Planify’s business activities are subject to extensive governmental regulation and oversight and it is critical that Planify and its employees comply with applicable laws, rules, and regulations, including those relating to insider trading. 

Conflicts of interest may arise when a person’s private interest interferes, or appears to interfere, with the interests of Planify, or where the interests of an employee or the firm are inconsistent with those of a client or potential client, resulting in the risk of damage to the interests of Planify or one or more of its clients. A conflict may arise, for example, if an employee takes an action or has an interest that could appear to make it difficult for the employee to conduct the employee’s responsibilities to Planify and/or the client objectively and effectively, or if such employee or any person associated with the employee, including but not limited to members of the employee’s family or household, receives an improper personal benefit, such as money or a loan, as a result of the individual’s position at Planify . Planify has adopted policies, procedures, and controls designed to manage conflicts of interest. Employees are required to comply with these and other compliance-related policies, procedures, and controls and to help mitigate potential conflicts of interest by adhering to the following standard of conduct:

• Act solely in the best interests of clients;

• Uphold Planify’s high ethical and professional standards;

• Identify, report, and manage actual, apparent, or potential conflicts of interest; and

• Make full and fair disclosure of any conflicts of interests, as may be required.

Conflicts of interest may not always be clear-cut and it is not possible to describe every situation in which a conflict of interest may arise – any question with respect to whether a conflict of interest exists, together with any actual or potential conflict of interest, should be directed to managers and L&C.

Employees must act in the best interests of our clients and consider the reputation of Planify when receiving or providing any gift or entertainment. Employees are prohibited from offering, promising, giving or receiving, or authorizing others to offer, promise, give or receive anything of value, either directly or indirectly, to any party in order to improperly obtain or retain business, or to otherwise gain an improper business advantage.

In addition, strict laws (including criminal laws) govern the provision of gifts and entertainment, including meals,transportation, and lodging, to public officials. Employees are prohibited from providing gifts or anything of value to public officials or their employees or family members in connection with Planify’s business for the purpose of obtaining or retaining business or a business advantage.

Employees and directors:

• are prohibited from taking personal opportunities for themselves that are discovered through the use of corporate property, information, or position without the consent of L&C;

• are prohibited from using corporate property, information, or position for improper personal gain;

• may not compete with Planify either directly or indirectly; and

• owe a duty to Planify to advance its legitimate interests when the opportunity to do so arises.