Sands Capital definition
Examples of Sands Capital in a sentence
Sands Capital shall maintain such records relating to this Code of Ethics, in the manner and as required by Rule 204-2(a)(12) under the Advisers Act and Rules 17f-1(f) and 31a-1(f) under the Investment Company Act.
In the event that a matter implicates the Chief Compliance Officer, notice of a violation may be provided to the General Counsel or another executive officer of Sands Capital.
Chief Compliance Officer, Sands Capital Management, LLC; failed to fileS.E.C. Form SC 12G notice of acquisition reports for Athenahealth, Baidu and Facebook during the period of the Facebook IPO in 2012; this conduct masked the conflicts of interest of Todd Y.
Founder and CEO, respectively, of Sands Capital Management LLC; failed to fileS.E.C. Form SC 13G acquisition reports for Athenahealth, Inc., Baidu, Inc.
Chief Counsel, Sands Capital Management, LLC; failed to fileS.E.C. Form SC 12G notice of acquisition reports for Athenahealth, Baidu and Facebook during the period of the Facebook IPO in 2012; this conduct masked the conflicts of interest of Todd Y.
Sands Capital shall not reveal the identity of any person who reports a violation of this Code and who asks that his or her identity as the person who made such report remain confidential.
Notwithstanding the foregoing and anything else contained in these policies and procedures, nothing in these policies and procedures is intended to prevent, delay or otherwise restrict a staff member’s rights under applicable law to notify government authorities of suspected or actual wrongdoing by Sands Capital or its employees and representatives.
Sands, Jr. (Founder and CEO, respectively, of Sands Capital Management LLC; failed to file S.E.C. Form SC 13G acquisition reports for Athenahealth, Inc., Baidu, Inc.
Supervised Persons may not serve as a board of director of any organization where Sands Capital directly serves as the investment manager of funds owned and/or directed by that organization without written approval from the Chief Compliance Officer.
In addition, Sands Capital prohibits any Supervised Person or agent, either personally or on behalf of others, from making, offering or promising to make, authorizing or directing any payment of anything of value (including cash or property), directly or indirectly, to a foreign government official for the purpose of inducing or influencing the foreign government official to use his or her position in order to assist in obtaining or retaining business or securing any improper business advantage.