Are there requirements for claiming compliance with the Asset Manager Code of Professional Conduct?
Yes. After an asset management organization determines it is in compliance with all aspects of the Code, it must notify CFA Institute by completing a claim of compliance form (PDF).

In addition, the following statement must be made whenever the manager states compliance with the Code:

“[Insert name of manager] claims compliance with the CFA Institute Asset Manager Code of Professional Conduct. This claim has not been verified by CFA Institute.”

Can a manager selectively adopt only portions of the Asset Manager Code of Professional Conduct?
No. Adoption of or compliance with the Code requires that firms adhere to all of the principles of conduct and provisions set forth in the Code. If a firm makes substantive changes that lead to the firm not complying with each of the principles of conduct and provisions of the Code, the firm may not represent that it is in compliance with the Code.

Does CFA Institute verify compliance with the Asset Manager Code of Professional Conduct?
No. CFA Institute does not verify compliance with the Code, nor are managers required to have external assessments or verifications of their adopted code of ethics. CFA Institute supports many self-regulation models and voluntary sets of professional conduct standards relevant to the investment industry, of which the Asset Manager Code of Professional Conduct is one.

Can a manager modify the Asset Manager Code of Professional Conduct to suit its needs?
Yes. A firm may reproduce the text of the Code entirely as written or may modify the Code to suit the firm’s needs, as long as those modifications result in a code that is consistent with the principles and provisions set forth in the Asset Manager Code of Professional Conduct. Many firms already have codes of ethics and other policies and procedures in place that address or go beyond the principles and provisions of the Asset Manager Code of Professional Conduct. Adoption of, or compliance with, the Code does not require a firm to amend its existing code of ethics or other policies and procedures, again, provided that they are at least consistent with the principles and provisions set forth in the Code.

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