EX-99.H OTH MAT CONT 11 coe-uva.htm CODE OF ETHICS - UNIVERSAL VALUE ADVISORS


Code of Ethics
In July 2004, the SEC adopted an important rule (Rule 204A-1) similar to Rule 17J-1 under the Investment Company Act, requiring SEC advisers to adopt a code of ethics. The new rule was designed to prevent fraud by reinforcing fiduciary principles that govern the conduct of advisory firms and their personnel. UVA, as a matter of policy and practice, and consistent with industry best practices and SEC requirements, has adopted the following Code of Ethics covering all supervised persons:
•
All UVA Supervised Persons are required to conduct themselves professionally, with integrity and good faith;
•
To comply with all applicable state and federal laws, rules and regulations, and the Policies and Procedures of the Firm;
•
To acknowledge our fiduciary duty to our clients, and our clients right to disclosure of any conflict of interest, and  avoid any action that might conflict with our interests of our clients, or that could be potentially construed as being in conflict with our client's interests;
•
To ensure that each supervised person does not put their trading interests ahead of our clients, each supervised person is required to:
o
Report and attest to their initial holdings, including any accounts of which they have a beneficial interest;
o
Custody their personal and related beneficial accounts at one of the Firm's custodians and under the same Master number as that of the Firm;
o
Provide transactional records and account statements upon request, and on an annual basis;
o
To hold secure client private, non-public information.
 The Firm's current Code of Ethics, and as amended, is incorporated by reference and made a part of these Policies and Procedures.
 Objectives
•
Setting a high ethical standard of business conduct reflecting an adviser's fiduciary obligations;
•
Compliance with federal securities laws;
•
Access persons to periodically report personal securities transactions and holdings, with limited exceptions;
•
Prior approval for any Initial Public Offering or private placement investments by access persons;
•
Reporting of violations;
•
Delivery and acknowledgement of the Code of Ethics by each supervised person;
•
 Reviews and sanctions;
•
Recordkeeping; and
•
Summary Form ADV disclosure.
An investment advisor's Code of Ethics and related policies and procedures represent a strong internal control with supervisory reviews to detect and prevent possible insider trading, conflicts of interest and potential regulatory violations.
UVA has adopted procedures to implement the Firm's policy on personal securities transactions and reviews to monitor and ensure the Firm's policy is observed, implemented properly and amended or updated, as appropriate, which include the following:
•
The Compliance Department maintains a list of the Firm's advisory representatives which is updated periodically;
•
Employees are to identify any personal investment accounts and any accounts in which the employee has a beneficial interest, including any accounts for the immediate family and household members, upon hire, annually thereafter and upon opening or closing any account(s);
•
For SEC registered firms, individuals identified as access persons must report all required information for covered personal securities transactions on a quarterly basis within 30 days of the end of each calendar quarter to the Compliance Officer or other designated officer;
•
Maintains appropriate records of the Firm's advisory representatives and employees, and reports of personal securities transactions, among other things;
•
Review all employees' reports of personal securities transactions for compliance with the Firm's policies, including the Insider Trading Policy, regulatory requirements and the Firm's fiduciary duty to its clients, among other things;
•
Employees are required to arrange for their personal and related beneficial accounts to be held under the same Custodial Master Account number as that of the Firm.