All employees are required to complete a “Conflicts of Interest” questionnaire as soon as possible following their initial hire date and on an annual basis thereafter. Employees must notify the Chief Compliance Officer in the event they have identified a conflict of interest.
In addition, SICM has adopted a Code of Ethics containing provisions designed to: (i) prevent improper personal trading by employees and certain family members; (ii) prevent improper use of material, non-public information about securities recommendations made by SICM or securities holdings of clients’; (iii) identify conflicts of interest; and (iv) provide a means to resolve any actual or potential conflict in favor of the client.
SICM employees must obtain the prior written approval of the Chief Compliance Officer before the employee or certain family members may engage in personal trading. All SICM employees must also submit a quarterly transaction report and annual holdings report for compliance review.
In addition, the firm has adopted an Allocation Policy designed to ensure that all accounts are treated in a fair and equitable manner with respect to trade orders.