Compliance officer manual

word “personnel” when used in this Manual includes all JASA (and affiliates) employees, trustees, vendors, interns, consultants and volunteers, unless the context clearly means otherwise. Whether or not specifically stated in this Manual, the Compliance Officer and all other. Executive Officer in charge: Legal and Compliance Officer Description of the Manual: This is a Compliance Regulatory Manual pursuant to CVM Instruction / It contains the rules and procedures concerning the Policy on Personal Investments, the Compliance, Internal Controls and Conformity Policy set forth in CVM Instruction /15, the. Chief Compliance Officer (CCO)- Pursuant to Rule (4)-7 of the Investment Advisers Act of , the individual responsible for administering the investment adviser’s policies and procedures. This individual must be a supervised person who is competent and knowledgeable regarding the Investment Advisers Act of and who is empowered.

developing, operating and monitoring Sprenger's compliance program. The Compliance Officer and his/her committee report directly to 's governing bodySprenger on compliance matters. Questions regarding the application of this Compliance Manual may be directed to the Compliance Officer. presentations related to compliance issues, please contact 's Chief Audit Compliance HonorHealth Officer. Please submit all suggestions for modifications or updates of this Manual to the Audit Chief Compliance Officer. procedures for the investment adviser. Thus, the compliance officer should have a position of sufficient seniority and authority within the organization to compel others to adhere to the compliance policies and procedures. Client- Pursuant to Rule (b)(3)-1 under the Investment Advisers Act of

Where the Compliance Manual is materially amended the CCO shall deliver the amended Compliance Manual, in whole or in part, to all Company personnel indicating what section or sections have been amended. The CCO shall record the date and time that the amended Compliance Manual, or revised section, was delivered to each person. Each person in receipt of the revised Compliance Manual may be required to acknowledge receipt of. Executive Officer in charge: Legal and Compliance Officer Description of the Manual: This is a Compliance Regulatory Manual pursuant to CVM Instruction / It contains the rules and procedures concerning the Policy on Personal Investments, the Compliance, Internal Controls and Conformity Policy set forth in CVM Instruction /15, the. This Ethics Compliance Program Manual (“Manual”) sets forth the means by which the HonorHealth Code of Conduct and related policies are implemented and monitored. HonorHealth has entrusted its management personnel with the responsibility achieving compliance for.