Quarterly Compliance Attestation
Employee Name: ______
To: Chief Compliance Officer
Re: Quarterly Compliance Attestation for the three-month period ending on [Insert Date] (the “Past Quarter”)
- ThePolitical Contribution Policy prohibitsemployees and their spouses and dependants from making any political contributionwithout obtaining pre-clearance from [ ] or engaging in any political activity for the purpose of directly or indirectly influencing or inducing the obtaining or retaining of theinvestment advisory services by a government entity. Furthermore, thePolitical Contribution Policy prohibitsemployees and their spouses and dependants from soliciting or coordinating any other person or political action committee (“PAC”) to make any political contribution or payment to a government official (whether federal, state or local), candidate for government office (whether federal, state or local), political party or PAC without obtaining pre-clearance by the [ ].
I certify that I have read, I understand and I have complied with the Political Contribution Policy during the Past Quarter. ______(please initial).
2. Choose either (a) or (b):
(a) During the Past Quarter, I and my spouse and dependants have not made (or directed to be made) any contributions to (or volunteered for or otherwise engaged in any activity with respect to) government officials (whether federal, state or local), candidates for government office (whether federal, state or local), political parties or PACs. ______(please initial if applicable); or
(b) During the Past Quarter, I or my spouse or dependants have made (or directed to be made) the following contributions to (or volunteered for or otherwise engaged in any activity with respect to)government officials (whether federal, state or local), candidates for government office (whether federal, state or local), political parties or PACs and I have pre-cleared all such contributions and activities in accordance with the Political Contribution Policy:Date of Contribution/ Activity / Date of Pre-Clearance / Candidate/Party / Election / Amount
Employees have received the Firm’s Compliance Manual which outlines policies and procedures with respect to insider trading. Additionally, the Firm continues to conduct compliance training throughout the year. It is imperative that employees follow the Firm’s policies and procedures in this area. Employees are encouraged to ask general questions on the subject matter and are reminded of the following:
- They must comply with the Firm’s Insider Trading Policy;
- They must continue to inform[ ]immediately aboutany fact patterns, large or small, that may arise with regard to potential material, non-public information;
- They are generally prohibited from disclosing or discussing confidential information concerning portfolio positions and investment plans to personnel at other firms other than as required in connection with obligations and responsibilities as an employee; and
- They are prohibited from trading on material non-public information that they may have received.
I agree that I understand and that I have complied with the above as may be applicable during the Past Quarter. Additionally, I have not received any material non-public information that I have not disclosed to the[ ]nor used any material,non-public information for my own benefit. ______(please initial).
- During the Past Quarter, I have not used any personal email accounts (such as those provided by Hotmail, Google, AOL or Yahoo), or any other form of non-Firm provided email, instant messaging or text messaging, to conduct company business of any kind or to create communications that would otherwise be required to maintain pursuant to the Investment Advisers Act of 1940, as described in the Compliance Manual except in the event of a business disruption whereby my business email address was copied in accordance with the Firm’s policies.
- During the Past Quarter, I have not given or received any gifts, favors, entertainment, special accommodations, or other things of material value (collectively, “Gifts”) in violation of the Gift Policy and I have not failed to report any Gifts required to be reported pursuant to such policy.
- During the Past Quarter, I have not used any personal social networks (such as those provided by Facebook, Twitter, MySpace, LinkedIn or YouTube), or any other form of non-Firm provided social network, to conduct company business of any kind or to create communications that would otherwise be required to maintain pursuant to the Compliance Manual except in the event of a business disruption whereby my business email address was copied in accordance with the Firm’s policies.
- During the Past Quarter, I have complied with the Firm’s personal trading policies including pre-clearance and/or the reporting of all non-brokeragetransactions, such as investments in privately-placed securities and private investment funds (including hedge funds) that are not provided through personal brokerage statements and confirmations.
- During the Past Quarter, I have complied with the Firm’s policy on the Foreign Corrupt Practices Act and have pre-cleared any gifts or entertainment related to government officials with [ ].
- During the Past Quarter, I have complied with the Firm’s policies regarding Outside Affiliations and Business Activities.
- During the Past Quarter, I have not been involved in any unethical or conflict of interest situation nor was I aware of any material unethical or conflict of interest situation on the part of any employee that has not been reported to senior management.
In the space provided below, please explain any exceptions related to questions 1-7 above:
By signing below, you confirm that the information and responses you have provided above are complete and accurate in all material respects to the best of your knowledge. Further, by signing below, you acknowledge the following:
I have been given, have access to, have read and understand the Compliance Manual and have complied with the Compliance Manual over the past quarter. I recognize that I am subject to the Compliance Manual and agree to comply with all provisions of the Compliance Manual applicable to me.
Signed: ______Date: ______
Report reviewed by: ______Date: ______
 For purposes of the Political Contribution Policy the term “contribution” is broadly defined and includes a donation of money, a donation of resources (such as a personal residence, office location or refreshments for a campaign event or in furtherance of a campaign), loans, advances, payments of campaign-related expenses and transitional and inaugural expenses, payments to satisfy debts incurred in connection with an election and anything else of value for the purpose of influencing an election.