Commonfund Group operates under a set of Core Corporate Policies that govern personal conduct of its Trustees, officers, employees and agents. These Policies are supplemented a comprehensive set of policies and procedures such as, for example only, asset valuation, broker monitoring, record keeping, use of social media, and so on, that govern Group operations. The Core Policies include:
Code of Ethics
Commonfund group has adopted a Code of Ethics that applies to its Trustees, officers and employees. It requires that they put the financial interests of clients ahead of their own, in addition to requiring they adhere faithfully to all applicable law and regulation. Please click here for a copy of the Code of Ethics*.
Conflict of Interest Policy
This policy covers all employees, Trustees, officers, and directors of subsidiaries, and broadly prohibits entering relationships or transactions with service providers to Commonfund Group without prior permission of the appropriate supervisor or body. It further directs all covered persons to avoid any relationships or transactions that cause conflicts, or the appearance thereof, with the best interests of Commonfund Group or its investment programs. Please click here for a copy of the policy.
Personal Securities Trade Policy
This policy prohibits insider trading and establishes a procedure for pre-clearance of personal securities transactions.
Whistle Blower policy
Commonfund Group maintains a “whistleblower” policy with respect to any discovery of inaccuracies or improprieties in its financial statements or other accounting information. Employees are required to bring such information to the attention of their supervisors, and to “report up” if the information is not acted on; they are protected from retaliation for so doing; and they are provided with the alternative of reporting such information anonymously to the Chair of the Board’s Audit and Risk Management Committee. Whistleblower procedures protections also apply to reports of violations of other Commonfund Group ethical policies. Please click here for a copy of the policy.
Gift and Entertainment Policy
Covered persons, including Trustees when acting for the Group, may not give or accept any gifts other than nominal or personal gifts, without prior permission from the Compliance Department. The policy also imposes appropriate limits on business entertainment. Please click here for a copy of the Gift and Entertainment Policy.
The Compensation Committee is responsible for determining the compensation of and reviewing the performance of the President and Chief Executive Officer. The Committee also reviews the compensation of other members of senior management, as well as the compensation systems and philosophy of the organization as a whole. It is the practice of the Compensation Committee to engage independent compensation consultants from time to time to assist it in its compensation-related duties, and in addition, to meet regularly in executive session outside the presence of the President and other members of management.
The Audit and Risk Management Committee maintains a policy on non-audit engagements of the organization’s independent accountants. Other than engagements for tax services (consisting of preparation of tax returns and assistance with tax audits), or general consulting on operational, accounting, compliance or tax planning matters (provided that the total billing for such general consulting does not exceed more than 10 percent of Commonfund Group’s total billing for audit services in any given year), all non-audit engagements require the prior permission of the Audit and Risk Management Committee.
*This version of the Code of Ethics integrates and amends a Commonfund Group Code of Ethics dated March 2005 and a Code of Ethics applicable only to the Advisers dated January 1, 2005.