EPP has adopted a Code of Ethics pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, as amended. The Code governs the activities of EPP's employees, who are held to high standards of integrity and fiduciary responsibility. The Code mandates that EPP's employees avoid conflicts of interest, or the appearance of conflicts of interest, in connection with the firm's investment process. Among other measures, the Code's policies for managing potential conflicts of interest in the investment process include controls related to the following key issues:
- Avoidance of self-dealing by ensuring that EPP's principals do not have personal or financial interests in securities recommended for investment
- Internal approval processes for certain personal investments and trading accounts, and disclosure requirements around all such activitites
- Restrictions on activities with other companies, boards, and other organizations
- Ensuring that service providers offer the most effective services and the best economic terms possible, particularly if such service providers are EPP affiliates