Ethical &

Professional
Standards
C FA L e v e l I
 Course Content

ETHICS AND TRUST IN THE INVESTMENT CODE OF ETHICS AND

A PROFESSION B STANDARDS OF PROFESSIONAL
CONDUCT
Ethics Application

GLOBAL INVESTMENT
C .
PERFORMANCE STANDARDS D
ETHICS AND TRUST IN
THE INVESTMENT
PROFESSION
What is Ethics?
Ethics can be described as a set of shared beliefs about what is
A .
good or acceptable behavior and what is bad or unacceptable
behavior.

Ethical conduct has also been described as conduct that improves

outcomes for stakeholders, who are people directly or indirectly
B affected by the conduct.

C Refers to a good or service being offered by a company. Ideally, a product should meet a
certain consumer demand, or it should be so compelling that consumers.
 Code of Ethics
A code of ethics is a written set of moral principles that can guide behavior by describing
what is considered acceptable behavior

Profession
'A profession refers to a group of people with specialized skills and knowledge who serve
others and agree to behave in accordance with a code of ethics.
 Investment professionals have a
special responsibility to use their
Need for high 01 specialized knowledge
and skills to both protect and grow
Ethical Standards 02
client assets.

in Investment Failure to act in a highly ethical

manner can damage not only client
Management. 02 wealth but also impede the success
of investment professionals

04
The fact that investment
management is an intangible
03 product makes high ethical
standards all the more important in
the financial service profession
Ethical Decision-Making Framework
Ethical decisions will be improved when ethics are integrated into a firm’s decision-making process. This
will allow decision-makers and teams to consider alternative actions as well as shorter- and longer-term
consequences from various perspectives, improving the ethical aspects of their decisions.

The following ethical decision-making framework is presented in the Level I CFA

curriculum: Ethics can be described as a set of shared beliefs about what is
A
• Identify Relevantgood
.
facts,or acceptableand
stakeholders behavior and what
duties owed, is principles,
ethical bad or unacceptable
conflicts of interest.
behavior
• Consider: Situational .
influences, additional guidance
• Decide and act
• Reflect: Was the outcome as anticipated? Why or Why Not?
Ethical conduct has also been described as conduct that improves
outcomes for stakeholders, who are people directly or indirectly
B affected by the conduct.

C Refers to a good or service being offered by a company. Ideally, a product should meet a
certain consumer demand, or it should be so compelling that consumers.
Explain Professionalism in Investment Management.

Because clients of investment professionals rely on their expertise, judgment, and ethical
principles, many of the characteristics of a profession we have described apply

Ethics can be described as a set of shared beliefs about what is

A .
Fiduciary Standard
good or acceptable behavior and Suitability
what is bad or Standard
unacceptable
behavior.

Ethical conduct has also been described as conduct that improves

outcomes for stakeholders, who are people directly or indirectly
B affected by the conduct.

C Refers to a good or service being offered by a company. Ideally, a product should meet a
certain consumer demand, or it should be so compelling that consumers.
CODE OF ETHICS
AND STANDARDS OF
PROFESSIONAL
CONDUCT
Code of Ethics
Members of CFA Institute [including Chartered Financial Analyst® (CFA®) charterholders] and candidates
for the CFA designation (“Members and Candidates”) must:
• 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.
Ethics can be described as a set of shared beliefs about what is
A .
• Place the integrity good
of theor acceptable
investment behavior
profession andand
thewhat is bad
interests or unacceptable
of clients above their own personal
interests. behavior.

• Use reasonable care and exercise independent professional judgment when conducting investment
Ethical conduct
analysis, making investment has also beentaking
recommendations, described as conduct
investment that and
actions, improves
engaging in other
outcomes for stakeholders, who are people directly or indirectly
professional activities.
B affected by the conduct.
• Practice and encourage others to practice in a professional and ethical manner that will relect credit
C
on themselves and the profession
Refers to a good or service being offered by a company. Ideally, a product should meet a
certain consumer demand, or it should be so compelling that consumers.

• Promote the integrity and viability of the global capital markets for the ultimate benefit of society
• Maintain and improve their professional competence and strive to maintain and improve the
competence of other investment professionals.
The Standards of Professional Conduct
I. Professionalism
II. Integrity of Capital Markets
III. Duties to Clients
IV. Duties to Employers
V. Investment Analysis,
EthicsRecommendations, and Actions
can be described as a set of shared beliefs about what is
VI. ConflictsA .
of Interest
good or acceptable behavior and what is bad or unacceptable
VII. Responsibilitiesbehavior
as a CFA .Institute member of CFA Candidate

Ethical conduct has also been described as conduct that improves

outcomes for stakeholders, who are people directly or indirectly
B affected by the conduct.

C Refers to a good or service being offered by a company. Ideally, a product should meet a
certain consumer demand, or it should be so compelling that consumers.
STANDARD I: PROFESSIONALISM

Standard I(A) Knowledge of the Law

Members and Candidates must understand and comply with all applicable laws, rules, and regulations
(including the CFA Institute Code of Ethics and Standards of Professional Conduct) of any government,
regulatory organization,
Ethicslicensing
can be agency, or professional
described as a set of association
shared governing
beliefs about their
what professional
is
A
activities. In the event
.
goodof conflict, Members
or acceptable and Candidates
behavior and what must comply
is bad with the more strict law, rules,
or unacceptable
or regulations. Members and
behavior. Candidates must not knowingly participate or assist in and must dissociate
from any violation of such laws, rules, or regulations.

Ethical conduct has also been described as conduct that improves

outcomes for stakeholders, who are people directly or indirectly
B affected by the conduct.

C Refers to a good or service being offered by a company. Ideally, a product should meet a
certain consumer demand, or it should be so compelling that consumers.
Recommendations for Members

 Establish, or encourage employer to establish, procedures to keep employees informed of changes in relevant
laws, rules, and regulations.
 Review, or encourage employer to review, the firm’s written compliance procedures on a regular basis.
 Maintain, or encourage employer to maintain, copies of current laws, rules, and regulations.
 When in doubt about legality, consult supervisor, compliance personnel, or a lawyer.
 When dissociating from violations, keep records documenting the violations, encourage employer to bring an
end to the violations.
 There is no requirement in the Standards to report wrongdoers, but local law may require it; members are
“strongly encouraged” to report violations to CFA Institute Professional Conduct Program

Recommendations for Firms

 Have a code of ethics.
 Provide employees with information on laws, rules, and regulations governing professional activities.
 Have procedures for reporting suspected violations
STANDARD I: PROFESSIONALISM

Standard I(B) Independence and Objectivity

Members and Candidates must use reasonable care and judgment to achieve and
Ethics can be described as a set of shared beliefs about what is
A good or acceptable
maintain independence
.
and objectivity in their professional activities.
behavior and what is bad or unacceptable Members and
Candidates mustbehavior
not offer,
. solicit, or accept any gift, benefit, compensation or
consideration that could reasonably be expected to compromise their own or
another’s independence and objectivity.
Ethical conduct has also been described as conduct that improves
outcomes for stakeholders, who are people directly or indirectly
B affected by the conduct.

C Refers to a good or service being offered by a company. Ideally, a product should meet a
certain consumer demand, or it should be so compelling that consumers.
Standard I(C) Misrepresentation
Members and Candidates must not knowingly make any misrepresentations relating to investment
analysis, recommendations, actions, or other professional activities.

Ethics can be described as a set of shared beliefs about what is

Actions thatA
.
would good
violateorthe Standard include:
acceptable behavior and what is bad or unacceptable
• Presenting third-party research as your own, without attribution to the source.
behavior.
• Guaranteeing a specific return on securities
• Selecting a valuation service because it puts the highest value on untraded security holdings.
• Selecting a performance benchmark that is not comparable to the investment strategy employed.
Ethical conduct has also been described as conduct that improves
• Presenting performance data or attribution analysis that omits accounts or relevant variables. ‘
outcomes for stakeholders, who are people directly or indirectly
B
• Offering false or misleading information about the analyst’s or firm’s expertise.
affected by the conduct.

C Refers to a good or service being offered by a company. Ideally, a product should meet a
certain consumer demand, or it should be so compelling that consumers.
Standard I(D) Misconduct

Members and Candidates must not engage in any professional conduct involving
dishonesty, fraud, or deceit or commit any act that reflects adversely on their professional
reputation, integrity, or competence.
Ethics can be described as a set of shared beliefs about what is
A
Recommendations for
.
good or acceptable behavior and what is bad or unacceptable
Firms
behavior
• Develop and adopt a code .of ethics and make clear that unethical behavior will not be tolerated.
• Give employees a list of potential violations and sanctions, including dismissal.
• Check references of potential employees.
Ethical conduct has also been described as conduct that improves
outcomes for stakeholders, who are people directly or indirectly
B affected by the conduct.

C Refers to a good or service being offered by a company. Ideally, a product should meet a
certain consumer demand, or it should be so compelling that consumers.
STANDARD II: INTEGRITY OF CAPITAL MARKETS

Standard II(A) Material Nonpublic Information

Members and Candidates who possess material nonpublic information that could affect the value of
an investment must not act or cause others to act on the information
Ethics can be described as a set of shared beliefs about what is
A for
Recommendations
.
Members
good or acceptable behavior and what is bad or unacceptable
• Make reasonablebehavior
efforts to.achieve public dissemination by the firm of information they possess.
• Encourage their firms to adopt procedures to prevent the misuse of material nonpublic
information.
Ethical conduct has also been described as conduct that improves
Recommendations outcomes
for Firms for stakeholders, who are people directly or indirectly
B
• Use a firewall within the firm, with
affected by the conduct. elements including:
• Exercise substantial control of relevant interdepartmental communications through a clearance
area, such as the compliance or legal department.
C Refers to a good or service being offered by a company. Ideally, a product should meet a
• Review employee trades.
certain consumer demand, or it should be so compelling that consumers.
• Maintain “watch,” “restricted,” and “rumor” lists.
Standard II(B) Market Manipulation

Members and Candidates must not engage in practices that distort prices or artificially inflate trading
volume with the intent to mislead market participants.
Ethics can be described as a set of shared beliefs about what is
A
Member actions may affect security values and trading volumes without violating this Standard. The
.
good or acceptable behavior and what is bad or unacceptable
key point here is that if there is the intent to mislead, then the Standard is violated. Of course,
behavior. to affect prices or volume is a violation of this Standard as is making trades
spreading false information
intended to mislead market participants.

Ethical conduct has also been described as conduct that improves

outcomes for stakeholders, who are people directly or indirectly
B affected by the conduct.

C Refers to a good or service being offered by a company. Ideally, a product should meet a
certain consumer demand, or it should be so compelling that consumers.
STANDARD III: DUTIES TO CLIENTS

Standard III(A) Loyalty, Prudence, and Care

Members and Candidates have a duty of loyalty to their clients and must act with reasonable care and
exercise prudent judgment. Members and Candidates must act for the benefit of their clients and
place their client’s interests before their employer’s or their own interests.
Ethics can be described as a set of shared beliefs about what is
A good or acceptable behavior and what is bad or unacceptable
.

• Exercise the prudence,

behaviorcare,
. skill, and diligence under the circumstances that a person acting in a
like capacity and familiar with such matters would use.
• Manage pools of client assets in accordance with the terms of the governing documents, such as
trust documents or investment
Ethical conduct has management agreements.
also been described as conduct that improves
• Make investment decisions
outcomes forin the context of
stakeholders, who theare
total portfolio.
people directly or indirectly
• B
Inform clients of any limitations
affected in an advisory relationship (e.g., an advisor who may only
by the conduct.
recommend her own firm’s products).
• Vote proxies in anRefers
informed
to a goodand responsible
being offeredmanner. Due to cost-benefit
a product shouldconsiderations, it may not
C
be necessary to vote
certainall
or service
proxies.
consumer
by a company. Ideally,
demand, or it should be so compelling that consumers.
meet a

• Client brokerage, or “soft dollars” or “soft commissions,” must be used to benefit the client.
• The “client” may be the investing public as a whole rather than a specific entity or person.
Recommendations for Members

• Follow applicable rules and laws. Establish investment objectives of client.

• Consider suitability of a portfolio relative to the client’s needs and circumstances, the investment’s basic
characteristics, or the basic characteristics of the total portfolio.
• Diversify.
• Deal fairly with all clients in regard to investment actions. Disclose conflicts.
• Disclose compensation arrangements.
• Vote proxies in the best interest of clients and ultimate beneficiaries. Maintain confidentiality.
• Seek best execution
STANDARD III: DUTIES TO CLIENTS

Standard III(B) Fair Dealing

Members and Candidates must deal fairly and objectively with all clients when providing investment
analysis, making investment recommendations, taking investment action, or engaging in other
professional activities
Ethics can be described as a set of shared beliefs about what is
A .
good are
Different service levels or acceptable
acceptable, behavior and not
but they must what is bad oraffect
negatively unacceptable
or disadvantage any clients.
behavior
Disclose the different . levels to all clients and prospects, and make premium levels of service
service
available to all those willing to pay for them.

Ethical conduct has also been described as conduct that improves

outcomes for stakeholders, who are people directly or indirectly
B affected by the conduct.

C Refers to a good or service being offered by a company. Ideally, a product should meet a
certain consumer demand, or it should be so compelling that consumers.
Recommendations for Members

• Encourage firms to establish compliance procedures requiring proper dissemination of investment recommendations and fair
treatment of all customers and clients.
• Maintain a list of clients and holdings—use to ensure that all holders are treated fairly.

Recommendations for Firms

• Limit the number of people who are aware that a change in recommendation will be made.
• Shorten the time frame between decision and dissemination.
• Publish personnel guidelines for pre-dissemination—have in place guidelines prohibiting personnel who have prior knowledge
of a recommendation from discussing it or taking action on the pending recommendation.
• Disseminate new or changed recommendations simultaneously to all clients who have expressed an interest or for whom an
investment is suitable.
• Develop written trade allocation procedures—ensure fairness to clients, timely and efficient order execution, and accuracy of
client positions.
• Disclose trade allocation procedures.
• Establish systematic account review—ensure that no client is given preferred treatment and that investment actions are
consistent with the account’s objectives.
• Disclose available levels of service.
Standard III(C) Suitability

When Members and Candidates are in an advisory relationship with a client, they must:
 Make a reasonable inquiry into a client’s or prospective client’s investment experience, risk and return
objectives, and financial constraints prior to making any investment recommendation or taking
investment action and must reassess and update this information regular

 Determine that an investment is suitable to the client’s financial situation and consistent with the client’s
written objectives, mandates, and constraints before making an investment recommendation or taking
investment action.

 Judge the suitability of investments in the context of the client’s total portfolio.

 When Members and Candidates are responsible for managing a portfolio to a specific mandate, strategy,
or style, they must make only investment - recommendations or take only investment actions that are
consistent with the stated objectives and constraints of the portfolio
Recommendations for Members

• For each client, put the needs, circumstances, and investment objectives into a written IPS.

• Consider the type of client and whether there are separate beneficiaries, investor objectives (return and risk),
investor constraints (liquidity needs, expected cash flows, time, tax, and regulatory and legal circumstances), and
performance measurement benchmarks.

• Review the investor’s objectives and constraints periodically to reflect any changes in client circumstances.
Standard III(D) Performance Presentation
When communicating investment performance information, Members and Candidates must make reasonable efforts to ensure
that it is fair, accurate, and complete.

Members must not misrepresent past performance or reasonably expected performance, and must not state or imply the ability
to achieve a rate of return similar to that achieved in the past.

Recommendations for Members

• Encourage firms to adhere to Global Investment Performance Standards.
• Consider the sophistication of the audience to whom a performance presentation is addressed.
• Present the performance of a weighted composite of similar portfolios rather than the performance of a single account.

• Include terminated accounts as part of historical performance and clearly state when they were terminated.
• Include all appropriate disclosures to fully explain results (e.g., model results included, gross or net of fees, etc.).
• Maintain data and records used to calculate the performance being presented.
Standard III(E) Preservation of Confidentiality
Members and Candidates must keep information about current, former, and prospective clients confidential unless:
1. The information concerns illegal activities on the part of the client;
2. Disclosure is required by law; or
3. The client or prospective client permits disclosure of the information

Recommendations for Members

• Members should avoid disclosing information received from a client except to authorized coworkers who are also working
for the client.

• Members should follow firm procedures for storage of electronic data and recommend adoption of such procedures if
they are not in place.
STANDARD IV: DUTIES TO EMPLOYERS

Standard IV(A) Loyalty

In matters related to their employment, Members and Candidates must act for the benefit of their
employer and not deprive their employer of the advantage of their skills and abilities, divulge
confidential information, or otherwise cause harm to their employer.

Recommendations for Members

Members are encouraged to give their employer a copy of the Code and Standards.
Best practice is to use separate social media accounts for personal and professional
communications.
Recommendations for Firms
Employers should not have incentive and compensation systems that encourage unethical
behavior.
Standard IV(B) Additional Compensation Arrangements
Members and Candidates must not accept gifts, benefits, compensation, or consideration that competes with or might
reasonably be expected to create a conflict of interest with their employer’s interest unless they obtain written consent from
all parties involved.

Compensation includes direct and indirect compensation from a client and other benefits received from third parties.

Recommendations for Members

Make an immediate written report to the employer detailing any proposed compensation and services, if additional
to that provided by the employer.

Members and candidates who are hired to work part time should discuss any arrangements that may compete with
their employer’s interest at the time they are hired and abide by any limitations their employer identifies.
Standard IV(C) Responsibilities of Supervisors
Members and Candidates must make reasonable efforts to ensure that anyone subject to their supervision or
authority complies with applicable laws, rules, regulations, and the Code and Standards.
Members must make reasonable efforts to prevent employees from violating laws, rules, regulations, or the Code
and Standards, as well as make reasonable efforts to detect violations.

Members with supervisory responsibilities have an obligation to bring an inadequate compliance system to the
attention of firm’s management and recommend corrective action

Recommendations for Members

• A member should recommend that his employer adopt a code of ethics. Members should encourage employers
to provide their codes of ethics to clients.
• Once the compliance program is instituted, the supervisor should: Distribute it to the proper personnel.
• Update it as needed.
• Continually educate staff regarding procedures. Issue reminders as necessary.
• Require professional conduct evaluations.
• Review employee actions to monitor compliance and identify violations.
Recommendations for Firms
Employers should not commingle compliance procedures with the firm’s code of ethics
 STANDARD V: INVESTMENT ANALYSIS, RECOMMENDATIONS, AND
ACTIONS

Standard V(A) Diligence and Reasonable Basis

Members and Candidates must:
• Exercise diligence, independence, and thoroughness in analyzing investments, making investment recommendations,
and taking investment actions.

• Have a reasonable and adequate basis, supported by appropriate research and investigation, for any investment
analysis, recommendation, or action.
Recommendations for Members

• Members should encourage their firms to adopt a policy for periodic review of the quality of third-party research, if they
have not.
• Have a policy requiring that research reports and recommendations have a basis that can be substantiated as reasonable
and adequate.
• Have detailed, written guidance for proper research and due diligence.
• Have measurable criteria for judging the quality of research, and base analyst compensation on such criteria.
• Have written procedures that provide a minimum acceptable level of scenario testing for computer-based models and
include standards for the range of scenarios, model accuracy over time, and a measure of the sensitivity of cash flows to
model assumptions and inputs.
• Have a policy for evaluating outside providers of information that addresses the reasonableness and accuracy of the
information provided and establishes how often the evaluations should be repeated.
• Adopt a set of standards that provides criteria for evaluating external advisers and states how often a review of external
advisers will be performed
 Standard V(B) Communication With Clients and Prospective
Clients

Members and Candidates must:

1.Disclose to clients and prospective clients the basic format and general principles of the investment
processes they use to analyze investments, select securities, and construct portfolios and must promptly
disclose any changes that might materially affect those processes.
2.Disclose to clients and prospective clients significant limitations and risks - associated with the
investment process.
3.Use reasonable judgment in identifying which factors are important to their investment analyses,
recommendations, or actions and include those factors in communications with clients and prospective
clients.
4.Distinguish between fact and opinion in the presentation of investment analyses and recommendations.
Standard V(C) Record Retention
Members and Candidates must develop and maintain appropriate records to support their investment
analyses, recommendations, actions, and other investment-related communications with clients and
prospective clients

Recommendations for Members

If no regulatory standards or firm policies are in place, the Standard recommends a seven-year
minimum holding period.
Recommendations for Firms
This recordkeeping requirement generally is the firm’s responsibility.
STANDARD VI: CONFLICTS OF INTEREST

Standard VI(A) Disclosure of Conflicts

Members and Candidates must make full and fair disclosure of all matters that could reasonably be
expected to impair their independence and objectivity or interfere with respective duties to their
clients, prospective clients, and employer. Members and Candidates must ensure that such
disclosures are prominent, are delivered in plain language, and communicate the relevant
information effectively

Recommendations for Members

Any special compensation arrangements, bonus programs, commissions, and incentives should
be disclosed.
Standard VI(B) Priority of Transactions
Investment transactions for clients and employers must have priority over investment transactions in which a Member or Candidate is the
beneficial owner.
Client transactions take priority over personal transactions and over transactions made on behalf of the member’s firm. Personal transactions
include situations where the member is a beneficial owner.

Recommendations for Members

• Members can avoid conflicts that arise with IPOs by not participating in them.
• Members should encourage their firms to adopt the procedures listed in the following recommendations for firms if they
have not done.

Recommendations for Firms

• All firms should have basic procedures in place that address conflicts created by personal investing. The following areas
should be included:
• Establish limitations on employee participation in equity IPOs.
• Establish restrictions on participation in private placements. Strict limits should be placed on employee acquisition of these
securities and proper supervisory procedures should be in place. Participation in these investments raises conflict of interest
issues similar to those of IPOs.
• Establish blackout/restricted periods. Employees involved in investment decision- making should have blackout periods prior
to trading for clients—no front running
• Establish reporting procedures, including duplicate trade confirmations, disclosure of personal holdings and beneficial
ownership positions, and preclearance procedures.
Standard VI(C) Referral Fees

Members and Candidates must disclose to their employer, clients, and prospective clients, as
appropriate, any compensation, consideration, or benefit received from or paid to others for
the recommendation of products or services

Standard VI(C) Referral Fees

Members and Candidates must disclose to their employer, clients, and prospective clients, as
appropriate, any compensation, consideration, or benefit received from or paid to others for
the recommendation of products or services
STANDARD VII: RESPONSIBILITIES AS A CFA INSTITUTE MEMBER OR CFA CANDIDATE

Standard VII(A) Conduct as Participants in CFA Institute Programs

Members and Candidates must not engage in any conduct that compromises the reputation or
integrity of CFA Institute or the CFA designation or the integrity, validity, or security of CFA Institute
programs

Members must not engage in any activity that undermines the integrity of the CFA charter. This
Standard applies to conduct that includes:
• Cheating on the CFA exam or any exam.
• Revealing anything about either broad or specific topics tested, content of exam questions, or
formulas required or not required on the exam.
• Not following rules and policies of the CFA Program.
• Giving confidential information on the CFA Program to candidates or the public. Improperly using
the designation to further personal and professional goals.
• Misrepresenting information on the Professional Conduct Statement (PCS) or the CFA Institute
Professional Development Program.
Standard VII(B) Reference to CFA Institute, the CFA Designation, and the CFA Program

When referring to CFA Institute, CFA Institute membership, the CFA designation, or candidacy
in the CFA Program, Members and Candidates must not misrepresent or exaggerate the
meaning or implications of membership in CFA Institute, holding the CFA designation, or
candidacy in the CFA Program
INTRODUCTION TO THE GLOBAL INVESTMENT PERFORMANCE
STANDARDS (GIPS)

GIPS present a standardized methodology for performance reporting that makes

comparison of performance across firms meaningful, provides specific information that
is useful to both current and prospective clients, and avoids misrepresentation of
performance.
GIPS only apply to firms that actually manage assets. Presenting performance
information compliant with GIPS is voluntary for such firms, and they may only claim
compliance with GIPS if they comply fully and on a firmwide basis
 Input data and Composite and
Fundamentals of
Calculation pooled fund
Compliance
Methodology management

Composite Pooled Fund

Composite Time
Money Time weighted
Weighted Return
Weighted Return Return

Pooled Fund
GIPS Advertising
Money weighted
Guidelines
Return
A composite is a grouping of individual discretionary portfolios representing a similar investment strategy,
objective, or mandate
Examples of possible composites are large capitalization stocks, investment-grade domestic bonds, and accounts
managed to match the performance of a specific securities index.

Concept of Independent Verification

Firms are encouraged to pursue independent verification of their compliance with GIPS. Verification applies to the entire
firm’s performance measurement practices and methods, not a selected composite
If a firm chooses to pursue verification, it must be performed by a third party, not by the firm itself, on a firmwide
basis. This third-party verifier must attest that (1) the firm has complied with all GIPS requirements for composite
construction on a firmwide basis and
(1) the firm’s processes and procedures are established to present performance in accordance with the calculation
(2) methodology required by GIPS, the data requirements of GIPS, and in the format required by GIPS.
Verified firms should include the following disclosure language:
[Insert name of firm] has been verified for the periods [insert dates] by [name of verifier]. A copy of the verification
report is available upon request