Independently Developed. The party independently developed such information. In addition, the Subadviser and its officers, directors and employees are prohibited from receiving compensation or other consideration, for themselves or on behalf of a Fund, as a result of disclosing a Fund’s portfolio holdings. The Subadviser agrees, consistent with its Code of Ethics, it nor its officers, directors or employees may engage in personal securities transactions based on non-public information about a Fund’s portfolio holdings. The Adviser and Trust each understand, acknowledge, and agree that the Fund is managed by the Subadviser using investment models which are used by the Subadviser and its affiliates to manage other accounts (specifically including, but not limited to, other registered mutual funds), that such other accounts may have portfolio holdings that are substantially similar or identical to those of the Fund, and that the use of such other portfolio holdings information is not subject to the restrictions of this Agreement or the Trust’s policies and procedures related to the disclosure of portfolio holdings.
Appears in 5 contracts
Samples: Subadvisory Agreement (Northern Lights Variable Trust), Subadvisory Agreement (Northern Lights Variable Trust), Subadvisory Agreement (Northern Lights Variable Trust)
Independently Developed. The party independently developed such information. In addition, the Subadviser Subadvisor and its officers, directors and employees are prohibited from receiving compensation or other consideration, for themselves or on behalf of a Fund, as a result of disclosing a Fund’s portfolio holdings. The Subadviser Subadvisor agrees, consistent with its Code of Ethics, it nor its officers, directors or employees may engage in personal securities transactions based on non-public information about a Fund’s portfolio holdings. The Adviser Advisor and Trust each understand, acknowledge, and agree that the Fund is managed by the Subadviser Subadvisor using investment models which are used by the Subadviser Subadvisor and its affiliates to manage other accounts (specifically including, but not limited to, other registered mutual funds), that such other accounts may have portfolio holdings that are substantially similar or identical to those of the Fund, and that the use of such other portfolio holdings information is not subject to the restrictions of this Agreement or the Trust’s policies and procedures related to the disclosure of portfolio holdings.
Appears in 5 contracts
Samples: Investment Subadvisory Agreement (Forethought Variable Insurance Trust), Investment Subadvisory Agreement (Forethought Variable Insurance Trust), Investment Subadvisory Agreement (Forethought Variable Insurance Trust)
Independently Developed. The party independently developed such information. In addition, the Subadviser and its officers, directors and employees are prohibited from receiving compensation or other consideration, for themselves or on behalf of a Fund, as a result of disclosing a Fund’s portfolio holdings. The Subadviser agrees, consistent with its Code of Ethics, neither it nor its officers, directors or employees may engage in personal securities transactions based on non-public information about a Fund’s 's portfolio holdings. The Adviser and Trust each understand, acknowledge, and agree that the Fund is managed by the Subadviser using investment models which are used by the Subadviser and its affiliates to manage other accounts (specifically including, but not limited to, other registered mutual funds), that such other accounts may have portfolio holdings that are substantially similar or identical to those of the Fund, and that the use of such other portfolio holdings information is not subject to the restrictions of this Agreement or the Trust’s 's policies and procedures related to the disclosure of portfolio holdings.
Appears in 2 contracts
Samples: Subadvisory Agreement (Northern Lights Variable Trust), Subadvisory Agreement (Northern Lights Variable Trust)