Code of Ethics

Preamble

The Inova Code of Ethics and Standards of Professional Conduct are fundamental to the values of Inova and essential to achieving its mission to lead by example by promoting the highest standards of ethics, education and professional excellence for the ultimate benefit of society. High ethical standards are critical to maintaining the trust of our clients, both in Inova but, more broadly, in the financial markets and the wider investment and advisory profession. Our Code of Ethics promotes the integrity of Inova staff and service providers and serve as a model for how we seek to act globally, regardless of sector, client, transaction, cultural differences, or local laws and regulations. All our employees, members and service providers must abide by the Code and Standards.

The code of ethics

Inova, its management, board of directors, staff and service providers seek to:

  • Act with integrity, competence, diligence, respect and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets;

  • Place the integrity of the investment profession and the interests of clients above their own personal interests; and

  • Use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities.

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Standards of Professional Conduct 

I. Professionalism

A. Knowledge of the Law. 

Staff must understand and comply with all applicable laws, rules, and regulations of any government, regulatory organization, licensing agency, or professional association governing their professional activities. In the event of conflict, Staff must comply with the more strict law, rule, or regulation. Staff must not knowingly participate or assist in and must dissociate from any violation of such laws, rules, or regulations.


B. Independence and Objectivity. 

Staff must use reasonable care and judgment to achieve and maintain independence and objectivity in their professional activities. Staff must not offer, solicit, or accept any gift, benefit, compensation, or consideration that reasonably could be expected to compromise their own or another’s independence and objectivity.

- Practice and encourage others to practice in a professional and ethical manner that will reflect credit on themselves and the profession.

- Promote the integrity and viability of the global capital markets for the ultimate benefit of society.

- Maintain and improve their professional competence and strive to maintain and improve the competence of other investment professionals.

C. Misrepresentation. 

Staff must not knowingly make any misrepresentations relating to investment analysis, recommendations, actions, or other professional activities.

 

D. Misconduct. 

Staff must not engage in any professional conduct involving dishonesty, fraud, or deceit or commit any act that reflects adversely on their professional reputation, integrity, or competence.

II. Integrity of Capital Markets

A. Material Nonpublic Information. 

Staff who possess material nonpublic information that could affect the value of an investment must not act or cause others to act on the information.

B. Market Manipulation. 

Staff must not engage in practices that distort prices or artificially inflate trading volume with the intent to mislead market participants.

III. Duties to Clients

A. Loyalty, Prudence, and Care. 

Staff have a duty of loyalty to their clients and must act with reasonable care and exercise prudent judgment. Members and Candidates must act for the benefit of their clients and place their clients’ interests before their employer’s or their own interests.

 

B. Fair Dealing. 

Staff must deal fairly and objectively with all clients when providing investment analysis, making investment recommendations, taking investment action, or engaging in other professional activities.

 

C. Suitability.

When Staff are in an advisory relationship with a client, they must:

- Make a reasonable inquiry into a client’s or prospective client’s investment experience, risk and return objectives, and financial constraints prior to making any investment recommendation or taking investment action and must reassess and update this information regularly.

- Determine that an investment is suitable to the client’s financial situation and consistent with the client’s written objectives, mandates, and constraints before  making an investment recommendation or taking investment action.

- Judge the suitability of investments in the context of the client’s total portfolio.

When Staff are responsible for managing a portfolio to a specific mandate, strategy, or style, they must make only investment recommendations or take only investment actions that are consistent with the stated objectives and constraints of the portfolio.

 

D. Performance Presentation. 

When communicating investment performance information, Staff must make reasonable efforts to ensure that it is fair, accurate, and complete.

 

E. Preservation of Confidentiality. 

Staff must keep information about current, former, and prospective clients confidential unless:

- The information concerns illegal activities on the part of the client or prospective client,

- Disclosure is required by law, or

- The client or prospective client permits disclosure of the information.

IV. Duties to Inova

A. Loyalty. 

In matters related to their employment, Staff must act for the benefit of their employer and not deprive their employer of the advantage of their skills and abilities, divulge confidential information, or otherwise cause harm to their employer.

 

B. Additional Compensation Arrangements. 

Staff must not accept gifts, benefits, compensation, or consideration that competes with or might reasonably be expected to create a conflict of interest with Inova's interest unless they obtain written consent from all parties involved.

 

C. Responsibilities of Supervisors. 

Staff must make reasonable efforts to ensure that anyone subject to their supervision or authority complies with applicable laws, rules, regulations, and the Code and Standards.

 

V. Investment Analysis, Recommendations and Actions

A. Diligence and Reasonable Basis. 

Staff must:

- Exercise diligence, independence, and thoroughness in analyzing investments, making investment recommendations, and taking investment actions.

- Have a reasonable and adequate basis, supported by appropriate research and investigation, for any investment analysis, recommendation, or action.

 

B. Communication with Clients and Prospective Clients. 

Staff must:

- Disclose to clients and prospective clients the basic format and general principles of the investment processes they use to analyze investments, select securities, and construct portfolios and must promptly disclose any changes that might materially affect those processes.

- Disclose to clients and prospective clients significant limitations and risks associated with the investment process.

- Use reasonable judgment in identifying which factors are important to their investment analyses, recommendations, or actions and include those factors in communications with clients and prospective clients.

- Distinguish between fact and opinion in the presentation of investment analysis and recommendations.

 

C. Record Retention. 

Staff must develop and maintain appropriate records to support their investment analyses, recommendations, actions, and other investment-related communications with clients and prospective clients.

VI. Conflicts of Interest

A. Disclosure of Conflicts.

Staff must make full and fair disclosure of all matters that could reasonably be expected to impair their independence and objectivity or interfere with respective duties to their clients, prospective clients, and employer. Staff must ensure that such disclosures are prominent, are delivered in plain language, and communicate the relevant information effectively.

 

B. Priority of Transactions. 

Investment transactions for clients and employers must have priority over investment transactions in which a member of Staff is the beneficial owner.

 

C. Referral Fees. 

Staff must disclose to their Inova, clients, and prospective clients, as appropriate, any compensation, consideration, or benefit received from or paid to others for the recommendation of products or services.