Part I. Purpose
The purpose of this Code of Conduct and Conflict of Interest Policy ("Code") is to protect the interests of Innovatix, LLC ("Innovatix") as well as the interests of its members, customers, and Participants. This Code reflects and reconfirms the principles of the existing Innovatix policies and adds some new provisions based on recent reports on "best practices" from a number of sources. It is intended to supplement but not replace any applicable Federal, state, and local laws governing conflicts of interest as well as other Innovatix policies and industry Codes of Conduct that have been adopted by Innovatix.
This Code, which applies to all Executive Employees of Innovatix, sets forth the minimum standards required of them by Innovatix. Similar policies also apply to Innovatix’s non-Executive staff. Innovatix, of course, expects each person to whom this Code applies to use his or her best judgment and common sense in addressing all matters regarding conflicts of interest, professional conduct, and ethics. Innovatix will review this Code from time to time and update or amend it as necessary. Additionally, nothing in this Code shall restrict Innovatix from taking appropriate action in any particular situation, even if it is not explicitly referenced in this Code.
Further, this Code may be adopted by relevant subsidiaries and/or affiliates of Innovatix. To the extent so adopted, all references in this Code to Innovatix shall apply to the relevant Innovatix subsidiary or affiliate.
There are a number of capitalized terms defined in this Code. For ease of reference, all such terms are defined at the end of this Code. If you have any questions about this Code, please contact the Compliance Officer.
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