Key to the risk management process at Fort Washington is the independence with which it is applied. Our Chief Risk Officer (CRO) has overall responsibility for our risk management process and reports to the Chairman, and the President & CEO of Western Southern Financial Group. The CRO has responsibility of Risk Management within Western Southern and Fort Washington.
Both Fort Washington’s and Western & Southern’s Codes of Ethics also address other conflicts of interest, outside business activities, fiduciary duties, gifts and entertainment, and provides proper behavioral standards and a venue for anonymous reporting of violations to the Codes. Employees of Fort Washington receive annual training and are required to attest to our code of ethics each year.
Fort Washington believes all material conflicts of interest have been identified and disclosed in the Firm's Form ADV. More specifically, Fort Washington's policies are in place to mitigate the risk associated with areas specifically related to employee trading, principal trading, and directed brokerage are as follows:
Fort Washington’s Code of Ethics describes policies and procedures for personal trading by employees. Except for the transactions specified in the exemptions section, Section II “Personal Trading Guidance” of the Code of Ethics, all securities transactions, including purchases in an initial public offering and transactions in private placements, in which an employee or immediate family member has or acquires a beneficial interest must be pre-cleared with Compliance.
Principal Trading Policy
Fort Washington’s policy and practice is that the firm may engage in principal transactions, however any such transactions may only be executed when proper written disclosures are provided, client consents obtained, and appropriate approvals received and records maintained.
Fort Washington will provide clients with disclosure regarding each principal transaction including information about the adviser's conflict of interest, the price of the transaction or current quoted price, market best price information regarding security and, if applicable, any commission charges. Fort Washington will obtain consent from a client regarding any principal transaction prior to settlement of the transaction.
The Compliance Department will maintain records of all principal transactions, disclosures, and client consents. Fort Washington will not engage in principal transactions for ERISA-covered clients absent an appropriate exemption from applicable regulations.
Directed Brokerage Policy
Fort Washington may accept client instructions for directing the client’s brokerage transactions to a particular broker-dealer. Any client instructions to Fort Washington are to be in writing with appropriate disclosures that for any directed brokerage arrangements Fort Washington will not negotiate commissions, may not obtain volume discounts or aggregate directed transactions, and that commission charges will vary among clients and best execution may not be obtained.
Any client directed brokerage instructions and arrangements are to be in writing and must be reviewed by the Best Execution and Client Service.
Fort Washington provides appropriate disclosures in the firm’s disclosure document and/or the firm’s advisory agreement. Any client brokerage instructions are maintained in the client document file. Any relationships and conflicts of interest relating to arrangements in which brokers refer clients to the firm are disclosed to clients.