Employee (access person)
Portfolio manager, trader, research analyst, operations staff and others designated as access persons
Meets their obligations under the Code of Ethics: pre-clearing trades, declaring accounts and submitting reports and certifications.
Sees
- Their own pre-clearance requests and decisions
- Their declared accounts and the trades and holdings loaded for them
- Their reporting and certification obligations and due dates
- Questions from compliance about their own trades
Does
- Submits pre-clearance requests
- Declares new accounts and reports closed ones
- Submits holdings and quarterly transaction reports
- Acknowledges the Code of Ethics and its amendments
- Answers compliance questions about their trades
Cannot
- See why a security is on the watch list or the list itself
- See other employees' requests, trades or exceptions
- Change a decision on their own request