Strengthening Your Code of Ethics Framework for Investment Advisers
A well-designed Code of Ethics is more than a compliance obligation, it is a reflection of a firm's fiduciary culture, governance standards, and commitment to ethical conduct. This whitepaper explores the SEC's Code of Ethics requirements for investment advisers, common compliance deficiencies, and practical enhancements firms can implement to strengthen oversight, accountability, and risk management.
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2026 CODE OF ETHICS WHITEPAPER
What’s inside:
- An overview of SEC Rule 204A-1 and Code of Ethics requirements for investment advisers.
- The five core provisions every adviser should include in their Code of Ethics.
- Guidance on access person reporting, personal trading reviews, and restricted activities.
- Common compliance deficiencies identified by the SEC and how to address them.
- Practical enhancements that help transform a Code of Ethics from a regulatory requirement into a strategic compliance tool.
Rethinking your Code of Ethics framework?
The most effective compliance programs treat the Code of Ethics as more than a regulatory requirement. Firms that strengthen oversight, reinforce accountability, and promote a culture of compliance are better positioned to manage risk and uphold their fiduciary responsibilities.