Code of Ethics
These types of securities require preclearance approval prior to trading
What are individual equity and debt securities and private placements
These are thresholds above which preclearance approval is required for gifts and entertainment
Gifts: $500
Entertainment: $1000
Which of the following is considered an "off-channel" communication:
1. Slack
2. Zoom video
3. WhatsApp
4. Teams Chat
3. WhatsApp
Approved methods include Microsoft Outlook, Teams, Slack, Bloomberg Messaging, Global Relay Messaging
This is information about a company that has not been made public and would likely influence an investor's decision to buy or sell securities
What is material nonpublic information
Kimmeridge's Abu Dhabi branch office is regulated by this regulatory body
What is the Financial Services Regulatory Authority (FSRA)
Kimmeridge has its Category 4 advising and arranging license in ADGM.
These types of securities do NOT require preclearance approval prior to trading
What are ETFs, mutual funds, money market instruments, treasuries and cryptocurrency
This is the dollar ($) threshold above which preclearance approval is required for political contributions
$0
This is who you need approval from to access AI platforms such as ChatGPT and Gemini
What is Legal/Compliance and IT
True/False: Trading on MNPI does not apply to private companies
False
In SEC v. Stiefel Laboratories, Stiefel Laboratories and its then-CEO repurchased stock from employee-shareholders without disclosing material information—including ongoing negotiations for an acquisition by GlaxoSmithKline—which would have significantly increased the stock’s value. The employees sold their shares at undervalued prices based on misleading information, prompting the SEC’s action.
This is the UK financial services regulator
What is the Financial Conduct Authority (FCA)
Kimmeridge Energy Management Ltd. is authorized with the FCA as a MiFid Adviser and Arranger firm
These types of accounts are excluded from pre-clearance requirements, but are still subject to quarterly and annual reporting requirements
What are Managed Accounts, 401(k) and similar retirements accounts, Mutual Fund only accounts and 529 plans
Of the following, this would be considered a conflicting outside business activity for a Kimmeridge employee:
(a) serving on the board of a public company without approval of legal and compliance;
(b) working in a similar capacity at Quantum;
(c) serving on the board of a private company without approval of legal and compliance.
a, b and c
This is currently the only pre-approved AI platform for firm-wide use
What is Microsoft Copilot
A friend shares that they learned in a board meeting about a public company acquisition of a private company and you decide to buy stock in the public company. This is known as what?
What is insider trading
Which of the following is not on the list of 2025 SEC exam priorities?
A) Cybersecurity and operational resiliency
B) Anti-money laundering compliance
C) ESG investing practices
D) Use of artificial intelligence
C) ESG investing practices
A trade approval is valid for this number of days
What is 2 days
These types of outside business activities do NOT require pre-approval from Legal/Compliance
What is service on cooperative apartment or condominium boards or not for profit or other charitable boards or organizations
Preclearance approval is required for: activities or employment for compensation or without compensation, or other work for a non- Kimmeridge organization or entity and serving as an officer or director or partner or member of another company or entity
**DAILY DOUBLE**
Hypothetical: Rick, an employee of Kimmeridge, has received approval from Legal/Compliance and IT to use ChatGPT. He is working on calculating the recyclable capital in Fund V and decides to ask ChatGPT for help in understanding the LPA. He copies the relevant Fund V LPA provisions into ChatGPT and asks for help interpreting. Is this a violation of the AI policy?
Yes. Even though Rick had approval to use ChatGPT, he still must abide by the AI policy, which states, "If the AI Request is approved, unless explicitly stated otherwise in the approval, Kimmeridge employees may not use any Kimmeridge information, confidential or otherwise, as “input”.
These are the three prongs of MNPI
1. Materiality: Would a reasonable investor likely consider the information important in their investment decision?
2. Non-public: Has the information been broadly communicated to the investing public?
3. Breach of Duty: May include duties owed by corporate or temporary insiders, duties imposed by law or due to a confidentiality agreement, a verbal or implied agreement to keep information confidential, etc.
These are the authorized signatories for KEMC and KOPs
Who is - Partners, Tamar, NDC, Brittany
These securities are on the Firm's restricted list
What are: (1) the securities that comprise the XOP Index, (2) top E&P companies (domestic & international), and (3) any securities for which the Firm has, or may have, MNPI or a contractual obligation not to trade
This U.S. state has particularly strict requirements governing lobbying activities and a broad definition of what constitutes lobbying activities.
What is California
Broad Definition of Lobbying: California defines lobbying to include not just direct communication with lawmakers, but also attempts to influence state administrative actions, regulations, or procurement decisions.
Extensive disclosure requirements, mandatory ethics training and gift and contribution limits.
These are the types of communications that must be done using approved communication methods
What are substantive business communications
**DAILY DOUBLE**
Hypothetical: A Kimmeridge employee learns that Company A (a portfolio company) is going to acquire Company B. Instead of trading on 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
SEC v. Panuwat: In August 2016, Panuwat received an email from Medivation’s CEO informing him that Pfizer was planning to acquire Medivation. Within minutes, Panuwat purchased 578 call options in Incyte Corporation, a competitor in the oncology sector. When the acquisition was publicly announced four days later, Incyte’s stock price rose by approximately 8%, resulting in a profit of over $120,000 for Panuwat.
This person is the current acting chair of the SEC
Who is Mark Uyeda