Personal Securities Transactions. Subadviser will comply in all material respects with Rule 17j-l under the 1940 Act. Upon reasonable request during any business day, Subadviser will promptly make available to Adviser or the Fund any reports concerning the Fund required to be made by Subadviser pursuant to Rule 17j-1 under the 1940 Act.
Personal Securities Transactions. The Sub-advisor will comply in all material respects with Rule l7j-l under the 1940 Act. Upon reasonable request during any business day, the Sub-advisor will promptly make available to the Advisor or the Fund any reports concerning the Fund required to be made by the Sub-advisor pursuant to Rule 17j-1 under the 1940 Act. On a quarterly basis, the Sub-advisor shall either certify in writing that there have been no violations of its Code of Ethics or identify in a written report any violations and the action(s) taken with respect thereto.
Personal Securities Transactions. Subadviser will comply in all material respects with Rule 17j-l under the 1940 Act and Rule 204A-1 of the Advisers Act. Upon reasonable request during any business day, Subadviser will promptly make available to Adviser or the Fund any reports concerning the Fund required to be made by Subadviser pursuant to Rule 17j-1 under the 1940 Act. Subadviser shall promptly inform Adviser and the Fund of any violations of Rule 204A-1 of the Advisers Act required to be reported under subsection (a)(4) of that Rule.
Personal Securities Transactions. Subadvisor shall comply in all material respects with Rule 17j-l under the 1940 Act and the Subadvisor's Code of Ethics. Upon reasonable request during any business day, Subadvisor will promptly make available to Advisor or the Fund any reports concerning the Fund required to be made by Subadvisor pursuant to Rule 17j-1 under the 1940 Act. On a quarterly basis, Subadvisor shall either certify that there have been no material violations of its Code of Ethics or identify any material violations.
Personal Securities Transactions. The personal transactions and investment activities of HCM PERSONNEL and employees of all investment advisory firms are the subject of various federal securities laws, rules and regulations. HCM PERSONNEL must accomplish all personal securities transactions in a manner that avoids a conflict between their personal interests and those of their CLIENTS or their CLIENTS' shareholders. When HCM PERSONNEL invest for their own accounts, conflicts of interest may arise between the CLIENTS and HCM PERSONNEL's interests. These conflicts may include: >> Taking an investment opportunity from the CLIENT for one's own portfolio >> Using one's advisory position to take advantage of available investments >> Front-running, which may include trading one's account before making CLIENT transactions >> Taking advantage of information or using a CLIENT'S portfolio assets in an attempt to influence or affect the market with the goal of taking personal advantage of the resulting market change MARKET TIMING AND LATE TRADING: HCM prohibits all HCM PERSONNEL from engaging in market timing or late trading when trading on behalf of its CLIENTS' accounts or HCM PERSONNEL's accounts.
Personal Securities Transactions. Access Persons must comply with the personal trading and reporting policies and procedures set forth in Appendix A to this Code.
Personal Securities Transactions. All personal securities transactions must be reviewed and approved by the Firm’s Chief Compliance Officer. Each IAR must have duplicate copies of any personal trading accounts sent to the CCO and must submit an annual report of security holdings, with the exclusion of mutual funds, money market funds and instruments, and unit investment trusts. This report should be submitted to the CCO via fax or email the first month of each year.
Personal Securities Transactions. 2.1 PRE-CLEARANCE BY ADVISORY PERSONS 6 2.2 BLACKOUT PERIODS 7 2.3 HIGHMARK FUND SHARES 7 2.4 INITIAL PUBLIC OFFERINGS AND LIMITED OFFERINGS 8
Personal Securities Transactions. All IARs and employees of First Affirmative must comply with the firm’s policies and procedures regarding personal securities transactions. Complete guidelines for personal securities transactions are contained in First Affirmative’s Written Supervisory Procedures Manual (provided to IARs and employees under separate cover). Specific areas of concern that must be avoided are:
Personal Securities Transactions. 2.1 PRE-CLEARANCE BY ADVISORY PERSONS 5 2.2 BLACKOUT PERIODS 6
