Examples of Investment Employee in a sentence
Investment Employees will generally not be given preclearance approval to execute a transaction in any security for which there is a pending buy or sale order for an affiliated account (other than an index fund) in the business unit where the Investment Employee has access to information about pending transactions.
Employees will be designated into one or more of the following classifications:Access Decision Maker Dreyfus/FINRA Employee Investment Employee Pre-Release Earning Group Insider Risk Employee Fund Officer Fund Service Employee Non-Classified Employees Service Employee U.S.-based employees must maintain their brokerage accounts with an approved broker-dealer.
Investment Employee An employee who, in the normal conduct of his/her job responsibilities, has access (or are likely to be perceived to have access) to nonpublic information regarding any advisory client’s purchase or sale of securities or nonpublic information regarding the portfolio holdings of any Proprietary Fund, is involved in making securities recommendations to advisory clients, or has access to such recommendations before they are public.
If one of these persons would be considered an Insider Risk Employee, Investment Employee or Access Decision Maker if he/she were a Mellon employee, the person’s manager should advise the Ethics Office and the Compliance Officer who will determine whether such individual should be subject to the preclearance and reporting requirements of the Policy.
Other Employee You are considered to be an Other Employee if you are an employee of Mellon or any of its direct or indirect subsidiaries who is not an Insider Risk Employee, Investment Employee, or an ADM.
Employees will be designated into one of the following classifications: Access Decision Maker Investment Employee Insider Risk Employee Other Employee It is the responsibility of each manager to communicate an employee’s classification and an employee’s obligation to confirm their classification with their manager, Compliance Officer or the Ethics Office.
In such circumstances, a decision to acquire securities of that issuer for client accounts must be reviewed independently by an Investment Employee with no personal interest in that issuer prior to placing an order.
For example, if an account contains only non-proprietary funds or other Exempt Securities, but has the capability to have reportable securities traded in it, the account must be reported and duplicate account statements and trade confirmations must be provided to Mellon.Initial Holdings Report – within 10 calendar days of being designated an Investment Employee or ADM, employees must file an “Initial Holdings Report”.
If no such Investment Employee exists, the transaction should not be effected for client accounts without specific client approval.
If one of these persons would be considered an Insider Risk Employee, Investment Employee or ADM if he/she were a Company employee, the person's manager should advise the Ethics Office and the Compliance Officer who will determine whether such individual should be subject to the preclearance and reporting requirements of the Policy.