A FUTURUM CAPITAL ASSET MANAGEMENT LTD. (“Futurum”) recognizes the importance of its partners, directors, employees, collaborators, managers, and individuals connected to them (“Members”) in managing and developing their own financial resources and the financial resources of their dependents through investment and short- and long-term strategies.
However, due to potential conflicts of interest inherent in our business and our sector, Futurum has implemented standards and limitations designed to minimize these conflicts and help ensure our focus on fulfilling our duties as fiduciary agents for our clients.
In general, the purchase and sale of securities by Members, for their own interest, is permitted provided that it does not constitute: (i) use of material non-public information; (ii) conflict of interest; or (iii) negative interference with the performance of professional activities.
Futurum encourages personal investments in managed collective vehicles, such as investment funds.
Futurum believes in the importance of Members aligning their own personal interests with the interests of our clients. Consequently, Members are encouraged to invest in products recommended by Futurum, if available and when appropriate.
In addition to those listed in Futurum's other policies, below are the main requirements and restrictions applicable to personal trading by Members, their immediate family members, and other financial dependents: (i) The Member must hold the securities for a minimum period of 14 calendar days from the purchase, and may only sell them after the 15th day; and (ii) The Compliance Department of Futurum has the authority to deny any personal trading by a Member if the security is part of or being considered for purchase or sale in any of the funds under its management.
The Compliance Department of Futurum, in cases where it believes there is founded suspicion of conduct in dissonance with what is provided in this Policy, must submit them for administration review, so that appropriate measures can be taken.
Investments made for the benefit of the Member in the financial market must be guided in a way that does not negatively interfere with the performance of professional activities. Furthermore, such investments must be completely segregated from operations conducted on behalf of Futurum, so as to avoid situations that may constitute conflicts of interest. The Member may not, in any way, take advantage of information obtained as a result of their role as a professional with Futurum to gain economic and/or financial benefits from investing or divesting in financial assets.
Members are also prohibited from encouraging unauthorized third parties to acquire them, for their own benefit or that of third parties, taking advantage of insider information obtained due to their relationship with Futurum.
Whenever a potential conflict of interest situation is detected, Members of Futurum are obligated not to carry out the operation or to divest their personal investment position. In this case, they must immediately notify in writing the Compliance Department.
Members must inform the Compliance Department if they obtain any material non-public information related to one or more financial assets. In this case, the Compliance Director will assess the necessity of classifying such financial assets, as well as their issuers, as restricted. Material non-public information is any information that, if made public, may impact the market price of financial assets.
Members are prohibited from conducting business in the capital market related to any financial asset classified as restricted, which will be defined by the Compliance Department and will be available for consultation by Members.
Members declare that they are aware of and agree to submit, when requested, to the Compliance Department a report declaring their personal investments in stocks, real estate funds, debentures, and other securities classified as restricted, in order to verify compliance with the premises established in this Policy.
Futurum Management will not actively manage its own resources, and its cash will be exclusively allocated for payment of expenses and distribution of profits to partners and will be invested exclusively in public securities, daily liquidity third-party DI investment funds, and first-rate Bank CDBs.
This Policy, as well as other applicable provisions from other codes and policies of Futurum, especially the sections of the Code of Ethics regarding Conflicts of Interest and Insider Information, must be observed by all Members.
Any questions or additional clarification in interpreting or applying the obligations and guidelines contained herein should be directed to the Compliance Department.
This securities trading Policy will be reviewed annually, or whenever necessary, by the Compliance Department of Futurum, whenever possible in conjunction with the portfolio manager of securities, in order to remain updated in line with legislation and best management practices.
