Compliance Policy and Code of Ethics, effective 01/25/18
This policy addresses the practices of Linscomb & Williams, Inc. (“the Adviser”), a registered investment adviser. Employees need to be aware that it is a criminal and civil offense, as well as a violation of industry regulations and Firm policy, to trade on material non-public information (“insider information”) or to pass it along to others who make trade on it.
a. “Material nonpublic information” is information about an issuer of securities which has not been disclosed to the general public and which would be important to a reasonable investor in determining whether to trade in the issuer’s securities. Material nonpublic information also includes information not available to the general public, which would be likely to affect the price of the securities. Examples of material nonpublic information could include, for example, the following types of information: pending mergers, new products, labor matters, government investigations, or anticipated litigation. Information is usually not considered to be public unless reported in general circulation news media, revealed by the company in a public forum, discussed in a research report or otherwise made publicly available.
b. “Insider trading” is trading in securities while in possession of material nonpublic information or the communication of material nonpublic information to others. The penalties for insider trading can include prison sentences, damages, disgorgement of profits, and injunctions.
c. An “insider” includes an officer, director, or employee of a company. One also can become a temporary insider by providing services including accounting, consulting, bank lending, or legal advice to a company.
d. Our policy is that L& W will not provide any investment advice to clients, nor manage client accounts based on material nonpublic information. Employees are forbidden from engaging in insider trading or sharing material nonpublic information with others.
e. Each employee is required to confirm in writing that he or she has no access to material nonpublic information about any publicly traded company. If an employee becomes aware of any material nonpublic information, the employee will not trade in the securities of the company about which the information is known until the information has been public for at least twenty-four hours.
Moreover, any employee who becomes aware of material nonpublic information is forbidden from divulging the information to anyone, including members of his or her family, or from communicating the information in any manner to others at L&W (other than the CCO). L&W will monitor the trading of employees for prohibited transactions. Additionally, at least annually, each employee of L&W will be required to certify that he or she has read this policy, understands it, and has not violated it.
f. Compliance with this policy is extremely important. Failure to comply with this policy can result in various sanctions – monetary fines, disgorgement of profits realized, and even employment termination. Sanctions in connection with this policy shall be determined by the CCO and the Finn’s Investment Committee. All questions about this policy should be directed to the CCO.