Western Equity Group


 

 
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Code of Ethics

Western Equity Group employees and Registered Representatives are committed to providing high-quality investment guidance to our clients in a manner that puts the clients' interest first, with full compliance to applicable federal and state rules and regulations. Accordingly, Western Equity Group has adopted the following Code of Ethics.

This Code of Ethics applies to the Firm, it's officers, managers, registered representatives and employees ("Associated Persons").

Fair Dealing

The Firm and all Associated Persons acknowledge their duty to deal fairly with each client. This means the Firm and Associated persons will treat all clients equally, refrain from extending any preferential treatment to any one group or individual, and strive to conduct client relationships with honesty and integrity.

Confidentiality

Associated Persons must treat confidential information with care to avoid disclosure of such information, unless disclosure is authorized or legally required. Confidential information includes, but is not limited to the following:

  • Information about the Firm's clients, including their names, addresses, other personal information, portfolio transactions and portfolio holdings;
  • Investment advice given to the Firm's clients;
  • Non-public information about the Firm that could aid or assist the the Firm's competitors or, if disclosed would be harmful to the Firm and
  • Personal information about the Firm's personnel.

Conflicts of Interest

A conflict of interest occurs when the Firm's interest's or an Associated person's interest's conflict with the interests of one or more clients. This includes, but is not limited to, receipt by the Firm or it's Associated Persons any undisclosed benefits or compensation and may also include certain personal securities transactions by Associated persons.

The Firm seeks to review all actual or potential conflicts of interest. Accordingly, Associated persons should take care to avoid situations in which there may be a conflict of interest, and to promptly report such situations to the Firm's Compliance department for further action.

Insider Trading

Associated Persons are required to avoid potential violations of the Firm's Insider Trading Policy, as well as laws and regulations designed to prevent insider trading. The Firm's Insider Trading Policy is included in the Firm's Written Supervisory Procedures. A Compliance Principal reviews all Associated Person's  securities accounts for compliance with the Insider Trading Policy.

Reporting Illegal and/or Unethical Activities

In the event that an Associated person becomes aware of activities that may be illegal or unethical, regardless of whether the activities are specifically addressed in this Code of Ethics, that person must promptly report the activities to the Compliance Department.

Associated persons must not, under any circumstances destroy, delete, falsify or alter any books or records that are required to be kept under this Code of Ethics, or related to any violation of this Code. Associated persons must promptly comply with any directives from the Compliance Department regarding record preservation and retention.

Pre-Approval by Associated Persons

The Firm prohibits any Associated Persons from purchasing Initial Public Offerings ("IPO's"). Additionally, Associated Persons must obtain written approval from the Firm's Chief Compliance Officer before making an investment in a "Private Placement." 

Disclosure by Associated Persons

Associated Persons must disclose all securities accounts maintained or in which they have a financial interest, whether with the Firm, another Broker-Dealer, a Registered Investment Advisor or a Trust Company. (This requirement does not apply to accounts limited to transactions in Investment Company Shares and Unit Investment Trusts.)

Compliance

The Firm expects and requires all Associated Persons to fully comply with this Code of Ethics as well as all laws, rules and regulations applicable to the Firm's operations and business which include:

  • The Investment Advisor Act of 1940
  • The Investment Company Act
  • The Securities Act of 1933
  • The Securities Exchange Act of 1934
  • Title V (privacy) of the Gramm-Leach-Bliley Act
  • The Sarbanes Oxley Act of 2002
  • The Bank Secrecy Act (Anti-money Laundering)

The obligations of the Firm as well as all Associated Persons are set forth in the Firm's Written Supervisory Procedures.

Updates and Amendments

The Firm will review and update it's Code of Ethics on a periodic basis. The review determines whether the Firm's Written Supervisory Procedures are adequate, accurate and effective. The Firm also periodically updates and amends the Code of Ethics based upon changes in laws, regulations, the Firm's business and/or the Industry.