The policy requires client and company information to remain confidential during and after a business or employment relationship. It covers client profiles, portfolios, financial records, proprietary processes, vendor information, intellectual property and other non-public information.
Material non-public information and details of pending client orders or strategies must be handled with particular care. Directors, sponsors and employees may not trade using insider information or disclose it to unauthorized people. Information may be released only with authorization or where required by law.
Business records and communications must be accurate, timely and complete. Only authorized representatives may speak for the company to the media, investors or regulators. Employees must also protect company assets and may not use confidential information or corporate opportunities for personal benefit.
The policy further addresses external employment, competing interests, corruption, gifts and professional conduct. Outside work and significant interests require prior approval where relevant, while inducements that could impair judgment are prohibited.
This summary is for convenience and does not replace the approved document. If there is any difference, the complete PDF governs.