Code of Ethics
Advertising and Marketing
Safeguarding client information
Trading
Miscellaneous
100
The duty that requires ZWJ to act in the best interest of its clients
What is Fiduciary Duty?
100
Websites such as LinkedIn, Twitter and Facebook
What is social media?
100
Where ZWJ's confidential client papers are discarded
What is the locked grey bin in the mechanical elevator room?
100
List of stocks that require pre-approval for purchase in personal trading accounts
What is the ZWJ Active List?
100
The process of disguising illegally obtained money so that it appears to be from legitimate sources or activities
What is money laundering?
200
Required by the SEC, this standard of conduct discloses conflicts of interest and reaffirms our fiduciary duty
What is the Code of Ethics?
200
Selecting the best performance information to provide to a prospect
What is cherry picking?
200
Social security numbers, tax identification numbers, account numbers, account balances, income, securities positions
What is non-public information?
200
Money paid by Schwab, based on our trade commissions, for research that benefits all ZWJ clients
What are soft dollars?
200
A regulatory body that establishes laws and rules and monitors the activities and compliance programs of registered Investment Advisors
What is the Securities and Exchange Commission (SEC)?
300
Putting your own interest first…helping yourself more than helping the client
What is conflict of interest?
300
Compliance document provided to all prospects with our brochure, updated with the SEC annually, and also offered to existing clients annually
What is our ADV?
300
We must maintain client records (as well as company records and marketing presentations) for this period of time, in either electronic or hard copy form
What is five years?
300
The requirement that an investment adviser execute securities transactions for clients in such a manner that the client's total cost or proceeds in each transaction is most favorable under the circumstances
What is best execution?
300
The residence of Brad Young, 2589 Brookwood Drive, Atlanta Georgia 30305
What is the ZWJ Disaster Recovery Site?
400
Must provide to Robin within 30 days of each quarter end
What is a quarterly personal transaction report?
400
Notice, circular, letter or other written communication addressed to more than one person that provides an analysis, report or publication concerning securities or any other investment advisory service
What are marketing materials?
400
ZWJ's statement to prospective and current clients regarding confidentiality
What is ZWJ's Privacy Policy?
400
Information that a reasonable investor would consider important in making investment decisions, such that disclosure would have an effect on the price of a company's securities
What is material information?
400
When an investment adviser holds, or has the authority to obtain, client funds or securities
What is custody?
500
Our Code of Ethics is found in this larger compliance document which is electronically filed in the public drive for all employees to access
What is the Compliance Manual?
500
Prohibited recommendations on social media sites, such as Linked In, Twitter or Facebook
What are testimonials?
500
So that we can provide confidential client information to a third party such as Chicago Clearing Corporation, a client must be offered this form with the option NOT TO participate
What is an opt-out form?
500
Acting on company information that is not known to the public, when the information could be beneficial to know before buying or selling that company's stock or being on the board of a company and having information about various business practices
What is insider trading?
500
$350 or less per election in which are you entitled to vote, and $150 or less per election in which you are not entitled to vote
What are the pre-clearance limits for political contributions?
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