Recommend practices and procedures designed to prevent violations of the Asset Manager Code addresses loyalty to clients. Loyalty to clients deal with always putting the client’s interests before your own, maintaining the confidentiality of client information, and not engaging in any business relationship or accepting gifts from others that could affect your judgment and objectivity. The code requires a determination of what constitutes a token gift and allowing only token gifts from outside business. This is to limit the influence of these individuals over the asset manager. Cash should never be accepted, employees should always notify their supervisor in writing when they accept any gifts. Litman made no reference to prohibiting cash, and the conversation implies that Litman had not been getting reports of gifts in writing |
