Putting Investors First
When you invest in an ICON portfolio, you hire a firm that adheres to the most stringent standards of regulatory compliance, performance reporting, and portfolio review. Read more:
PUTTING INVESTORS FIRST
Putting Investors First
As a firm, there is zero tolerance for any sign of shareholder trading activity that would negatively impact our investors.
Protection from Trading Abuses
Mutual funds, like the ICON Funds, are designed for investors with long time horizons. However, certain investors trade in and out of strategically targeted mutual funds over a short time period in order to take advantage of the way those funds are managed and priced. These investors are ‘market timers’ or ‘short-term investors.’
We strongly discourage market timing and short-term investing in the ICON Funds and have attempted to identify and restrict this type of investing.
ICON staff monitors trading activity daily and has rigorous reporting procedures in place to identify potential market timers and short-term investors. And in an additional step to protect the Funds, ICON employs daily fair valuing of foreign securities traded in countries outside the Western Hemisphere to minimize stale prices and make the foreign Funds less attractive to market timers.
While fair value pricing takes into account any significant events occurring after the close of a foreign market, it cannot eliminate the possibility of market-timing or short-term trading. However, it is our belief that the procedures implemented at ICON help protect the interests of long-term Fund shareholders.
GIPS® COMPLIANCE
ICON Advisers, Inc. (“ICON”) is a registered investment adviser incorporated in 1991. ICON uses a disciplined, objective, non-emotional methodology to identify industries and sectors that our methodology suggests are underpriced relative to our calculation of intrinsic value. ICON utilizes sector and industry rotation to invest in U.S. and foreign securities of any market capitalization. ICON offers its disciplined, objective, non-emotional methodology across a wide range of portfolio solutions, including tactical fund allocation portfolios, diversified and sector mutual funds, as well as diversified and concentrated separate accounts.
ICON claims compliance with the Global Investment Performance Standards (GIPS®). The periods prior to January 1, 1995 have not been verified. To receive a complete list and description of ICON’s composites and/or a presentation that adheres to the GIPS® standards, please call 1-800-828-4881 or visit www.InvestwithICON.com. Additional information regarding ICON’s policies for calculating and reporting returns is available upon request.
This verification illustrates ICON’s commitment to fair representation and full disclosure, as well as consistency and comparability of investment management performance. It also represents our focus on helping investors to make valid performance comparisons.
To receive a list and descriptions of ICON’s active composites and/or a presentation that adheres to the GIPS-PPS, see below.
ICON COMPANIES CODE OF CONDUCT
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, 8480 E Orchard Road, Suite. 1200, Greenwood Village, CO 80111.
Keeping Your Investments Safe and Private
Electronic safety and privacy are on investors’ minds more than ever before. Your peace of mind is as important as the safety of your data. ICON protects the privacy of your investments with defined procedures and policies to ensure that your investments are protected in the event of a business disruption. Read more:
BUSINESS CONTINUITY PLANNING
In order to ensure ongoing operations in the event of a natural or man-made disaster or business interruption, ICON has instituted a comprehensive Business Continuity Plan. This plan is focused on maintaining the integrity, security and privacy of systems and data.
Moreover, the plan ensures the ability to maintain the highest possible level of service to our valued clients. The plan has many aspects, including:
- Protecting mission-critical and client data
- Providing an orderly and swift recovery
- Ensuring regulatory compliance
- Executing fiduciary responsibility
- Ensuring effective decision-making
- Ensuring organizational stability
Disaster Recovery
The ICON Business Continuity Plan incorporates disaster recovery measures that facilitate the restoration of mission-critical systems through the use of off-site and mobile recovery centers in the event of a business disruption.
Upon restoration of these mission-critical systems, ICON will conduct all operations necessary to ensure that client obligations and communications, in addition to regulatory compliance and interaction, are being executed at the highest possible level.
Data Protection
The Business Continuity Plan also incorporates secure off-site data protection, which serves as a key interface in the restoration of mission-critical information. In the event of a disaster, ICON will have immediate access to the company’s most current electronic data, which is backed up on a daily basis and verified as to its accuracy.
PORTFOLIOS PRIVACY POLICY
ICON Advisers, Inc. and the ICON Funds
Notice of Privacy Policies | Effective January 26, 2009
In the course of doing business with ICON Advisers, Inc. ( “ICON”) you provide personal and financial information. ICON respects your privacy. We collect non-public personal information about you on your applications or other forms and through your transactions with us. You may provide this information in writing, electronically, or by phone. The information may contain your name, address, phone number, Social Security number, account information, investment activity, and other information that you provide to us directly or through our service providers. This information permits us to service your accounts and to provide information to you upon request.
We may share some or all of this information with our affiliates, as well as with third parties that assist us in maintaining your accounts, processing transactions on your accounts, or mailing information to you as may be permitted by law. Further, we may permit third party vendors to download this information as needed in order to assist us or your Registered Representative/Financial Adviser in maintaining your account. Otherwise, our policies prohibit employees of ICON from sharing your personal and financial information except as permitted or required by law. Under no circumstances do we sell information about you to anyone.
We restrict access to your non-public personal information to those employees who have a need to know that information to service your accounts. We also maintain physical, electronic and procedural safeguards to protect your privacy. Our service providers are required to restrict access to your non-public personal information, and to maintain physical, electronic and procedural safeguards against unintended disclosure.
If you would like more information about our Privacy Policies, please call 1-800-828-4881.
ICON FUNDS PRIVACY NOTICE
SITE SECURITY
ICON Advisers works hard to protect your account information. Our infrastructure, policies, and procedures secure your data with the latest technology and rigorous standards.
Some ICON personnel, such as account representatives and regulatory compliance officers, as well as a limited number of outside vendors may occasionally have access to your non-public account data. This only happens when absolutely necessary for servicing your account or to maintain our system. Policies guide and control the confidentiality of this process.
Beyond our rigorous security procedures, ICON also applies a strict privacy policy to further protect your information.
Steps You Can Take to Protect Yourself Online
You can help protect your information for all your online activity. Start with these suggestions:
- Choose hard-to-break passwords and change them regularly. Never share your password with anyone. Special characters and a mix of letters and numbers strengthens the security of your password. Avoid obvious choices, such as your birthdate, Social Security number, or address. For further safety, you may also want to use a unique password for your online account.
- Use anti-virus software. You can choose among several easy-to-install packages. These can protect your computer from rogue programs that can capture and send personal information from your computer to another party.
- Use a firewall. Personal firewalls may use software and hardware to guard your computer. These can prevent outsiders from taking over your computer. Firewalls are especially helpful if you have a cable modem or DSL, which tend to make your computer more vulnerable to online hacking.
- Keep your system software up-to-date. Using the latest operating system and current browsers means you are using the Internet with the latest safeguards in place. Download patches whenever necessary to block your system against new hacks and security gaps in your software.
- Clean out your cache or temporary folders. After viewing account information, close out of your browser and delete any temporary files. To configure your browser to automatically (or manually) delete the information stored in these folders, consult the User Manual, FAQ, or Help function of your browser and operating system software.
Terms of Use
By using the website, you are agreeing to accept and be legally bound by the terms in the ICON Terms of Use document; read it to ensure you comply.
TERMS OF USE FOR ICON’S WEBSITE
PLEASE READ THESE TERMS OF USE CAREFULLY; THEY ARE THE TERMS THAT GOVERN YOUR USE OF THE ICONADVISERS.COM / INVESTWITHICON.COM WEBSITE. BY USING THE WEBSITE YOU ARE AGREEING TO ACCEPT AND BE LEGALLY BOUND BY THESE TERMS. IF YOU DO NOT AGREE WITH THE TERMS OF THIS WEBSITE USER AGREEMENT, PLEASE LEAVE THIS WEBSITE IMMEDIATELY.
For purposes of this Agreement, “you” means any person or entity contacting and using iconadvisers.com (or investwithicon.com), any person or entity obtaining a user identification and password for the secure areas of the website, and any other persons or entities authorized to use your online/Internet account. “Content” means any and all information, services, hyperlinks, or other audio, visual, graphic, textual or other form of material or data displayed on the website. You agree to ensure that other parties using your Internet account abide by the terms and conditions of this Agreement and you assume responsibility for any breaches of the Agreement by any such persons or entities.
1. Disclaimer
Some of the Content, including but not limited to financial information and research, market data, tools, services and commentary available on or through this website is provided by or obtained from third parties and is made available by ICON Advisers for general reference and educational purposes only. The availability of the information contained herein does not constitute any financial, investment or tax advice. ICON Advisers does not guarantee the accuracy of the third-party information provided, although it is believed to be reliable. The products and services described on this website are available to U.S. investors only and the information on this website is only for such persons. The information on this website is not an offer to sell or a solicitation of an offer to buy any security, nor shall any such security be offered or sold to any person in any jurisdiction in which such offer, solicitation, purchase or sale may not lawfully be made. Past performance is no guarantee of future results. Share price, yield and investment returns of mutual funds fluctuate such that an investor’s shares may be worth more or less than original cost upon redemption. You acknowledge that any reliance on information obtained through your use of this website, including through any linked sites, is at your sole risk, and that you assume full responsibility for any and all costs associated in any way with use of the website and the materials it contains and any linked sites, and that ICON Advisers, its officers, directors and employees are not liable for damages of any kind, whether or not such damages might have been foreseeable, related to your use of the website, the materials and information it contains, or any linked sites. You agree to indemnify, defend and hold harmless ICON Advisers and all of its employees, agents and representatives, from any claims asserted by a third party arising from your use of this website, except for claims which pertain to ICON Advisers’ ownership of intellectual property rights in the Content.
2. Limitation on Liability
BY ACCESSING THIS WEBSITE OR RECEIVING ANY OF THE SERVICES PROVIDED HEREIN, YOU AGREE TO WAIVE ALL CLAIMS AGAINST ICON ADVISERS AND ALL THIRD PARTY CONTENT PROVIDERS REGARDING THE INFORMATION PROVIDED ON THIS WEBSITE AND ANY INFORMATION RECEIVED BY YOU AS A RESULT OF USING THE SERVICES, AND ANY USE BY YOU OF SUCH INFORMATION. YOU AGREE THAT UNDER NO CIRCUMSTANCES SHALL ICON ADVISERS OR ANY OTHER PARTY INVOLVED IN CREATING, PRODUCING, OR DELIVERING THIS WEBSITE OR ITS CONTENTS OR SERVICES BE LIABLE TO YOU FOR ANY DAMAGES, INCLUDING, BUT NOT LIMITED TO, ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES FOR LOSS OF PROFITS, GOOD WILL, BUSINESS INTERRUPTION, USE, DATA, EQUIPMENT OR OTHER INTANGIBLE LOSSES (EVEN IF ICON ADVISERS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES) THAT RESULT FROM (1) THE USE OF OR INABILITY TO USE THIS SITE OR ANY SERVICES; (2) THE CONSEQUENCES OF ANY DECISION MADE OR ACTION OR NON-ACTION TAKEN BY YOU OR BY ANYONE TO WHOM YOU COMMUNICATE SUCH INFORMATION, OR FOR ANY ERRORS BY YOU IN COMMUNICATING SUCH INFORMATION; (3) THE COST OF SUBSTITUTE GOODS OR SERVICES; OR (4) ANY OTHER MATTER RELATING TO THE CONTENT, SERVICES, OR DISTRIBUTION OF SERVICES THROUGH THIS WEBSITE. ICON ADVISERS SHALL NOT BE LIABLE FOR DAMAGE OR INJURY TO PERSONS OR PROPERTY ARISING FROM ANY USE OF ANY PRODUCT, INFORMATION, PROCEDURE, OR SERVICE OBTAINED THROUGH THIS WEBSITE.
3. Arbitration and Governing Law Provisions
By using ICON’s website, you agree that all claims and disputes of every type and matter which may arise between you and ICON Advisers will be submitted to binding arbitration pursuant to the Commercial Arbitration rules of the American Arbitration Association. Such arbitration proceedings and hearings will take place only in Denver, Colorado. To the extent not preempted by federal law, Colorado statutory law (including without limitation the statutes governing the award of damages in arbitration) and Colorado common law will govern. You expressly waive any right to conduct litigation or arbitration in any other forum. Arbitration is final and binding on all the parties.
4. Acceptable Use
The website may not be used in violation of any community standards, accepted Internet policy, laws or regulations of local, state, foreign or federal governments or agencies thereof, or international treaty. Actions such as, but not limited to, misuse of copyrighted, patented or protected materials, use of the website for defamatory, threatening or obscene purposes, the mass distribution of any message on an intrusive basis to users of the Internet, or denial-of-service or security-related attacks is prohibited.
5. Security/Privacy
The Internet is not a secure network. Confidential or sensitive information should not be transmitted over the Internet, or stored on computers directly connected to the Internet. ICON Advisers does not assume responsibility for loss or theft of information transmitted over the Internet or stored on computers directly connected to the Internet. You further acknowledge that, by using the website, information as to your Internet address, your identity, the details of your activity on the website and other similar information will become available to ICON Advisers and you hereby permit ICON Advisers to collect, store, analyze and use this information in its sole discretion for marketing, promotional, quality control and other purposes related to the Content and to the operation of the website. ICON Advisers will not make such information available to third parties except as provided in ICON Advisers’ privacy policy without your consent.
6. Downtime and Interruptions in Service
ICON Advisers strives to keep the website available on a continuous basis. However, as with all computer systems, periodic upgrades and other service will sometimes be required. In addition, telecommunications links that are necessary to operate the website are maintained by third parties and ICON Advisers has no control over the ability of such external systems to remain in operation without disruption. Therefore, you acknowledge that the website may be occasionally unavailable due to such periodic maintenance or to other unexpected interruptions and that ICON Advisers is not responsible for inaccessibility during such downtimes.
7. Modification and Termination
ICON Advisers may modify the Content of this website at any time without notice. This Agreement and any subsequent amendments or modifications are effective unless and until terminated by ICON Advisers. ICON Advisers may terminate this Agreement at any time without notice to you, and accordingly deny you access to any password-protected areas of the website in our sole discretion if you fail to comply with the provisions of this Agreement.
8. General Provisions
This Agreement sets forth the entire agreement related to the subject matter addressed above. If any provision of this Agreement is invalid or unenforceable, the remainder of the Agreement shall remain in force and the affected provisions shall be deemed modified so as to be enforceable to the maximum extent permitted by law. You may not assign this Agreement to a third party without ICON Advisers’ prior consent. ICON Advisers will not be deemed to have waived any rights herein by electing not to enforce such rights. ICON Advisers will not be responsible for any failure in performance that is due to causes or occurrences beyond its reasonable control.
ICON Advisers, Inc.
8480 E Orchard Road, Suite 1200
Greenwood Village, CO 80111