DSM has adopted a Code of Ethics describing its commitment to integrity and high ethical standards. The Code of Ethics is based upon the principle that DSM and its employees owe a fiduciary duty to clients to conduct their affairs, including personal securities transactions, in such a manner as to avoid any actual or potential conflict of interest. The Code of Ethics contains provisions relating to the prohibition against trading on material, non-public information. It also describes permissible personal securities transactions, gifts and entertainment, outside business activities as well as protecting the confidentiality of client information.
To align the interest of its employees with its clients, DSM encourages its employees to personally invest in the same model investment strategies and securities as its clients. This may cause a conflict as DSM, its employees and their related accounts may invest in the same securities, at the same or different times, that it purchases and sells for clients. Under the Code of Ethics, employees of DSM and their immediate family members must obtain pre-clearance from DSM's Chief Compliance Officer for certain securities transactions.
All employees of DSM must acknowledge the terms of the Code of Ethics annually and as amended.