WHAT DOES THE CODE COVER? The principles of the Code outline the ethical and professional responsibilities of firms that manage assets on behalf of clients while allowing flexibility in implementation for asset managers of various sizes and structures. The Code provides practical guidelines in six main areas of conduct designed to apply facets of the manager-client relationship: Supported by specific guidance, the general principles of the Code state that investment managers have those responsibilities to their clients: WHO BENEFITS? Both investors and asset managers who value high ethical and professional standards benefit from the adoption of a universal code of conduct. THE ASSET MANAGER CODE