ASSET MANAGER CODE
The CFA Institute Asset Manager Code outlines the ethical and professional responsibilities
of firms (“Managers”) that manage assets on behalf of clients. By adopting and enforcing a
code of conduct for their organizations, Managers demonstrate their commitment to ethical
behavior and the protection of investors’ interests.
GENERAL PRINCIPLES OF CONDUCT
Managers have the following responsibilities to their clients.
1. Act in a professional and ethical manner at all times.
2. Act for the benefit of clients.
3. Act with independence and objectivity.
4. Act with skill, competence, and diligence.
5. Communicate with clients in a timely and accurate manner.
6. Uphold the applicable rules governing capital markets.
A. LOYALTY TO CLIENTS
1. Place client interests before their own.
2. Preserve the confidentiality of information communicated by
clients within the scope of the Manager–client relationship.
3. Refuse to participate in any business relationship or accept
any gift that could reasonably be expected to affect their
independence, objectivity, or loyalty to clients.
B. INVESTMENT PROCESS AND ACTIONS
1. Use reasonable care and prudent judgment when managing
2. Not engage in practices designed to distort prices or
artificially inflate trading volume with the intent to mislead
3. Deal fairly and objectively with all clients when providing
investment information, making investment recommendations,
or taking investment action.
4. Have a reasonable and adequate basis for investment decisions.
ASSET MANAGER CODE
5. When managing a portfolio or pooled fund according to a specific
mandate, strategy, or style:
a. Take only investment actions that are consistent with the
stated objectives and constraints of that portfolio or fund.
b. Provide adequate disclosures and information so investors can
consider whether any proposed changes in the investment
style or strategy meet their investment needs.
6. When managing separate accounts and before providing
investment advice or taking investment action on behalf of
a. Evaluate and understand the client’s investment objectives,
tolerance for risk, time horizon, liquidity needs, financial
constraints, any unique circumstances (including tax
considerations, legal or regulatory constraints, etc.), and any
other relevant information that would affect investment policy.
b. Determine that an investment is suitable to a client’s
1. Not act or cause others to act on material nonpublic information
that could affect the value of a publicly traded investment.
2. Give priority to investments made on behalf of the client over
those that benefit the Managers’ own interests.
3. Use commissions generated from client trades to pay for only
investment-related products or services that directly assist the
Manager in its investment decision making process, and not in
the management of the firm.
4. Maximize client portfolio value by seeking best execution for all
5. Establish policies to ensure fair and equitable trade allocation
among client accounts.
D. RISK MANAGEMENT, COMPLIANCE, AND SUPPORT
1. Develop and maintain policies and procedures to ensure that their
activities comply with the provisions of this Code and all applicable
legal and regulatory requirements.
2. Appoint a compliance officer responsible for administering the
policies and procedures and for investigating complaints regarding
the conduct of the Manager or its personnel.
3. Ensure that portfolio information provided to clients by the
Manager is accurate and complete and arrange for independent
third-party confirmation or review of such information.
4. Maintain records for an appropriate period of time in an easily
5. Employ qualified staff and sufficient human and technological
resources to thoroughly investigate, analyze, implement, and
monitor investment decisions and actions.
6. Establish a business-continuity plan to address disaster recovery
or periodic disruptions of the financial markets.
7. Establish a firmwide risk management process that identifies,
measures, and manages the risk position of the Manager and
its investments, including the sources, nature, and degree of
E. PERFORMANCE AND VALUATION
1. Present performance information that is fair, accurate, relevant,
timely, and complete. Managers must not misrepresent the
performance of individual portfolios or of their firm.
2. Use fair-market prices to value client holdings and apply, in
good faith, methods to determine the fair value of any securities
for which no independent, third-party market quotation is
1. Communicate with clients on an ongoing and timely basis.
2. Ensure that disclosures are truthful, accurate, complete, and
understandable and are presented in a format that communicates
the information effectively.
3. Include any material facts when making disclosures or providing
information to clients regarding themselves, their personnel,
investments, or the investment process.
4. Disclose the following:
a. Conflicts of interests generated by any relationships with
brokers or other entities, other client accounts, fee structures,
or other matters.
b. Regulatory or disciplinary action taken against the Manager or
its personnel related to professional conduct.
c. The investment process, including information regarding
lock-up periods, strategies, risk factors, and use of derivatives
d. Management fees and other investment costs charged to
investors, including what costs are included in the fees and the
methodologies for determining fees and costs.
e. The amount of any soft or bundled commissions, the goods
and/or services received in return, and how those goods and/or
services benefit the client.
f. The performance of clients’ investments on a regular and
g. Valuation methods used to make investment decisions and
value client holdings.
h. Shareholder voting policies.
i. Trade allocation policies.
j. Results of the review or audit of the fund or account.
k. Significant personnel or organizational changes that have
occurred at the Manager.
l. Risk management processes.
NOTIFICATION OF COMPLIANCE
Managers must notify CFA Institute of their claim of compliance
through the Asset Manager Code claim of compliance form at
www.cfainstitute.org/assetcode. This form is for communication
and information-gathering purposes only and does not represent
that CFA Institute engages in enforcement or quality control of an
organization’s claim of compliance. CFA Institute does not verify
either the Manager’s claim of compliance or actual compliance
with the Code.
For additional information on complying, please visit
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