将不要求员工提供单独的季度交易报告, provided all information is contained in trade confirmations or account statements that CIC holds in its records, and provided CIC has received those confirmations or statements not later than 30 days after the close of the calendar quarter in which the transaction takes place.

 

5. 报告规定的例外情况

根据规则204A-1,中投将允许个人证券报告的这些例外情况. 无需提交报告:

  • 根据自动投资计划进行的交易.
  • With respect to securities held in accounts over which the access person had no direct or indirect influence or control

 

6. 可报告的证券

Access persons must submit holdings and transaction reports for “reportable securities” in which the access person has, 或获得, 任何直接或间接受益所有权. An access person is presumed to be a beneficial owner of securities that are held by his or her immediate family members sharing the access person’s household.

规则204A-1将所有证券视为可报告证券, with five exceptions designed to exclude securities that appear to present little opportunity for the type of improper trading that the access person reports are designed to uncover:

  • 美国政府的直接债务的交易和持有.
  • 货币市场工具-银行承兑汇票, 银行存单, 商业票据, 回购协议和其他高质量短期债务工具.
  • 货币市场基金的股份.
  • 其他类型共同基金的交易和持股.
  • Transactions in units of a unit investment trust if the unit investment trust is invested exclusively in unaffiliated mutual funds.

 

D. 首次公开发行和非公开配售

CIC requires that access persons obtain the Chief Compliance Officer’s approval before investing in an initial public offering (“IPO”) or private placement.

 

E. 报告违反

Violations to this 道德规范 will be reported promptly to the chief compliance officer or his/her designee. Where someone other than the chief compliance officer is designated to receive reports of violations, 首席合规官还将定期收到所有违规行为的报告.

 

F. 教育员工关于道德规范

每个被监督的人都将以书面形式确认其已收到《澳门金沙城官方赌城》. CIC will hold periodic training sessions with new and existing employees to remind them of their obligations under the code, 会要求员工证明他们已经阅读并理解道德规范吗, 并要求员工每年重新阅读证书, 理解并遵守本守则.

 

G. 审查和执行

CIC’s chief compliance officer will be responsible for maintaining and enforcing the Codes of Ethics. 执行守则将包括审查访问人员的个人证券报告. Review of personal securities holding and transaction reports will include 1) an assessment of whether the access person followed required internal procedures, 比如预先结算和禁止在受限名单上交易证券, and 2) an assessment of whether the access person is trading for his own account in the same securities he is trading for clients.

 

H. 保留记录

中投公司将保留其《澳门金沙城官方赌城》的副本, 违反规范的记录和因违反而采取的行动, 以及被监督人员收到代码的书面确认副本. CIC will also keep a record of the holdings and transaction reports made by access persons, and records of decisions approving access persons’ acquisition of securities in IPOs and limited offerings.

CIC will retain these records for the standard retention period required for books and records under rule 204-2: five years, 在一个容易到达的地方, 前两年在合适的投资顾问办公室工作.

 

I. 修订表格ADV

CIC will provide on Part II of Form ADV a description of the 道德规范 for clients and, 要求, 是否会向客户提供一份《澳门赌城app在线》. 这一披露将有助于客户了解中投公司的道德文化和标准, how CIC controls sensitive information and the steps CIC has taken to prevent employees from misusing their inside positions at clients’ expense.

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