Compliance Glossary

Code of Ethics

A code of ethics is a set of written guidelines that establish the standards of behavior and conduct expected of employees in a business setting. It’s a broad document that outlines professional expectations and helps to ensure that employees make good decisions.

In regulatory compliance, Code of Ethics is:

All SEC-registered firms (and some state registered firms) are required under Rule 204A-1 to create and maintain a written Code of Ethics which covers:

  • Fiduciary duty
  • Insider trading laws
  • A procedure for reporting personal securities transactions
  • Reporting for access persons (those who have access to nonpublic information about clients’ securities holdings)
  • How the CCO will enforce and maintain the Code of Ethics
  • Training and education practices for new and existing employees
  • Documentation of compliance to the rule dating back at least five years

The SEC has kept its codes of ethics ruling intentionally broad. Firms are encouraged to create their own financial adviser ethics codes which best reflect their business models and operations.

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