Personal Securities Transactions. Subadviser will observe and comply with Rule 17j-l under the 1940 Act. Upon request during any business day, Subadviser will 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. Subadvisor has implemented policies and procedures reasonably designed to comply with Rule 17j-l under the 1940 Act. Subadvisor will comply in all material respects with Rule 17j-l under the 1940 Act and Rule 204A-1 under the Advisers Act. Upon reasonable request during any business day, Subadvisor will promptly make available to Advisor, the Corporation or the Board any reports concerning the Fund required to be made by Subadvisor pursuant to Rule 17j-1 under the 1940 Act.
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
2.5 PERSONAL SECURITIES TRANSACTIONS RECORDS 8
2.6 REPORTING REQUIREMENTS 10 2.7 CONFIDENTIALITY 10
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. [THIS SECTION INTENTIONALLY LEFT BLANK]
2.1 PRE-CLEARANCE BY ADVISORY PERSONS (AND THEIR SPOUSES*) (*May include individuals in addition to a spouse. See Appendix A and definitions of "Beneficial Ownership.") Advisory Persons must pre-clear certain purchases and sales of SECURITIES with the Compliance Officer. The following security transactions (buys and sells) must be pre-cleared if a `Yes' appears below. (This list is NOT intended to be all-inclusive. If there is a security type not listed here and you have a question, please call HCM Compliance.)
(1) Yes Fixed Income Transactions (2) Yes Closed-End Mutual Funds Yes Securities offered as part of an INITIAL PUBLIC OFFERING ("IPO") Yes Securities offered as private placements or LIMITED OFFERINGS (3) Yes Exercise of puts and calls purchased by Advisory Persons (1) Yes Writing of puts and calls by Advisory Persons Yes Non-Index Futures (4) Yes UBOC Stock (5) No Mitsubishi UFJ Financial Group, Inc. (MUFG) No HighMark Funds No Open-end Non-HighMark Mutual Funds No UBOC Stable Value Fund No Exchange Traded Funds (6) No U.S. Treasury/Agencies No Short-Term Instruments or Cash Equivalents No Employee 401(k) Automatic Purchases (7) No Index Futures (6) No
(1) IF EQUITY TRANSACTION EXCEEDS 1,000 SHARES AND $20,000. (See note below.) Includes purchase of options. This...
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. 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. The following transactions by Employees are considered "personal" under applicable SEC rules and therefore subject to this statement of policy:
1. Transactions for an Employee's own account, including XXX's. If an Employee has a substantial measure of influence or control over an account, but neither the Employee nor the Employee's family has any direct or indirect beneficial interest (e.g., a trust for which the Employee is a trustee but not a direct or indirect beneficiary), the rules relating to personal securities transactions are not considered to be directly applicable. Therefore, prior clearance and subsequent reporting of such transactions are not required. In all transactions involving such an account an Employee should, however, conform to the spirit of these rules and avoid any activity which might appear to conflict with the investment company or counseling clients or with respect to the Employee's position within Wellington Management. In this regard, please note "Other Conflicts of Interest", found later in this Code of Ethics, which does apply to such situations. EXCEPT AS SPECIFICALLY EXEMPTED IN THIS SECTION, ALL EMPLOYEES MUST CLEAR PERSONAL SECURITIES TRANSACTIONS PRIOR TO EXECUTION. This includes bonds, stocks (including closed end funds), convertibles, preferreds, options on securities, warrants, rights, etc., for domestic and foreign securities, whether publicly traded or privately placed. The only exceptions to this requirement are automatic dividend reinvestment and stock purchase plan acquisitions, broad-based stock index and US government securities futures and options on such futures, transactions in open-end mutual funds, US Government securities, commercial paper, or non-volitional transactions. Non-volitional transactions include gifts to an Employee over which the Employee has no control of the timing or transactions which result from corporate action applicable to all similar security holders (such as splits, tender offers, mergers, stock dividends, etc.). Please note, however, that most of these transactions must be reported even though they do not have to be precleared. See the following section on reporting obligations. Clearance for transactions must be obtained by contacting the Director of Global Equity Trading or those personnel designated by him for this purpose. Requests for clearance and approval for transactions may be communicated orally or via email. The Trading Department will maintain a log of all requests for...
Personal Securities Transactions. While all personal securities transactions must be cleared prior to execution, the following guidelines indicate which transactions will be prohibited, discouraged, or subject to nearly automatic clearance. The clearance of personal securities transactions may also depend upon other circumstances, including the timing of the proposed transaction relative to transactions by our investment counseling or investment company clients; the nature of the securities and the parties involved in the transaction; and the percentage of securities involved in the transaction relative to ownership by clients. The word "clients" refers collectively to investment company clients and counseling clients. Employees are expected to be particularly sensitive to meeting the spirit as well as the letter of these restrictions. Please note that these restrictions apply in the case of debt securities to the specific issue and in the case of common stock, not only to the common stock, but to any equity-related security of the same issuer including preferred stock, options, warrants, and convertible bonds. Also, a gift or transfer from you (an Employee) to a third party shall be subject to these restrictions, unless the donee or transferee represents that he or she has no present intention of selling the donated security.
