Code of Ethics

The following is a description of our Code of Ethics. We will provide a separate copy to any client, or prospective client, upon request.

  • We will conduct every aspect of our business in a fair, lawful and ethical manner. • Our customers will be offered only those pre-approved products/services that have been determined to be appropriate for their specific needs and which provide fair value. • It is our obligation to respect and protect the right to privacy of all our clients. • Confidential or proprietary information, obtained in the course of employment with SDR Investment Management, Inc., is not to be used for personal gain or to be shared with others for personal benefit.
  • All efforts will be made to avoid actual or apparent conflicts of interest. (Such a conflict may exist even when no actual wrongdoing occurs; the opportunity to act improperly may be sufficient to give the appearance of a conflict.)
  • Strict compliance with all laws and regulations governing the securities industry is paramount.
  • Management of SDR Investment Management, Inc. will lead by example, creating an environment that encourages honesty and fair play by all employees in the conduct of his or her duties.
  • Management of SDR Investment Management, Inc. has reviewed (and found to be acceptable) the qualifications, experience and training of all individuals prior to assigning any supervisory responsibilities.
  • Individual employees who do not live up to this Code of Ethics, as well as all other policies and directives issued by SDR Investment Management, Inc., in every manner, during the course of any activities they undertake on behalf of SDR Investment Management, Inc. will be subject to immediate termination.

On occasion, SDR’s employees may buy or sell the same securities that they recommend to clients. There is no conflict of interest, as these securities are widely held and publicly traded. In addition, securities bought or sold for the firm’s employees on the same day as recommended to the client may be bundled together with client trades. This will ensure that employees do not get a more favorable price than the client. Bundling is the accumulation of shares into the same block at the same price on the same day. This practice may have an effect on the final price and commission costs. The Chief Compliance Officer reviews these trades monthly.