Code of Ethics

One of the greatest benefits of going to Baylor is its focus on ethics and professionalism. There is a strong connection in how you perform and how others perceive you by your background and I am glad mine is built on a strong foundation. Those same attributes are professed by many other organizations that prioritize similar values and there are a few examples below specific to the finance industry to represent what I mean.

Code of Ethics

• Act in an ethical manner
• Place integrity of profession and interest of clients above personal interest
• Use reasonable care and exercise independent judgment
• Encourage other to practice in a manner that is a credit to the profession
• Promote the integrity of capital markets
• Maintain and improve you and your and others professional competence

Summary of Standards

1. Know the law relevant to your position
   1. Comply with the most strict law or standard that applies to you
   2. Don’t solicit gifts
   3. Don’t compromise objectivity or independence
   4. Use reasonable care
   5. Don’t lie cheat or steal
   6. Don’t continue association with others who are breaking laws
   7. Don’t use others work or ideas without attribution
   8. Don’t guarantee investment results or say past will be repeated
   9. Don’t do things outside of work that reflect poorly on your integrity
2. Do not act or cause others to act on material nonpublic information
   1. Do not manipulate market prices or trading with intent to mislead others
3. Act solely for benefit of client and know when fiduciary duty is owed with regard to trust and retirement
   1. Treat clients fairly by attempting simultaneous dissemination of changes and recommendations
   2. Do not personally take shares in oversubscribed IPOs
   3. When in an advisory relationship

                                                              i.      Know your client

                                                            ii.      Make suitable investment recommendations in a total portfolio context

                                                          iii.      Preserve confidential client information unless it concerns illegal activity

                                                           iv.      Do not mislead with performance presentation

                                                             v.      Vote nontrivial proxies in clients best interest

4. Act for the benefit of your employer
   1. Do not harm your employer obtain written permission to compete with your employer or accept additional compensation from clients contingent on future performance
   2. Disclose (to employer) any gifts from clients
   3. Don’t take material with you when you leave employment
   4. Supervisors must take action to both prevent and detect violations
   5. Don’t take supervisory responsibility if you believe procedures are inadequate
5. Thoroughly analyze investments
   1. Have reasonable basis
   2. Keep records
   3. Tell clients about investment process
   4. Distinguish between fact and opinion
   5. Review quality of third party research
   6. In quantitative model, consider what happens when their inputs are outside normal range
6. Disclose potential conflicts of interest
   1. Disclose referral arrangements
   2. Client transactions before employer before personal transactions
   3. Treat clients who are family members just like any client