Asset Manager Code

This voluntary code of conduct helps asset managers practice ethical principles that put client interests first.


What Does it Cover?

The Code outlines the ethical and professional responsibilities of firms that manage assets on behalf of clients. It provides standards and supportive guidance based on general principles of conduct.

It states that managers have these responsibilities to their clients:

  • To act in a professional and ethical manner at all times
  • To act for the benefit of clients
  • To act with independence and objectivity
  • To act with skill, competence, and diligence
  • To communicate with clients in a timely and accurate manner
  • To uphold the rules governing capital markets

Many firms have their own conduct standards in place to guide their work, but it can be difficult for clients to compare different codes and identify key differences in the firm's level of commitment toward protecting their interests.

How Do Investors Benefit from the Asset Manager Code?

Plan sponsors and other investors can easily identify which asset managers uphold the ethical foundation that resolves conflicts of interest in favor of investors. By adopting the Code, asset management firms signal their commitment to commonly held ethical principles.

How Can My Firm Comply?

  • Review your firm’s existing code of ethics, policies, and procedures in comparison to the Code and identify possible gaps or differences.
  • Refer to the Recommendations and Guidance (Appendix) and review the interpretations and additional guidance to help you determine whether your firm's procedures comply.
  • Make revisions, as needed, to align with the Code.
  • Make revisions, as needed, to align with the Code.