CODE OF ETHICS OVERVIEW
While many Advisers Act rules are principles-based – meaning it’s up to the registered entity to put policies in place to reasonably comply with the intent of the rule – there exists a clear requirement for all registered advisers to establish, maintain and enforce a written code of ethics.
 
The relevant Advisers Act rule is rule 204A-1 (investment adviser codes of ethics).
 
You code should fit your firm, although there are certain provisions that must, at a minimum, be addressed. For example, your COEs must speak to a standard of “business conduct” for your “supervised persons.” It must contain provisions requiring your supervised persons to comply with applicable securities laws, to report their personal securities transactions and alert compliance to code violations. It is this rule that holds compliance “or other persons” to review staff personal trading reports, provide the code to employees and to receive back a written acknowledgement of that receipt.

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