Insider Trading-Prevention

Below is a list of pre-emptive actions you can take to prevent the firm’s exposure to Insider Trading:

1. Annual Investment Adviser Representative attestations of the Code of Ethics, Compliance Manual, Outside Business Activities;

2. Thorough review of quarterly personal securities transaction reports;

3. Use of restricted securities lists, when appropriate;

4. Ongoing employee training; and

5. Clear and concise policies and procedures that are enforced equally across the firm.

 

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