Compass Advisors, LLC (the “Firm”) is committed to conducting our business with the highest level of ethical standards consistent with our fiduciary duties to our clients. In keeping with this commitment, we have adopted a Code of Ethics to define the standards of ethical conduct expected of personnel of the Firm and to which we hold such personnel accountable.
Our Firm recognizes that we have a duty to exercise our authority and responsibility first and foremost for the benefit of our clients. As such, we have placed on our personnel an affirmative duty of utmost good faith to act solely in the best interests of our clients. Our Code of Ethics prohibits outright any fraudulent, deceptive or manipulative conduct by our personnel.
While our Firm seeks to conduct business in a manner that minimizes conflicts of interest, we also recognize that such conflicts will arise from time to time and, in many cases, are unavoidable. We are committed to full and accurate disclosure of all such conflicts of interest. We disclose such conflicts in our Form ADV Part II, which is provided to potential clients prior to entering into any relationship with our Firm. We also disclose such conflicts in our investment advisory services agreement, should potential clients decide to retain our services.
Our Firm is committed to protecting the privacy of client information. In this regard, we maintain a Privacy Policy and have adopted procedures designed to ensure the confidentiality of personal and identifying information regarding our clients. Our Privacy Policy can be located elsewhere on this site.
As an investment adviser, we recognize the need to ensure that our personnel are fair and ethical in respect of their own personal trading decisions and are not competing with, diverting away, or exploiting unfairly investment opportunities available to our clients. In addition, we take very seriously our obligation to ensure that our personnel do not unfairly, unethically or illegally take advantage of our unique access to information on the markets and opportunities in which we invest. We have thus established policies and procedures designed to ensure the Firm is apprised of, and can effectively monitor, the personal trading decisions of our personnel for inappropriate trading activity.
Our Firm is proud of our reputation in the industry and our commitment to deliver superior services to our clients. Our Code of Ethics has been designed to ensure that all of our personnel are similarly committed and exhibit the highest level of integrity in carrying out their responsibilities.
A complete copy of our Code of Ethics may be obtained at any time, at no cost to you, upon written request to Compass Advisors, LLC, Attn: Compliance Department, 1125 NW Couch Street, Eighth Floor, Portland, Oregon 97209.