IV(A.3) Independence and Objectivity. Members shall use reasonable care and judgment to achieve and maintain independence and objectivity in making investment recommendations or taking investment actions.

　　Compliance:

　　1. Protect integrity of opinions. Reports should reflect the analyst’s unbiased opinion.

　　2. Disclose all corporate relationships (i.e., directorships, underwriting arrangements or acting as a market maker).

　　3. Disclose personal holdings and beneficial ownerships.

　　4. Create a restricted list.

　　5. Restrict special cost arrangements. Members should pay for their commercial transportation and hotel charges.

　　6. Limit gifts (US$100 is the maximum acceptable value for a gift or gratuity).

　　7. Restrict investments (strict limits should be imposed on private placements).

　　8. Review procedures (supervise the personal investment activities of the employees).

　　B.: Interactions with Clients and Prospects

　　IV(B.1) Fiduciary Duties: In relationships with clients, members shall use particular care in determining applicable fiduciary duty and shall comply with such duty as to those persons and interests to whom the duty is owed. Members must act for the benefit of their clients and place their clients' interests before their own.

　　Compliance:

　　1. Follow all applicable rules and laws.

　　2. Establish the investment objectives of the client.

　　3. Diversify.

　　4. Deal fairly with all clients with respect to investment actions.

　　5. Disclose all possible conflicts of interest.

　　6. Disclose compensation arrangements.

　　7. Preserve the confidentiality of client information.

　　8. Maintain loyalty to the plan beneficiaries.

　　IV(B.2) Portfolio Investment Recommendations and Actions: Members shall:

　　a. Make a reasonable inquiry into a client's financial situation, investment experience, and investment objectives prior to making any investment recommendations and shall update this information as necessary, but no less frequently than annually, to allow the members to adjust their investment recommendations to reflect changed circumstances.