Preserving the trust of our clients is a matter of singular importance to the management of Payden & Rygel. To this end, we wish to avoid apparent and actual conflicts of interest. Our internal controls involve a combination of oversight by the managing principals of the firm, state-of-the-art software, and separation of duties.
The firm’s Code of Ethics provides policies and procedures dealing specifically with conflicts of interests surrounding investment management practices, such as insider trading, personal securities transactions, and other conflicts of interest related to the investment management process. The firm’s Compliance Group plays an integral part in monitoring employee compliance to the Code of Ethics. The Code of Ethics is reviewed in detail with all new employees, including in particular the provisions on conflicts of interest. At least once a year at the Annual Compliance Review that all employees are required to attend, and more frequently if necessary, the conflicts of interest provisions of the Code are reviewed and employees are required to confirm that they know of no conflicts of interest they may have.