General Code of Ethics
Gryphon’s General Code of Ethics ensures fair treatment of our clients. Our directors, managing partners, officers, employees, and representatives are committed to upholding the high standards of integrity and ethical business conduct laid out in the Code. It also ensures compliance with the requirements of securities legislation, regulations, rules of jurisdictions where Gryphon is registered, and other laws applicable to Gryphon’s business.
- To provide a clear statement of our responsibilities to all clients.
- To protect the clients of Gryphon by seeking to deter misconduct.
- To educate directors, managing partners, officers, and employees as to their responsibilities to our clients.
- To prevent violations of Securities Acts and Laws and associated legislation, rules, and regulations.
- To set out procedures that facilitate Gryphon in monitoring compliance with the Code.
- Purpose of the Code
- Standards of Conduct
- Conflicts of Interest
- Personal Trading
- Prohibited Activities
- Reporting to CEO and Board of Directors
- Disciplinary Actions
Code of Ethics for Personal Trading
Securities laws prohibit trading by persons with knowledge of the investment program of a mutual fund (which includes pooled funds) or the investment portfolio of a client of Gryphon. The Code of Ethics for Personal Trading establishes policies and procedures to ensure compliance with this requirement.
This code covers topics including:
- Purpose of this Code
- Special rules for Access Persons
- Who is an access person
- Prohibited activities
- Requirement to obtain prior approval for personal trades
- Exempt securities
- Procedures to obtain approval
- Blackout Periods
- Personal trading reporting procedures
- Compliance review procedures
- Disciplinary Procedures
Conflict of Interest Disclosure Statement and Additional Relationship Disclosure Information
Gryphon is required to identify material conflicts of interest that would be expected to arise between Gryphon (including each individual acting on its behalf) and its clients. Further, if a reasonable investor would expect to be informed of the nature and extent of an identified conflict of interest, Gryphon must do so. Gryphon has prepared a Conflict of Interest Disclosure Statement and Additional Relationship Disclosure Information document that is available upon request.
To request a copy of any of these documents at no charge, please contact Gryphon’s Chief Compliance Officer at firstname.lastname@example.org.