Compliance and Monitoring
Code of Ethics
McLean Budden’s policy begins with the CFA Institute’s Code of Conduct. All clients are treated equally and all client trades precede any activity by employees of the firm.
Conflict of Interest
A compliance program is in place and a code of ethics is maintained with respect to the investment activities of employees and monitoring for conflicts of interest. All employees must submit their personal portfolio transaction statements and those of their spouses to McLean Budden’s Compliance Officer who compares them to the firm’s trading activity over the same period. Any apparent conflicts are investigated.
In addition, participation in new issues or private placements is prohibited. Prior to selling a security, a McLean Budden employee must receive approval from the relevant equity team as well as the trader to ensure we are not planning any transactions in the security. Employees must wait until all client trades are completed. McLean Budden employees are prohibited from purchasing securities.
Formulation of the Investment Policy
For each new account McLean Budden agrees upon a long-term policy asset mix with the client, which establishes a benchmark portfolio of indices against which McLean Budden will be measured. The policy statement is reviewed by the primary Portfolio Manager annually to ensure that it continues to reflect the client’s priorities and the market environment. A client must submit in writing any requests for changes to their portfolio benchmarks.
Twice a month various select partners, the Compliance Officer and the President (CEO) review the benchmark report prepared for all institutional clients. Variances from client benchmarks are compared to policy and any necessary adjustments are made. The Portfolio Manager and the back-up Portfolio Manager confirm that client specific guidelines have been followed in each client quarterly report.
Procedures for Transfer of the Investment Functions to the Firm
McLean Budden has a great deal of experience in setting up portfolios. The portfolio managers have primary responsibility for implementing portfolio structure and monitoring compliance with each client’s investment policy within thirty days of our management commencement.
Audit
Independent internal and/or external audits are conducted to review and test key internal control procedures. Audits are conducted annually by Deloitte & Touche and include a review of our internal controls as well as our pooled fund products.
Registration
McLean Budden is registered as Portfolio Manager, Mutual Fund Dealer and Exempt Market Dealer in all provinces and territories in Canada. We are also registered with the Securities and Exchange Commission (SEC) as an Investment Advisor.
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Contact Us
For all general inquiries, please contact us any time at
+1 416 862 9800
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