Code of Ethics of the Advisor

Investment Advisor Code of Ethics

Rule 204A-1 under the Investment Advisers Act of 1940 requires all investment advisors registered with the Securities and Exchange Commission (SEC) to adopt codes of ethics that set forth standards of conduct and require compliance with federal securities laws.

This code of ethics is intended to reflect fiduciary principals that govern the conduct of Seaway Advisors, Ltd, its owners, and its employees (Associates). It consists of policies regarding several key areas: standards of conduct and compliance with laws, rules and regulations, protection of material non-public information, and personal securities trading.

As one of the owners of Seaway Advisors is a member of the NYSSCPA and the CFA Institute, Seaway Advisors will adhere to the Code of Ethics of the NYSSCPA and the CFA Institute (Standards of Professional Conduct) as long as the owner remains a member of the organization in good standing. A copy of the Code of Ethics and the CFA Institute Code of Ethics and Standards of Professional Conduct will be furnished to clients or prospective clients upon request.

Standard of Conduct and Compliance with Laws, Rules, and Regulations

Seaway Advisors expects its owners and employees to comply with all laws, rules, and regulations applicable to its operations and business. All Associates are responsible for reviewing this Code and the company policies that are part of this Code, and for acting in compliance with these policies.  All Associates should understand that their behavior and activity reflects upon Seaway Advisors and all Associates are responsible for protecting the firm’s reputation.

Protection of Material Non Public or Confidential Information

All Associates should exercise care in maintaining the confidentiality of any confidential information regarding Seaway Advisors or its clients, except when disclosure is authorized or mandated by law. Confidential information includes non-public information of Seaway Advisors that may be helpful to competitors, or otherwise harmful to Seaway Advisors, or its clients. Confidential information also refers to the portfolio holdings of Seaway Advisors and its clients.

Personal Trading Procedures

All Associates must be familiar with and abide by all Seaway Advisors trading policies and procedures. Rule 204A-1 of the Investment Advisors Act requires that all Associates of an investment advisor registered with the SEC to report, and the investment advisor to review, their personal securities transactions and holdings periodically.

Associates have investment accounts that will be managed in the same manner as other clients with similar investment objectives. Associates will neither buy nor sell securities in these accounts as part of a trading program until clients with similar objectives have made the relevant purchase or sale. In other words, Associates will not “front run” trading ahead of clients.

For all other transactions (those not part of a firm wide trading program),  Associates will first obtain the permission of  the Chief Compliance Officer, who will make reasonable inquiry as to the trading or proposed trading. Seaway Advisors will maintain records of the approval of, and rationale supporting, the transaction. This policy extends to members of the Associate’s immediate family.

Quarterly Transaction Reports – A quarterly transactions report is kept of all personal security transactions, including those of family members.

Conflicting Trades – No Associate shall purchase or sell a security in which a client has made the opposite transaction within the prior 5 trading days.

Disclosure – No Associate shall recommend or disclose a prospective securities transaction to anyone, including clients. Disclosure to clients may only be made subsequent to the transaction unless such discussion is warranted to clear up any issues relating to restrictions set forth in the Investment Management Agreement.

Principal Transactions - Neither Seaway Advisors nor any Associate may effect a transaction as principal with a client.

Education and Reporting Violations

All owners and Associates will be provided a copy of the Code of Ethics. All Associates are required to promptly report any actual or suspected violations of the Code to the Chief Compliance Officer.


The Investment Advisers Act requires advisors to keep copies of all relevant material. Seaway Advisors will maintain the following records as they pertain to the Code of Ehtics:

  1. A copy of this and any other Code adopted during the past 5 years.

  2. A record of any violation of the Code and of any action taken as a result of such violation.

  3. A copy of all Quarterly Transactions Reports submitted within the past 5 years.



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