Raison AM (Leagal Entity - Threesixty Elements S.A.) is an US SEC Registered Investment Adviser. We are required to adopt a code of ethics. Our code of ethics set forth the standards of business conduct expected of our “supervised persons”. You can always read our Standards of Professional Conduct on our web-site or ask you contact person for the newest version of the mentioned document to be sent to you.

Fiduciary Duties

We have a fundamental obligation to always act in the best interests of our clients. We owe our clients a duty of undivided loyalty and utmost good faith. We disclose any activity that may present a conflict of interest with any client and we take steps reasonably necessary to fulfill our obligations. We provide full and fair disclosure of all material facts to our clients and prospective clients. Facts are “material” if a reasonable investor would consider them to be important in making an investment decision.

Transparency and Client Disclosure

The principle of our Company is "Full business transparency". We are open for the market and responsible for the accuracy, reliability and timeliness of the information provided. We always provide our advisory clients and prospective clients with a written disclosure documents. As an US SEC RIA, we comply with this requirement by completing Part 2 of Form ADV, which requires to provide information about a variety of topics relating to our business practices. Also you can find additional info about the Funds on Bloomberg OpenFIGI and Bloomberg professional services.

Responsibility

The employees of Raison AM take full responsibility for every personal and businessact. We are not afraid to take responsibility and do it consciously to maximize the customers' satisfaction.

Effectiveness and Efficiency

We work not for the sake of process but to achieve specific objectives aimed at the development of our company. We try to continually improve our results and to ensure the most efficient use of resources in achieving our goals.

Partnership

The partnership is simple if you know how to work in a team. In the relations with the clients, colleagues, managers and stuff we adhere to the principles of long-term and deep relationships commitment to the objective dialogue respect for and recognition of person`s individuality.

Development

We do not stand still, we always strive for the best, think beyond the ordinary. We aim to constantly develop our relationships with the clients, we care about personal and professional development of our employees. To summarize - Development for us is a hobby which helps to achieve the best results.