Code of Ethics


Elite Wealth Management, as a matter of policy and practice, and consistent with industry best practices and SEC requirements has adopted a written Code of Ethics covering all supervised persons. Our firm’s Code of Ethics requires high standards of business conduct, compliance with federal securities laws, reporting and recordkeeping of personal securities transactions and holdings, reviews and sanctions. The firm’s current Code of Ethics, and as amended, is incorporated by reference and made a part of these Policies and Procedures.

In July 2004, the SEC adopted an important rule (Rule 204A-1) similar to Rule 17-j-1 under the Investment Company Act, requiring SEC advisers to adopt a code of ethics. The new rule was designed to prevent fraud by reinforcing fiduciary principles that govern the conduct of advisory firms and their personnel.

Among other things, the Code of Ethics rule requires the following:

Setting a high ethical standard of business conduct reflecting an adviser’s fiduciary obligations;

  • Compliance with federal securities laws;
  • Access persons to periodically report personal securities transactions and holdings, with limited exceptions;
  • Prior approval for any IPO or private placement investments by access persons;
  • Reporting of violations;
  • Delivery and acknowledgement of the Code of Ethics by each supervised person;
  • Reviews and sanctions;
  • Recordkeeping; and
  • Summary Form ADV disclosure.

An investment adviser’s Code of Ethics and related policies and procedures represent a strong internal control with supervisory reviews to detect and prevent possible insider trading, conflicts of interest and potential regulatory violations.

The Code of Ethics is predicated on the principle that EWM has a duty to exercise its authority and responsibility for the benefit of its clients, to place the interests of its clients first, and to refrain from having outside interests that conflict with the interests of its clients. The Company must avoid any circumstances that might adversely affect or appear to affect its duty of complete loyalty to its clients.

EWM owes a fiduciary duty to its clients. Accordingly, EWM’s Employees must avoid activities, interests and relationships that run contrary (or appear to run contrary) to the best interests of clients. At all times, EWM must:

  • Place client interests ahead of EWM’s. As a fiduciary, EWM must serve in its clients’ best interests. In other words, EWM Employees may not benefit at the expense of advisory clients. This concept is particularly relevant when Employees are making personal investments in securities traded by advisory clients.
  • Engage in personal investing that is in full compliance with EWM’s Code of Ethics. Employees must review and abide by EWM’s Personal Securities Transaction and Insider Trading Policies.
  • Avoid taking advantage of your position. Employees must not accept investment opportunities, gifts or other gratuities from individuals seeking to conduct business with EWM, or on behalf of an advisory client.
  • Maintain full compliance with the Federal Securities Laws1[1] – Employees must abide by the standards set forth in Rule 204A-1 under the Advisers Act.

Any questions with respect to EWM’s Code of Ethics should be directed to the Compliance Officer. As discussed in greater detail below, Employees must promptly report any violations of the Code of Ethics to the CCO. All reported Code of Ethics violations will be treated as being made on an anonymous basis.

Guiding Principles & Standards of Conduct

All Employees of EWM, and consultants closely associated with the Company, will act with competence, dignity and integrity, in an ethical manner, when dealing with clients, the public, prospects, third-party service providers and fellow Employees. The following set of principles frame the professional and ethical conduct that EWM expects from its Employees and consultants:

Act with integrity, competence, diligence, respect, and in an ethical manner with the public, clients, prospective clients, employers, Employees, colleagues in the investment profession, and other participants in the global capital markets;

  • Place the integrity of the investment profession, the interests of clients, and the interests of EWM above one’s own personal interests;
  • Adhere to the fundamental standard that you should not take inappropriate advantage of your position;
  • Avoid any actual or potential conflict of interest;
  • Conduct all personal securities transactions in a manner consistent with this policy;
  • Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities;
  • Practice and encourage others to practice in a professional and ethical manner that will reflect favorably on you and the profession;
  • Promote the integrity of, and uphold the rules governing, capital markets;
  • Maintain and improve your professional competence and strive to maintain and improve the competence of other investment professionals.
  • Comply with applicable provisions of the federal securities laws.2

1           “Federal securities laws” means the Securities Act of 1933, the Securities Exchange Act of 1934, the Sarbanes-Oxley Act of 2002, the Investment Company Act of 1940, the Investment Advisers Act of 1940, Title V of the Gramm-Leach-Bliley Act, any rules adopted by the Commission under any of these statutes, the Bank Secrecy Act as it applies to funds and investment advisers, and any rules adopted thereunder by the Commission or the Department of the Treasury.

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