Code of Ethics Policies

Aviance maintains an investment policy relative to personal securities transactions. This investment policy is part of Aviance’s overall Code of Ethics (“Code”), which serves to establish a standard of business conduct for all Aviance’s Supervised Persons that is based upon fundamental principles of openness, integrity, honesty, and trust.  A copy of the Code of Ethics is available upon request.

The Code is distributed to each employee at the time of hire and at least annually thereafter upon any material changes. It is supplemented with annual training and ongoing monitoring of employee activity.

 The Code includes provisions related to the following:

•    Confidentiality of client information;

  • Prohibitions on
    • Insider trading (Aviance’s policy prohibits any employee from acting upon, misusing, or disclosing any material, nonpublic corporate information, known as inside information, for their own benefit);
    • Accepting or giving gifts that exceed our internal limitations;
    • Reporting of potential personal conflicts of interest;
    • Reporting outside business activities;
    • Reporting of political contributions;
  • Reporting of gifts;
  • Pre-clearance of all personal securities transactions as required by securities laws;
  • Reporting of business entertainment;
  • Quarterly and annual reporting of personal securities transactions; and
  • Annual acknowledgment of the receipt and understanding of the Code of Ethics by all Supervised Persons.  This includes verification of their compliance with the Code and identification of all securities accounts over which they exercise control.

 Aviance and/or representatives of Aviance may buy or sell securities that are also recommended to clients. This practice may create a situation where Aviance and/or representatives of the firm are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. 

 Aviance has policies in place to detect and prevent insider trading by employees. As part of the Code of Ethics, each Access Person of Aviance must provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide the Chief Compliance Officer or his/her designee with an annual written report of the Access Person’s securities holdings and a quarterly report of transactions within thirty (30) days of the end of the calendar quarter. Aviance and/or representatives may buy or sell securities, at or around the same time (but not prior to client trades) as those securities are recommended to clients.

April 2018