The Code of Ethics Team is part of the Legal/Compliance and Fund Administration team in Los Angeles. The team administers the Code of Ethics which include the following policies: Gifts and Entertainment Policy, Personal Investing Policy, and Political Contributions Policy. While all of these Policies are under the Code of Ethics, the majority of the team's tasks are related to the Personal Investing Policy.
The Ethics Compliance Specialist handles personal and confidential information for associates, including personal investment information, political contributions and outside business interests/affiliations. Updates and maintains the Personal Trading Assistant (PTA) system with account, holdings and transaction information of global associates who are covered by Capital’s Personal Investing Policy (covered associates). Processes pre-clear requests for covered associates utilizing multiple internal trading and investment systems as well as knowledge of internal controls. Reviews disclosures to ensure covered associates conform to Capital’s Code of Ethics Policy.
• Updates the PTA system with financial transactions of global covered associates.
o Enters personal financial information into PTA. Follows up with covered associates and appropriate site contacts regarding missing documentation or discrepancies.
• Reviews global covered associates’ disclosures of securities accounts and transactions.
o Reviews covered associates’ accounts, holdings and trade information and validates against information on file received from brokerage firms.
o Investigates discrepancies and takes necessary steps to ensure information is accurate.
• Processes pre-clear requests for global covered associates to buy or sell securities.
o Verifies the coverage level of the associate making the pre-clear request (covered associate, investment professional or money manager level of coverage).
o Analyzes pre-clear buy and sell requests and determines which internal trading and investment systems to review in order to determine if the pre-clear request can be approved.
o Makes decisions on routine pre-clear requests. Escalates matters of greater complexity and significance as necessary to more senior associates.
• May specialize in one or more functions within the Code of Ethics department’s realm of responsibilities.
• May participate in departmental projects.
• May participate in the training of other associates.
• Demonstrates sound judgment in resolving matters of moderate complexity.
• Demonstrates effective written and oral communication skills with a diverse group of associates and senior business leaders.
• Demonstrates ability to prioritize assigned work and complete in a timely manner.
• Demonstrates ability to collaborate and develop/maintain relationships within Capital.
• Maintains in-depth knowledge of confidentiality and privacy expectations and controls.
• Demonstrates initiative by identifying issues and recommending solutions.
• Demonstrates in-depth knowledge of Capital’s Code of Ethics Policy and various department procedures. Exhibits knowledge in current and possible future policies, practices, trends, technology and information affecting the department/business area.
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