Asset Manager Code

Asset Manager Code

Download the Code


The Asset Manager Code (the Code) outlines the ethical and professional responsibilities of firms that manage assets on behalf of clients. The principles and provisions address six broad categories: (1) loyalty to clients, (2) investment process and actions, (3) trading, (4) risk management, compliance, and support, (5) performance reporting and valuation, and (6) disclosures. 

What Is Covered?

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.

The Code 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 

How Can I Comply?

Your firm may already have a code of ethics in place that addresses or goes beyond the principles and provisions in the CFA Institute Asset Manager Code. Provided your code is consistent with ours, you do not need to amend your existing code to comply with ours. 

  1. Review your firm’s existing code of ethics, policies, and procedures in comparison to the Code and identify possible gaps or differences.
  2. Refer to the Appendix: Recommendations and Guidance (PDF) and review the interpretations and additional guidance (PDF) to help you determine whether your firm's procedures comply.
  3. Make revisions, as needed, to align with the Code.   
  4. Complete and submit the claim of compliance form.

Consider the RCA Compliance Transparency Platform – Implementing the CFA Institute Asset Manager Code, a third-party tool for reviewing compliance by your firm.

Why Was it Developed?

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. Rather than evaluating each firm's code of conduct separately, clients can use the CFA Institute Asset Manager Code to quickly identify firms that commit to a common foundation of ethical principles. Adopting the Code isn't an "either - or" proposition; some managers already comply simply on the strength of their existing code of ethics.


The Code is a high-level summary (2 pages) of the principles and requirements of the Asset Manager Code. Recommended Guidance provides you more details about how to interpret the Code.

All of the following are PDF documents.

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