Code of Ethics
The standards of business conduct, personal-trading rules, and fiduciary principles that govern all personnel of the firm.
1. Purpose
The Code of Ethics sets forth the fiduciary standards and rules of conduct expected of all personnel of Alzaro Capital Management, LLC. It is designed to comply with Rule 204A-1 under the Investment Advisers Act of 1940 and to reinforce the firm’s obligation to place the interests of investors ahead of its own.
2. Fiduciary Duty
All personnel owe a fiduciary duty to the funds and their limited partners. This duty requires acting in good faith, with loyalty and care, avoiding conflicts of interest where possible, and disclosing and mitigating conflicts that cannot be avoided.
3. Standards of Conduct
Personnel must act with honesty and integrity, comply with applicable federal securities laws, protect confidential information, and avoid any activity that could reasonably create the appearance of impropriety.
4. Personal Trading
Access persons must pre-clear certain personal securities transactions, hold reportable accounts at approved custodians, and report holdings and transactions on the schedule required by the Advisers Act. Trading in securities on the firm’s restricted list is prohibited.
5. Gifts & Entertainment
Personnel may neither give nor accept gifts or entertainment that could improperly influence business decisions. Gifts and entertainment above de minimis thresholds must be reported and, where required, pre-approved.
6. Outside Business Activities
Personnel must disclose and obtain approval for outside business activities that could present a conflict of interest with the firm or its funds.
7. Insider Trading
The firm prohibits trading on the basis of material non-public information and maintains information barriers and a restricted list to prevent misuse of such information.
8. Reporting & Certification
Personnel certify compliance with the Code at hire and annually. Violations must be reported promptly to the Chief Compliance Officer. Retaliation against good-faith reporters is prohibited.
9. Enforcement
Violations of the Code may result in disciplinary action up to and including termination, disgorgement of profits, and referral to regulatory or law-enforcement authorities.
Notice
This document is a summary of the firm’s internal policy as adopted by the approving body identified above. The complete policy as adopted governs in any case of conflict between this summary and the underlying policy document. Limited partners and other authorized parties may request the full policy from the policy owner. This document does not create contractual rights, employment rights, or third-party beneficiary rights, and may be amended at any time by action of the approving body.
Questions about this policy should be directed to [email protected]. Confidential or anonymous reports may also be made through the channels described in the Whistleblower Policy.
Questions about firm governance
Limited partners, regulators, and counterparties with questions about firm governance, policies, or compliance should contact [email protected].