Asset Manager Code

This voluntary code of conduct helps asset managers practice ethical principles that put client interests first.

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.

How Can My Firm Comply with the Code?

  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 Recommendations and Guidance (Appendix) and review the interpretations and additional guidance 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.

How Do Investors Benefit from the Code?

Plan sponsors and other investors can easily identify which asset managers uphold the ethical foundation that resolves conflicts of interest in favor of investors. By adopting the Code, asset management firms signal their commitment to commonly held ethical principles.

Who Should Adopt this Code?

Asset management firms. Over 1,300 firms already claim compliance with the code. See the list of firms that claim compliance.

What Does the Code Cover?

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.

It 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

Why Did CFA Institute Develop This Code?

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.

How Was the Code Developed?

CFA Institute developed the Asset Manager Code in consultation with investors and asset managers. We sponsor an advisory committee of practitioners to review the Code and help promote its adoption.

Learn about the Asset Manager Code Advisory Committee

Questions? Contact us