Judge if the practices and procedures of an asset management firm are in line with the Asset Manager Code

Testing compliance is a provision-by-provision audit. Loyalty: are client interests put first, client information protected, and gifts that could sway independence refused? Investment process: are funds run strictly to their stated mandate, with each separate account's objectives and constraints recorded and reviewed? Trading: is best execution sought, are soft commissions used only for client benefit, and is allocation fair? Risk management and compliance: is there a designated compliance officer, independent third-party confirmation of client holdings, adequate records, qualified staff and a business continuity plan? Performance and valuation: are holdings at fair market prices, independently sourced where possible? Disclosures: are fees, conflicts and regulatory actions disclosed? A firm meeting only some provisions, or only for some products, cannot claim compliance.