Compliance

 

Trading and Performance Review

• Trade Order Management Committee
  • Best Execution
  • Soft Dollar Review
• Annual GIPS performance audit and verification
• Performance Evaluation and Technology Committee

Operations

• Maintain portfolio trading/accounting systems
• Monthly portfolio reconciliation and performance attribution analysis
• Proxy Voting and Reporting Committee

Code of Ethics and Compliance Reviews

• Annual Compliance Report
• Ongoing compliance training
• Trade Monitoring and Compliance Committee

Sarbanes Oxley 404 Compliant

• Quarterly testing of internal controls by internal and external auditors
• Annual IT systems and network testing

Disaster Recovery

• Remote systems access
• Replicated off-site network