Code of Ethics
These types of securities require preclearance approval prior to being traded
What are individual debt and equity securities
Preclearance approval is also required for options, derivatives, short sales and private investments.
These are the thresholds above which preclearance approval is required for gifts and entertainment
What is $500 for gifts and $1000 for entertainment
Which of the following is considered an "off-channel" communication?
A. Slack
B. Zoom chat
C. Bloomberg messaging
D. Teams chat
B. Zoom chat
You read in the Wall Street Journal that a company announced a merger yesterday morning. The information has been widely reported and discussed by the market. Would you trade it?
Yes. The information has been broadly disseminated, is no longer non-public and there is no obligation of confidentiality (assuming no other obligations of confidentiality or restriction)
This is the number of days employees have to complete their quarterly compliance certifications
What is 30 days
Trades in these four types of securities do NOT require preclearance approval
What are ETFs, mutual funds, treasury securities and cryptocurrency
This is the dollar threshold above which preclearance approval is required for political contributions
What is $0
“Contributions” can include gifts, loans, the payment of debts, and the provision of any other thing of value, in addition to a cash donation, as well as a donation or contribution to a political action committee
These are the current firm-approved AI platforms
What is ChatGPT, Claude and Microsoft Copilot (all Enterprise versions)
Members of the investment team are conducting diligence on a public company and Kimmeridge enters into a confidentiality agreement to receive confidential information. Would you trade the stock?
No. Public companies that Kimmeridge enters into NDAs with should generally be added to the Firm's restricted list. Companies that Kimmeridge may be doing business with should not be personally traded by employees.
Legal & Compliance, along with the investment team, will assess whether the firm is in possession of MNPI pursuant to the NDA.
Kimmeridge's Abu Dhabi branch office is regulated by this regulatory body
What is the Financial Services Regulatory Authority (FSRA)
Kimmeridge has a branch office in AD with a Category 4 advising and arranging license
These three types of accounts are generally excluded from preclearance requirements, but are still subject to quarterly and annual reporting requirements
What are managed accounts, 401ks and similar retirement accounts, 529 plans
During the holiday season, an employee in the Denver office receives a gift card from a vendor for $150. This is what the employee should do when she receives the gift.
Return it to the vendor. Employees may never give or receive cash or gift cards (regardless of amount).
Before recording a Zoom meeting, the meeting host must first do this.
What is obtain participant consent
Verbal consent is permissible. May be implied by continued participation in the meeting following a recording notification pop-up. If any participant objects to being recorded, the host may elect not to record the meeting or excuse the participant.
You are unsure whether information you received at a conference about a public company is material. Would you trade it?
Confirm with Compliance.
Which of the following was NOT added or updated in the April 2026 Compliance Manual?
A. Meeting Recording Policy
B. Political Contribution pre-clearance requirements
C. Use of AI
D. Personal Trading Escalation Procedures
B. Political Contribution pre-clearance requirements
Once a trade is approved, it is valid for this number of days
What is two (2) days
These two types of outside business activities are generally excluded from preclearance approval
What is service on a cooperative apartment or condo board or not for profit or other charitable board or organization
Employees should use reasonable discretion when engaging in such activities and consider communicating with L&C to identify and address any potential conflicts of interest
This is how long meeting recordings will be stored in the Zoom cloud for before they are automatically deleted
What is 10 days
Summaries will be emailed to the host after the meeting. Audio recordings will be in Zoom cloud. If they are not downloaded within 10 days, they will be automatically deleted. If recordings are downloaded, they must be saved in the designated folder on the S drive.
You are copied on an email from another firm that was clearly intended for a different recipient. The email references an upcoming acquisition involving a public company. Would you trade it?
No. There is no free pass because the information was received accidentally. Any potential exposure to MNPI should be discussed with Legal & Compliance.
This percentage ownership threshold generally triggers a Schedule 13D or 13G filing
What is 5%
Under SEC rules, beneficial ownership of more than 5% of a public company generally triggers a reporting obligation.
Schedule 13D = generally used when an investor may seek to influence management or corporate actions. Generally due within 5 business days after crossing 5%.
Schedule 13G = shorter filing generally available for passive investors. Generally due within 45 days after the end of the quarter in which the investor exceeds 5%.
These are the four categories of securities that will generally be added to the Firm's restricted list
1. Any company in which a Kimmeridge Fund has an investment
2. Any public company Kimmeridge has entered into an NDA with or for which there is a contractual obligation not to trade
3. Securities comprising XOP
4. Any company for which Kimmeridge is in possession of MNPI
Hypothetical: Katherine, an employee of Northern Trust (Kimmeridge's fund custodian), invites Andy to the Knicks game in San Antonio (ticket valued at $1,000). NT also offers to cover airfare and hotel. Can Andy accept?
Andy can accept the ticket but cannot accept the travel or lodging.
Recording of meetings is strictly prohibited for these four types of meetings
What is (1) meetings with law firms (or meetings where external counsel is present)
(2) Kimmeridge committee meetings (ICs, Valuation, Brokerage)
(3) meetings with regulators or govt reps
(4) HR or personnel-related meetings
A Kimmeridge employee learns that Company A is going to acquire Company B. Instead of trading the securities of Company B, they buy stock in Company C, a competitor likely to be impacted. This is known as what type of insider trading?
What is shadow trading
This person is the current chair of the SEC
Who is Paul Atkins
Atkins is the 34th Chair of the SEC, nominated by President Trump and sworn in on April 21, 2025.