Ethics Notes

Ethics

Integrity is paramount and clients always come first.

Use reasonable care; be independent.

Be a credit to the investment profession

Competence

Violations, not required to report to gov authorities

Misconduct, may not be illegal

Mosaic Theory, no violation when an analyst combines non-material non-public infor with public inf to reach conclusion.

Clients first, you last

Comply with any applicable fiduciary duty.

Manage pools of client assets according to terms of governing docments.

Vote proxies responsibly and disclose proxy voting policies to clients.

“Soft dollars” must benefit client (出于对监管当局制定的规则的遵守和防止价格恶性竞争，经纪商通常都会保持交易佣金水平，但是为了吸引客户进行交易，往往私下里为客户提供一定的优惠，如提供研究报告及其他优惠等。这种优惠一般采取非现金形式，因此，被称为“软美元”)

Shorten time frame-decision to dissemination

Simultaneous dissemination.

Suitability: suitable? Authorisable?

Prepare IPS (constrains, objectives, risk tolerance…), update it at least annually

Performance presentation: consider audience sophistication when presenting performance; use performance of the weighted composite of similar portfolios; include terminated acc as pt of historical performance; make all disclosures and maintain records.

Preservation of Confidentiality: except sometimes may need to disclose to CFAI

Responsibilities of supervisors: continually educate staff

Diligence and reasonable basis during investment analysis, recommendations and actions （懒惰，麻烦，于是不做）——high standard best: establish policy and review before external circulation; no need to dissociate from group research that the member disagrees with(但是如果大多数反对，而为了公司利益而这样做，则除外)

Communication with clients and prospective clients: disclose basic format and any changes

Record retention: appropriate records to support investment analysis, recommendations, actions and other investment-related communications with clients and prospective clients.

If no regulatory requirement, CFAI recommends retention period of 7 years.

Responsibility...