ALM First’s Code of Ethics sets the tone for the conduct and professionalism of our employees, officers, and directors. Because the ethical culture of our firm is of critical importance and ethical leadership begins at the highest levels, the Code of Ethics has the complete endorsement of senior management and covers all employees at ALM First.

 

Our Code of Ethics has been established to:

  • Protect ALM First’s clients by deterring misconduct
  • Educate employees regarding ALM First’s expectations and the regulations governing their conduct
  • Remind employees they are in a position of trust and must act with propriety at all times
  • Protect the reputation of ALM First
  • Guard against violation of the securities laws
  • Establish policies and procedures for employees that reinforce ethical behavior and allow
    ALM First to determine if employees are complying with ALM First’s ethical principles.

 

GENERAL PRINCIPLES:

ALM First’s fiduciary duty is to its clients. Personal securities transactions must be conducted in compliance with the Code of Ethics and the policies and procedures controlling trading activities to avoid any actual or potential conflict of interest or abuse of an employee’s position of trust. ALM First is committed to providing services in a fair and professional manner and to fully disclose key elements of these services to clients. Independence in the investment decision making process is important and the interest of the client always comes first. Client information and holdings are confidential and maintained in an environment of confidentiality and trust. Additionally, employees are required to comply with all applicable federal securities laws and regulations. Failure to comply with ALM First’s Code of Ethics, standards of conduct, and policies and procedures may result in disciplinary action, including termination of employment. The Code of Ethics covers federal securities laws, conflicts of interest, insider trading, personal securities transactions, gifts and entertainment, confidentiality, service on boards and other outside activities, and marketing and promotional activities.

 

A copy of ALM First’s complete Code of Ethics and the ADV Statement can be obtained upon request. Please contact Kevin Kirksey, Chief Compliance Officer at 214.451.3486 or kkirksey@almfirst.com to request your copy.