Developing a Code of Ethics Program



Facing increased due diligence from institutional investors, the CEO of a $2B SEC registered investment adviser sought to establish a code of ethics program.

The code of ethics program needed to reflect the firm’s business practices, reinforce the firm’s ethical stance, and lend a competitive advantage in the institutional marketplace.


We assessed the firm’s business risk profile and practices to develop a program that met strategic, operational, and regulatory needs and expectations. We then created and implemented a code of ethics program that met both the firm’s needs and the requirements of Rule 204A-1, conducted firm-wide training, and created procedures for the ongoing administration of the program. 


The firm now has a code of ethics program, which clearly sets forth the firm’s standards of conduct and requirements under federal securities law, as well as a sustainable process for reviewing, updating, and administering the program overtime. Senior management perceives the new code of ethics program as a strong and an accurate reflection of the firm’s ethical beliefs that better positions the firm to compete for institutional asset management business.

Compliance, RiskAnn Oglanian