Compliance disclosure
Code of Ethics
Required by Rule 204A-1 under the Investment Advisers Act of 1940. Governs personal trading, conflicts of interest, insider trading prevention, and reporting.
Placeholder. Final Code of Ethics drafted by RIA legal counsel during registration. Outline below is the standard structure.
Section 1 — Standards of Conduct
Every employee of Vega Wealth owes a fiduciary duty to clients. Employees must place client interests ahead of their own, act with integrity and honesty, and comply with applicable federal securities laws.
Section 2 — Personal Trading
Employees must report initial and annual holdings, plus quarterly transactions, in covered securities. Pre-clearance is required for IPOs, private placements, and limited offerings. Front-running of client trades is prohibited.
Section 3 — Insider Trading
Material non-public information may not be used for personal or client benefit. Employees who become aware of MNPI must report to the CCO immediately.
Section 4 — Gifts and Entertainment
Employees may not accept gifts or entertainment from any person or entity doing business with Vega Wealth above a de-minimis threshold ($100/year/source).
Section 5 — Political Contributions
Pre-clearance required for contributions to government officials of any jurisdiction where Vega Wealth manages or solicits assets (Rule 206(4)-5).
Section 6 — Reporting Violations
Suspected violations must be reported to the Chief Compliance Officer. Retaliation against good-faith reporters is prohibited.
Section 7 — Acknowledgement
Employees acknowledge receipt of, and agree to abide by, this Code of Ethics annually.