CC&L adheres to the Code of Ethics as prescribed by the CFA Institute (CFAI). CC&L is in compliance with CFAI’s ethical investment management standards and subscribes to full disclosure. A formal policy delineating Standards of Personal Conduct (SPC) and encompassing a personal trading policy is in place. Policies are monitored on an ongoing basis by the firm’s Compliance Officer, and reviewed at least annually by the Board of Directors. On an annual basis, all members of firm confirm their understanding of and adherence to the firm’s SPC. On a quarterly basis, all personnel provide an online certification written report of trading activity and conflicts of interest. Trading activity is audited in accordance with CC&L’s internal procedures and a report on Compliance Activities is provided to the Board of Directors on a quarterly basis.
Some members of the firm are involved in various outside activities in their community. All such outside activities have been reviewed and approved by CC&L’s UDP, and disclosed to securities regulators in accordance with National Instrument 31-103. None of these activities present a material conflict of interest with the members obligations to CC&L and its clients, and no issues have been raised by the securities regulators.