The ICON Companies provides investment advisory services to various clients and accounts (collectively the “Managed Accounts”), some of which are investment companies registered under the Investment Company Act of 1940 (the “Company Act”). Persons designated as Access Persons of ICON Companies, who have access to information about the investment activities of the Managed Accounts, owe a duty of loyalty to such Managed Accounts, and must therefore adhere to the highest ethical and professional standards of conduct. It is the objective of all persons subject to the ICON Companies’ Code of Conduct (“Code”) to maintain the highest standards of integrity and conduct in order to meet their respective duties and obligations to the ICON Companies and the Managed Accounts. Furthermore, all persons subject to the ICON Companies’ code are required to comply with all applicable securities laws. These standards, as contained in the Code, are based on the requirements of the Company Act, the Investment Advisers Act of 1940 (the “Advisers Act”), the Insider Trading and Securities Fraud Enforcement Act (“ITSFEA”), and the laws governing the management of investment accounts.
The ICON Companies will provide a copy of its Code to any client or prospective client upon request.
Written requests should be sent to ICON Advisers c/o the Chief Compliance Officer, 5299 DTC Blvd., Ste. 1200, Greenwood Village, CO 80111.