WrapManager has established a Code of Ethics that applies to all of its employees and associated persons. This disclosure provides a summary of our Code of Ethics.
WrapManager requires all of its supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand and agree to comply with our Code of Ethics.
An investment adviser is considered a fiduciary according to the Investment Advisers Act of 1940. This fiduciary duty is considered the core underlying principle for the WrapManager’s Code of Ethics. As such:
- WrapManager has a fiduciary duty to all clients. It is our responsibility to act solely in the best interest of each of our clients at all times.
- It is WrapManager’s responsibility to provide fair and full disclosure of all material facts.
- WrapManager and its supervised persons must conduct business in an honest, ethical and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients.