Taos Global Investors, LLC has adopted a Code of Ethics (“Code”), pursuant to SEC rule 204A- 1, that describes the standards of business conduct that it requires of employees and accounts owned predominantly by persons associated with Taos Global Investors, LLC, and establishes procedures intended to prevent Taos Global Investors, LLC, and its personnel and certain of their relatives, from inappropriately benefiting from Taos Global Investors, LLC’s relationships with its clients.
The Code provides that:
(i) Taos Global Investors, LLC’s clients’ interests come before Taos Global Investors, LLC’s or employees’ interests;
(ii) Taos Global Investors, LLC must disclose to clients all material facts about conflicts of which it is aware between Taos Global Investors, LLC’s and its employees’ interests on the one hand and clients’ interests on the other;
(iii) Employees must operate on Taos Global Investors, LLC’s and their own behalf consistently with Taos Global Investors, LLC’s disclosures to and arrangements with clients regarding conflicts and its efforts to manage the impacts of those conflicts;
(iv) Taos Global Investors, LLC and its employees must not take inappropriate advantage of Taos Global Investors, LLC’s clients or their positions of trust with or responsibility to clients; and
(v) Taos Global Investors, LLC and its employees must comply with all applicable securities laws.
The Code generally prohibits employees from trading in any securities held by client accounts and requires employees to report personal securities holdings on an annual basis. In addition, Taos Global Investors, LLC monitors all employees’ securities transactions: employees must arrange for duplicate copies of their brokerage statements and trade confirmations to be sent to the Chief Compliance Officer. The Code includes procedures for and restrictions on employee trading intended to prevent employees from benefiting from, or appearing to benefit from, any price movement that may be caused by client transactions or Taos Global Investors, LLC’s recommendations regarding securities. Among other things, these include requirements that employees make a written request for and receive clearance from Taos Global Investors, LLC’s Chief Compliance Officer (or his or her designee) before they buy or sell any security (other than certain government securities, shares of mutual funds not managed by Taos Global Investors, LLC, and certain other types of securities that Taos Global Investors, LLC does not believe create a potential for conflicts of interest). Pre-cleared transactions must be completed within a specified time frame. The Code also contains restrictions on and procedures to prevent inappropriate trading while Taos Global Investors, LLC is in possession of material nonpublic information.
The pre-clearance process is used to prevent front-running in accordance with Taos’ policy that client interests come before the interests of Taos and its employees. If a conflict of interest does arise, then the client account always comes first. In an instance of allocation, better prices will always be given to client accounts.
In general, positions will be purchased and automatically allocated by the broker based on the net liquidation value of each account. The Taos proprietary account will be one of the allocation accounts and should receive the same price as all other accounts. In rare instances, the allocations may be different from this, based on client request, requirement, or for extraordinary risk control. When a client relationship begins, it will be their option either to replicate the Taos proprietary account immediately or align over time as new positions are added.
Taos Global Investors, LLC will provide a copy of its Code of Ethics to any client or prospective client upon request. Such a request may be made by submitting a written request to Taos Global Investors, LLC.