A compliance program only matters if it changes behavior. Ours is part of the approval steps, documentation standards, and reporting obligations of daily work.
A compliance program is only meaningful if it changes behavior. Ours is designed to be part of how work gets done: built into approval steps, documentation standards, and reporting obligations rather than layered on afterward.
The program is overseen by our Chief Compliance Officer, who has authority to escalate matters independently, and is reviewed periodically to reflect changes in our activities and the regulatory environment.
We identify potential conflicts at the outset of a relationship or transaction, document them, and address them through avoidance, mitigation, or clear disclosure. Where a conflict cannot be eliminated, investors are told about it.
Personnel are subject to reporting, preclearance, and restriction requirements designed to prevent personal activity from conflicting with client interests or from using non-public information.
Information barriers, access controls, and confidentiality obligations protect both investor data and material non-public information encountered in the ordinary course of our work.
This page describes our compliance program in general terms for informational purposes. It is a summary and does not describe every policy, procedure, or control in effect, and it is not a legal or regulatory representation.
To request additional information about our compliance program, contact [email protected]. See also our Code of Ethics, AML / KYC Policy, and Regulatory Information.
