This Code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not absolve Bluemound Asset Management, LLC personnel from liability for personal trading or other conduct that violates a fiduciary duty to advisory clients.
Specific Requirements of Access Persons (Investment Advisor Representatives and Employees and any other associate who may have access to client information) of Bluemound Asset Management, LLC
A. Prohibition Against Fraud, Deceit and Manipulation
Representatives of Bluemound Asset Management, LLC may not, in connection with the purchase or sale, directly or indirectly, of a security held or to be acquired by any client account:
1. Employ any device, scheme or artifice to defraud the client account;
2. Make to the client any untrue statement of a material fact or omit to state to the client a material fact necessary in order to make the statements made, in light of the circumstances under which they are made, not misleading;
3. Engage in any act, practice or course of business which would operate as a fraud or deceit upon the client; or
4. Engage in any manipulative practice with respect to securities or a client.
Two of the most common risks associated with personal securities transactions are front-running and trading opposite a client account. For example, front-running would include the purchase of a security any time within seven days ahead of when a client account purchases the same security or the sale of a security any time within seven days ahead of when a client account sells the same security. An example of trading opposite a client account would include the sale of a security any time within seven days after a client account purchases the same security or the purchase of a security any time within seven days after a client account sells the same security.
B. Limits on Accepting or Receiving Gifts
In order to protect the reputation and integrity of Bluemound Asset Management, LLC access persons shall not accept any gift of more than nominal value ( totaling less than $100 over a 12 month period) from any existing or prospective client, broker, persons who regulate, advise or render services to Bluemound Asset Management, LLC nor offer any such gifts.
This provision does not include:
o Occasional meals, tickets to a sporting event or the theater, or normal business entertainment, if the person or entity providing the entertainment is present; and
o Any payment or reimbursement for professional training or educational meetings.
C. Political and Charitable Contributions
Access Persons may not make political contributions for the purpose of obtaining or retaining advisory contracts with government entities relating to private pension plans or municipal securities offerings. Bluemound Asset Management, LLC will take reasonable steps to ensure that any political contributions made by it or its supervised persons are not intended to obtain or retain advisory business.
E. Interpretation of Provisions
The Executive Officer (Kirk Spano) of Bluemound Asset Management, LLC may from time to time adopt such interpretations of this Code as it deems appropriate.
F. Acknowledgment of Receipt and Annual Certification
Each IAR will receive a copy of this Code and any subsequent amendments to the Code, and must acknowledge receipt of the Code in writing. In addition, each person is required to certify annually that he/she (i) has read and understands the Code, (ii) is aware that he/she is subject to the provisions of this Code, (iii) has complied with the Code at all times during the previous calendar year, and (iv) has, during the previous calendar year, reported all holdings and transactions that he/she is required to report pursuant to the Code.