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The professionals of Cluster Family Office guide itself by the policies of the code of ethics of the CFA Institute, to ensure the alignment of our interests with the ones of our clients, to provide an optimum service, and to guarantee a professional conduct.

The CFA Institute is a global association of investment professionals that awards the CFA (Chartered Financial Advisor) and CIPM (Certificate in Investment Performance Measurement) designations. It promotes the highest ethical standards and offers a range of educational opportunities around the world.

The code of ethics for Asset Manager states that the responsibilities that the Manager should have with their clients are:

  • Act in a professional and ethical manner at all times.
  • Act for the benefit of clients.
  • Act with independence and objectivity.
  • Act with skill, competence, and diligence.
  • Communicate with clients in a timely and accurate manner.
  • Uphold the applicable rules governing capital markets.

The code of ethics of CFA is organized in six categories of principles that outline the professional conducts expected of investment managers. Each category contains ethical standards that define the responsibility of managers when providing asset management services for clients.

A. Loyalty to Clients.
B. Investment Process and Actions.
C. Trading
D. Risk Management, Compliance, and Support
E. Performance and Valuation.
F. Disclosures.

The standards of the code include the following:

Managers must:
  • Place client interests before their own.
  • Use reasonable care and prudent judgment when managing client assets.
  • Establish policies to ensure fair and equitable trade allocation among client accounts.
  • Employ qualified staff and sufficient human and technological resources to thoroughly investigate, analyze, implement, and monitor investment decisions and actions.
  • Present performance information that is fair, accurate, relevant, timely, and complete. Managers must not misrepresent the performance of individual portfolios or of their firm.
  • Communicate with clients on an ongoing and timely basis.

The Code sets the minimum for ethical conduct, while allowing flexibility for asset managers of various sizes and structure. The associated guidance included in the Code allows managers to develop appropriate compliance policies and procedures that also satisfy any additional regulatory requirements.

The Asset Manager Code of Professional Conduct can be downloaded from the following link:

Download the Asset Manager Code of Professional Conduct.