Inside Information. Portfolio Manager shall, as a general rule, seek only to obtain publicly available research material and information. In the event Portfolio Manager does acquire or in some manner possess “material non-public information,” (“MNPI”) (as defined under the Xxxxxxx xxxxxxx and Securities Fraud Enforcement Act of 1988) Portfolio Manager acknowledges that it has implemented adequate procedures which may include information sharing restrictions (fire walls) to reasonably seek to assure regulatory compliance. The Trust acknowledges that possession of MNPI may adversely affect the Portfolio Manager’s ability to initiate investing or continue investing in a specific portfolio security.
Appears in 71 contracts
Samples: Portfolio Management Agreement (Hc Capital Trust), Portfolio Management Agreement (Hc Capital Trust), Portfolio Management Agreement (Hc Capital Trust)