CFA Chicago Conflict of Interest Policy

Drafted October 2006

The Board has adopted this policy to provide guiding principles to Society Directors and Officers for the identification and resolution of conflicts of interest. This policy does not attempt to describe all possible conflicts of interest that may develop or how those conflicts are to be handled. Society Directors and Officers are expected to use sound judgment and good faith in identifying actual and potential conflicts of interest with the objective of disclosing any position or activity that may give rise to a conflict. Society Directors and Officers shall follow both the letter and the spirit of this policy.

General Statement on Conflicts

Society Directors and Officers must avoid to the extent possible conflicts of interest between themselves and CFA Society Chicago. Not all conflicts or the appearance of conflicts can be avoided. A conflict of interest can occur when a Society Director and Officer's private interest interferes in some way, or may appear to interfere, with the interest of CFA Society Chicago. Conflicts may also arise when a Society Director and Officer takes action or has interests that may make it difficult to serve as a Society Director and Officer objectively and effectively or receives improper benefit as a Society Director and Officer of CFA Society Chicago. Conflicts may arise indirectly, where for example, a Society Director and Officer holds a material position in another organization that is affected by the Society Director and Officer's action as a member of the Board of CFA Society Chicago.

This Code provides guidance for the disclosure of more common conflicts to which Society Directors and Officers may be subject, provides for disclosure of other interests held by a Society Director and Officer and for annual reporting of conflicts.

Gifts and Entertainment

No Society Director and Officer shall solicit for their or their family's personal benefit any gift from any organization or person on account of their position as a Society Director and Officer of CFA Society Chicago. Society Directors and Officers and members of the family of Society Directors and Officers may not accept gifts from persons or entities who deal with CFA Society Chicago where the gift has more than a nominal value (and may never accept cash) or where the receipt of the gift may create the appearance of a conflict. In some countries, gift giving and receipt is an accepted business custom and the refusal of a gift may not be in the best interests of CFA Society Chicago. In such circumstances, the Society Director and Officer may accept the gift, disclose the receipt and turn the gift over to the custody of CFA Society Chicago.

No Society Director and Officer shall solicit for their or their family's personal benefit any entertainment from any organization or person on account of their position as a Society Director and Officer of CFA Society Chicago. The receipt of entertainment in the presence of others with whom CFA Society Chicago has business, professional and investment industry relationships is permissible so long as it does not create the appearance of an obligation of the Society Director and Officer to the person or organization providing the entertainment. In this context, the receipt of lavish or extravagant entertainment, or entertainment provided in the absence of the persons financing the entertainment, is discouraged and should be disclosed to CFA Society Chicago.

Nonpublic Information

Any nonpublic investment information that a Society Director and Officer may learn on account of the Society Director and Officer's position on the Board or at any meeting held by or for CFA Society Chicago shall be treated confidentially and the Society Director and Officer shall deal with the information consistent with law and the CFA Institute Code of Ethics and Standards of Professional Conduct.

Corporate Opportunities

Society Directors and Officers may not take for themselves business or other opportunities relating to the business of CFA Society Chicago, use the property or information of CFA Society Chicago for personal gain or compete with CFA Society Chicago for business opportunities, without the express approval of the Society Directors and Officers who are disinterested in the transaction.

Handling of Conflicts

Not all conflicts may be avoided in advance by Society Directors and Officers, and conflicts may arise or be discovered in the course of the Society Director and Officer's work on the Board. Each Society Director and Officer is expected, upon learning of a conflict, to disclose the conflict to the Chairman of CFA Society Chicago and to its Secretary. In cases of doubt, a Society Director and Officer should err in favor of disclosure.

Upon disclosure the Chairman shall, in consultation with the Board and the Secretary, determine the proper handling of the conflict. The conflict may be handled by the making of a full disclosure to the Board, recusal of the Society Director and Officer from discussion of the matter, recusal of the Society Director and Officer from voting on the matter, absence of the Society Director and Officer from the meeting discussing the matter or such other means or combination of means as shall be determined by those Society Directors and Officers not subject to the conflict.

Reporting of Interests and Conflicts

Each Society Director and Officer shall provide an annual statement to CFA Society Chicago attesting to any conflict of interest identified by the Society Director and Officer or the absence of any conflict of interest to the best of knowledge of the Society Director and Officer.

Each Society Director and Officer shall provide CFA Society Chicago, at such time as may be requested, a statement of:

(i) each organization for which the Society Director and Officer is a director or executive (or holds an equivalent position) or by which the Society Director and Officer is employed, and

(ii) each investment, interest, volunteer activity, membership or other matter that may conflict or interfere with the Society Director and Officer's position on the Board or that may cause a conflict of interest between the Society Director and Officer's duty to CFA Society Chicago and the investment, interest, activity, membership or matter.

In making such statements to CFA Society Chicago a Society Director and Officer shall report in good faith and consistent with the letter and spirit of this policy. The reporting of a conflict under this provision is in addition to, and not in lieu of, the Society Director and Officer's obligation to report the conflict when taking action as a member of the Board.