This code of ethics sets forth the standards of business conduct for all Eight Ventures Private Wealth Management (“Eight Ventures”) personnel. Eight Ventures was created in order to serve others. The values that led to the creation of Eight Ventures are these:
- Doing unto others as you would have them do unto you
- 100% transparency
- 100% honesty
- 100% independence
- 100% conflict-free
Our fiduciary structure is about placing clients first. Taking pride in the way we do business ensures that clients get the unbiased support they have been promised.
Standard of Conduct
Eight Ventures personnel are required to meet their fiduciary obligation by acting only in the best interest of clients. Further, Eight Ventures’ compensation structure and other policies (e.g., soft dollar and referral policies) are structured to ensure firm and client interests are fully aligned.
Compliance
Eight Ventures personnel will comply with all federal securities laws governing Registered Investment Advisor activity.
Communication
Eight Ventures personnel will communicate with honesty and forthrightness. Eight Ventures personnel will not mislead a client in any manner, including the use of manipulative practices or the deliberate omission of material facts. It is the goal of Eight Ventures to communicate liberally with clients regarding all activities conducted on their behalf, consistent with client preferences regarding the frequency of communications.
Protection of Material Nonpublic Information
Eight Ventures personnel are prohibited from trading, either personally or on behalf of others, while in possession of material, nonpublic information. Further, they are prohibited from communicating such information to others. Insider trading is prohibited.
Strict Confidentiality
Eight Ventures personnel will not disclose a client’s personal information, to include account details and transactions.
Client Referrals and Other Compensation
The Eight Ventures business model hinges on strong customer referrals from existing clients as well as friends and professional colleagues who trust Eight Ventures to place clients first. The firm may provide those referring parties with non-monetary tokens of appreciation; however, Eight Ventures will never pay money for referrals. Regarding outgoing referrals, Eight Ventures will not accept referral fees from other professionals when a prospect or client is referred to them.
Similarly, in order to protect against conflicts of interest, Eight Ventures will not accept “other compensation” of any type or form.
Personal Trading Procedures
Eight Ventures personnel will conduct trading in their own personal accounts in a manner consistent with the requirements of the Code of Ethics to avoid any potential conflict of interest or any abuse of the employee’s position of trust at Eight Ventures. Eight Ventures personnel are prohibited from engaging in the following:
- front running client trades
- selling securities from their own portfolio directly to a client
- buying securities directly from a client for their own portfolio
Reporting on Holdings for Access Persons
All Eight Ventures “access persons” are required to report all personal securities holdings to the Chief Compliance Officer. Access persons will submit a complete report of the securities that they hold at the time they first become an access person at Eight Ventures, due prior to offer of employment. This report will be updated annually, within thirty days of the fiscal year.
These reports must include all accounts in which the access person has a financial interest, irrespective of whose name such an account is registered under. These additional report inclusions would always include spouse holdings in households filing “married filing jointly,” but often applies more broadly.
Adherence to the Code of Ethics
All Eight Ventures personnel will be provided with a copy of the Code of Ethics and will be required to respond with a written acknowledgement that they have reviewed it and agree to fully comply with all of its provisions, in both letter and spirit.
Availability of the Code of Ethics
Eight Ventures’ Code of Ethics will be provided to clients and prospective clients upon request.