CLEMENTY ASSET MANAGEMENT LLP adheres to the Asset Manager Code of Professional Conduct provided for by the CFA Institute.

 

 

1. LOYALTY TO CLEMENTY ASSET MANAGEMENT LLP FUNDING FAMILIES 

 

CLEMENTY DOES::

• Place funding families’ interests before its own.
• Preserve the confidentiality of information communicated by funding families within the scope of the Manager–funder relationship.
• Refuse to participate in any business relationship or accept any gift that could reasonably be expected to affect their independence, objectivity, or loyalty to funding families.

 

1. INVESTMENT PROCESS AND ACTIONS

 

CLEMENTY ASSET MANAGEMENT LLP MANAGERS must:

• Use reasonable care and prudent judgment when managing Funding Families’ assets.
• Not engage in practices designed to distort prices or artificially inflate trading volume with the intent to mislead market participants.
• Deal fairly and objectively with all Funding Families when providing investment information, making investment recommendations, or taking investment action.
• Have a reasonable and adequate basis for investment decisions.

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 the Funding Families:

• Evaluate and understand the Funding Families’ 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.
• Determine that an investment is suitable to a Funding Family’s financial situation.

 

 

 

1. TRADING

 

CLEMENTY ASSET MANAGEMENT LLP MANAGERS must:

• Not act or cause others to act on material non-public information that could affect the value of a publicly traded investment.
• Give priority to investments made on behalf of the Funding Families over those that benefit the Managers’ own interests.
• Use commissions generated from Funding Families 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.
• Maximize Funding Families’ portfolio value by seeking best execution for all Funding Families transactions.
• Establish policies to ensure fair and equitable trade allocation among Funding Families accounts.

 

 

1. RISK MANAGEMENT, COMPLIANCE, AND SUPPORT

 

CLEMENTY ASSET MANAGEMENT LLP MANAGERS must:

• 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.
• Appoint a compliance officer responsible for administering the policies and procedures and for investigating complaints regarding the conduct of the Manager or its personnel.
• Ensure that portfolio information provided to Funding Families by the Manager is accurate and complete and arrange for independent third-party confirmation or review of such information.
• Maintain records for an appropriate period of time in an easily accessible format.
• Employ qualified staff and sufficient human and technological resources to thoroughly investigate, analyze, implement, and monitor investment decisions and actions.
• Establish a business-continuity plan to address disaster recovery or periodic disruptions of the financial markets.
• 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 risk exposure.

 

 

1. PERFORMANCE AND VALUATION

 

CLEMENTY ASSET MANAGEMENT LLP MANAGERS must:

• Present performance information that is fair, accurate, relevant, timely, and complete. Managers must not misrepresent the performance of individual portfolios or of their firm.
• Use fair-market prices to value Funding Families holdings and apply, in good faith, methods to determine the fair value of any securities for which no independent, third-party market quotation is readily available.

 

 

 

1. DISCLOSURES

 

CLEMENTY ASSET MANAGEMENT LLP MANAGERS must:

1. Communicate with Funding Families 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 Funding Families regarding themselves, their personnel, investments, or the investment process.
4. Disclose the following:

• Conflicts of interests generated by any relationships with brokers or other entities, other Funding Families accounts, fee structures, or other matters.
• Regulatory or disciplinary action taken against the Manager or its personnel related to professional conduct.
• The investment process, including information regarding lock-up periods, strategies, risk factors, and use of derivatives and leverage.
• 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.
• 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 Funding Families.
• The performance of Funding Families’ investments on a regular and timely basis.
• Valuation methods used to make investment decisions and value Funding Families holdings.
• Shareholder voting policies.
• Trade allocation policies.
• Results of the review or audit of the fund or account.
• Significant personnel or organizational changes that have occurred at the Manager.
• Risk management processes.