Portfolio Persons Clause Samples

Portfolio Persons o may not purchase or sell, directly or indirectly, any Security within 7 days before or after a client portfolio has executed a trade in that same Security, (including any equity-related security of the same issuer such as preferred stock, options, warrants, and convertible bonds) unless the order is withdrawn. o may not acquire Securities as part of an Initial Public Offering("IPO") without obtaining the written approval of the designated Compliance Officer before directly or indirectly acquiring a beneficial ownership in such securities. o may not acquire a beneficial ownership interest in Securities issued in a private placement transaction without obtaining prior written approval from the Compliance Department. o may not profit from the purchase and sale or sale and purchase of a Security within 60 days of acquiring or disposing of Beneficial Ownership of that Security. This prohibition does not apply to transactions resulting in a loss, or to futures or options on futures on broad-based securities indexes or U.S. government securities. o may not receive any gift of more than de minimus value (currently $100.00 per year) from any person or entity that does business with or on behalf of any Investment Vehicle. o may not serve on the board of directors of any publicly traded company.