Who is obligated to report transactions per the Code of Ethics?

The obligation to report transactions per the Code of Ethics primarily falls on access persons who have direct or indirect beneficial ownership of securities. Access persons typically include individuals within a firm who are in a position to influence or have access to nonpublic information related to the firm's investment decisions. Because they may trade on this information or may have transactions that could conflict with their fiduciary responsibilities to clients, they are required to disclose their trading activities to ensure transparency and compliance with ethical standards.

This reporting requirement helps to mitigate potential conflicts of interest and promotes integrity within the investment advisory firm. By holding access persons accountable, the firm can monitor for any unethical activities such as insider trading or self-dealing. As a consequence, other groups, such as senior management or all staff members, do not share the same reporting obligations unless they also qualify as access persons. External auditors and consultants are not typically subject to the same Code of Ethics reporting requirements, as they operate under different guidelines and agreements.