Ad Deum Funds has always had as its first priority the needs and interests of our clients. The Investment Advisers Act of 1940 imposes a fiduciary duty on investment advisers. As fiduciaries, we have an obligation of accountability to our clients, our peers, and ourselves to uphold our reputation and personal integrity by always acting in the best interest of each client. Our clients’ trust demands high standards upon our conduct and reliability. Employees are expected to act in the best interest of each client, regardless of situation or circumstance. The below Code of Ethics does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not shield associated persons from liability for personal trading or other conduct that violates a fiduciary duty to advisory clients.
Our Code of Ethics addresses the securities-related conduct of Ad Deum Funds, our advisory representatives, employees, and associated persons. The Code of Ethics encompasses our policies and procedures developed to protect your interest, and is as follows:
• Ad Deum Funds will never buy or sell a security directly from you or to you. We do not act as principals for transactions.
• It is possible that persons related to Ad Deum Funds may purchase a publicly traded security for a client’s account that they have purchased for their own portfolios. In no instance will they own as much as 1% of said security. Ownership of a security by a related person will be disclosed to the client holding the same security.
• If a person affiliated with Ad Deum Funds wants to buy or sell a security and similar transactions are being made for clients that same day, the related person must wait until all planned client transactions are completed before entering his own.
• Any information concerning you, your holdings, and your financial circumstances is considered confidential.
The firm will provide a copy of the Code of Ethics to any client or prospective client upon request.
Our Code of Ethics addresses the securities-related conduct of Ad Deum Funds, our advisory representatives, employees, and associated persons. The Code of Ethics encompasses our policies and procedures developed to protect your interest, and is as follows:
• Ad Deum Funds will never buy or sell a security directly from you or to you. We do not act as principals for transactions.
• It is possible that persons related to Ad Deum Funds may purchase a publicly traded security for a client’s account that they have purchased for their own portfolios. In no instance will they own as much as 1% of said security. Ownership of a security by a related person will be disclosed to the client holding the same security.
• If a person affiliated with Ad Deum Funds wants to buy or sell a security and similar transactions are being made for clients that same day, the related person must wait until all planned client transactions are completed before entering his own.
• Any information concerning you, your holdings, and your financial circumstances is considered confidential.
The firm will provide a copy of the Code of Ethics to any client or prospective client upon request.