BFM_Ethics Code
0 likes308 views
Bourbon Financial Management's code of ethics outlines standards of conduct for employees, including: [1] Acting with integrity, competence, and placing clients' interests above its own; [2] Using independent and objective professional judgment; [3] Maintaining confidentiality of client information. The code also addresses duties to clients such as suitability of recommendations, fair dealing, and preserving confidentiality. It prohibits misrepresentation, misconduct, and other acts that could damage the firm's reputation.
BFM_Ethics Code
- 1. BOURBON FINANCIAL MANAGEMENT, LLC 616 West Fulton Street, Suite 411 • Chicago, Illinois 60661, USA +1 312-909-6539 • Patrick@BourbonFM.com CODE OF ETHICS
- 2. PREAMBLE The Code of Ethics is fundamental to the values of Bourbon Financial Management, LLC (“BFM”) and essential to achieving its mission of high standards of education, integrity, and professional excellence. It sets out principles and practices that BFM expects all of its employees and directors to follow unreservedly both in letter and in spirit. High ethical standards are critical to maintaining the trust in financial markets and in the investment profession. The BFM code of ethics is based on the CFA Institute code of ethics. STANDARDS OF PROFESSIONAL CONDUCT • Act with integrity, competence, diligence, respect, and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets. • Place the integrity of the investment profession and the interests of clients above its own personal interests. • Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities. • Practice and encourage others to practice in a professional and ethical manner that will reflect credit on us and the profession. • Promote the integrity of, and uphold the rules governing, capital markets. • Maintain and improve professional competence and strive to maintain and improve the competence of other investment professionals. I. PROFESSIONALISM A. Knowledge of the Law BFM and its employees must understand and comply with all applicable laws, rules, and regulations of any government, regulatory organization, licensing agency, or professional association governing its professional activities. BFM must not knowingly participate or assist in and must dissociate from any violation of such laws, rules, or regulations. B. Independence and Objectivity BFM must use reasonable care and judgment to achieve and maintain independence and objectivity in its professional activities. BFM must not offer, solicit, or accept any gift, or compensation, that reasonably could be expected to compromise his own or another’s independence and objectivity. C. Misrepresentation BFM must not knowingly make any misrepresentations relating to investment analysis, recommendations, actions, or other professional activities. D. Misconduct BFM must not engage in any professional conduct involving dishonesty, fraud, or deceit or commit any act that reflects adversely on its professional reputation, integrity, or competence.
- 3. II. INTEGRITY OF CAPITAL MARKETS A. Material Non-public Information BFM who possesses material non-public information that could affect the value of an investment must not act or cause others to act on the information. B. Market Manipulation BFM must not engage in practices that distort prices or artificially inflate trading volume with the intent to mislead market participants. III. DUTIES TO CLIENTS A. Loyalty, Prudence, and Care BFM has a duty of loyalty to its clients and must act with reasonable care and exercise prudent judgment. BFM must act for the benefit of its clients and place its clients’ interests before its employer’s or its own interests. In relationships with clients, BFM must determine applicable fiduciary duty and must comply with such duty to persons and interests to whom it is owed. B. Fair Dealing BFM must deal fairly and objectively with all clients when providing investment analysis, making investment recommendations, taking investment action, or engaging in other professional activities. C. Suitability 1. When BFM is in an advisory relationship with a client, it must: a. Make a reasonable inquiry into a client’s or prospective clients’ investment experience, risk and return objectives, and financial constraints prior to making any investment recommendation or taking investment action and must reassess and update this information regularly. b. Determine that an investment is suitable to the client’s financial situation and consistent with the client’s written objectives, mandates, and constraints before making an investment recommendation or taking investment action. c. Judge the suitability of investments in the context of the client’s total portfolio. 2. When BFM is responsible for managing a portfolio to a specific mandate, strategy, or style, they must only make investment recommendations or take investment actions that are consistent with the stated objectives and constraints of the portfolio. D. Performance Presentation When communicating investment performance information, BFM must make reasonable efforts to ensure that it is fair, accurate, and complete.
- 4. E. Preservation of Confidentiality BFM must keep information about current, former, and prospective clients confidential unless: 1. The information concerns illegal activities on the part of the client or prospective client 2. Disclosure is required by law 3. The client or prospective client permits disclosure of the information IV. DUTIES TO EMPLOYERS A. Loyalty In matters related to its employment, BFM must act for the benefit of its employees and not deprive its employees of the advantage of its skills and abilities, divulge confidential information, or otherwise cause harm to its employees. B. Additional Compensation Arrangements BFM must not accept gifts, or compensation, that competes with, or might reasonably be expected to create a conflict of interest with, its employer’s interest unless they obtain written consent from all parties involved. C. Responsibilities of Supervisors BFM must make reasonable efforts to detect and prevent violations of applicable laws, rules, and regulations by anyone subject to its supervision or authority. V. INVESTMENT ANALYSIS, RECOMMENDATIONS, AND ACTION A. Diligence and Reasonable Basis BFM must: 1. Exercise diligence, independence, and thoroughness in analyzing investments, making investment recommendations, and taking investment actions/recommendations. 2. Have a reasonable and adequate basis, supported by appropriate research and investigation, for any investment analysis, recommendation, or action.
- 5. B. Communication with Clients and Prospective Clients BFM must: 1. Disclose to clients and prospective clients the basic format and general principles of the investment processes used to analyze investments, select securities, and construct portfolios and must promptly disclose any changes that might materially affect those processes. 2. Use reasonable judgment in identifying which factors are important to its investment analyses, recommendations, or actions and include those factors in communications with clients and prospective clients. 3. Distinguish between fact and opinion in the presentation of investment analysis and recommendations. C. Record Retention BFM must develop and maintain appropriate records to support its investment analysis, recommendations, actions, and other investment-related communications with clients and prospective clients. VI. CONFLICTS OF INTEREST Disclosure of Conflicts BFM must make full and fair disclosure of all matters that could reasonably be expected to impair its independence and objectivity or interfere with respective duties to its clients, prospective clients, and employee. BFM must ensure that such disclosures are prominent, are delivered in plain language, and communicate the relevant information effectively. VII. MISCELLANEOUS BFM adheres to the standards and restrictions imposed by applicable laws, rules and regulations. BFM takes its responsibility to preserve the integrity of the financial system, and its own operations, seriously. We are committed to assisting in the fight against money laundering. BFM is committed to building and sustaining relationships with clients built on trust. BFM is committed to upholding client confidentiality and protecting client information. BFM provides employment and advancement opportunities for individuals regardless of race/ethnicity, gender national origin, age, disability, sexual orientation or religion. BFM is committed to protecting health and safety of employees in the workplace. BFM is committed to acting in an environmentally responsible manner in all its business dealings. © 2012 Bourbon Financial Management, LLC