Code of Ethics
Our commitment to the highest standards of professional conduct and fiduciary responsibility
As a registered investment advisor with the Securities and Exchange Commission, Vetta Investment Management is held to the highest fiduciary standard. We are legally and ethically obligated to act in our clients' best interests at all times. This Code of Ethics establishes the principles and standards that guide our professional conduct.
Core Principles
We acknowledge and accept our fiduciary duty to our clients. This means we are legally and ethically bound to act in our clients' best interests, placing their interests ahead of our own. All investment recommendations and decisions are made with the sole objective of benefiting our clients.
We conduct our business with the highest standards of integrity and honesty. We provide accurate and complete information to clients, regulators, and other stakeholders. We do not engage in any deceptive practices or misrepresentation of our services, performance, or capabilities.
We believe in complete transparency with our clients. This includes full disclosure of our fee structure, potential conflicts of interest, investment risks, and complete historical performance data. Clients have access to detailed monthly reports showing all portfolio holdings and transactions.
We maintain strict confidentiality regarding all client information. Client data, account details, and personal information are protected and never disclosed to third parties except as required by law or with explicit client consent. We maintain robust data security measures to protect client information.
We are committed to maintaining and enhancing our professional competence. Our team continuously studies market conditions, investment strategies, and regulatory developments. We invest in research and technology to ensure our investment process remains at the forefront of quantitative portfolio management.
Specific Standards of Conduct
Conflicts of Interest
We identify and disclose all material conflicts of interest to our clients. When conflicts arise, we take appropriate steps to ensure they do not compromise our fiduciary duty. Our fee structure is designed to align our interests with those of our clients—we succeed when our clients succeed.
Personal Trading
All personnel are subject to personal trading restrictions designed to prevent conflicts with client interests. We maintain policies that prohibit front-running, insider trading, and other practices that could disadvantage clients. Personal trades by access persons are monitored and must be reported.
Best Execution
We seek best execution for all client trades, considering factors including price, speed, likelihood of execution, and overall cost. We regularly review our execution quality and broker relationships to ensure clients receive favorable execution.
Fair Allocation
When executing trades across multiple client accounts, we ensure fair and equitable allocation. No client receives preferential treatment in trade execution or allocation. All clients following the same strategy receive the same portfolio composition.
Accurate Performance Reporting
All performance figures are calculated accurately and reported honestly. Our track record includes all periods, both favorable and unfavorable. Performance is reported net of all fees, giving clients a true picture of actual returns. We do not cherry-pick time periods or selectively report results.
Regulatory Compliance
We maintain full compliance with all applicable securities laws and regulations. This includes registration requirements, reporting obligations, and operational standards set by the SEC and other regulatory bodies. We cooperate fully with regulatory examinations and inquiries.
Client Communication
We communicate with clients in a clear, honest, and timely manner. We respond promptly to client inquiries and concerns. We provide regular performance reports and are available to discuss portfolio performance, strategy, and any client questions.
Enforcement and Accountability
This Code of Ethics is not merely aspirational—it represents binding standards that all personnel must follow. Violations of this Code are taken seriously and may result in disciplinary action up to and including termination.
All personnel receive training on this Code and are required to acknowledge their understanding and commitment to upholding these standards. The Code is reviewed annually and updated as necessary to reflect evolving best practices and regulatory requirements.
Clients who have concerns about potential violations of this Code are encouraged to contact us directly. We take all compliance concerns seriously and investigate them thoroughly.
Our Commitment
We are committed to upholding the highest standards of professional conduct and fiduciary responsibility. Our clients trust us with their financial future, and we take that responsibility seriously. This Code of Ethics reflects our unwavering commitment to acting in our clients' best interests at all times.