【ACIIA】PRINCIPLES of ETHICAL CONDUCT

孙业栋

Association of Certified International Investment Analysts
PRINCIPLES OF ETHICAL CONDUCT
Preamble
In an increasingly global investment environment, the Association of Certified International
Investment Analysts, ACIIA* was founded with the goal of establishing
a base of common standards of technical and ethical knowledge and practices and
of facilitating the exchange of information among investment analysts worldwide.
The philosophy behind the development of the CIIA* education program was that
investment analysts’ activities in various countries and regions are characterized
by differences in culture, practices and regulations which should be recognized and
respected by market participants. The CIIA program also seeks to promote the
implementation and enforcement of high technical and ethical standards, to ensure
the close relationship and mobility of investment analysts across the different
markets.
The ACIIA considers professional competence and ethics as the key pillars underlying
investment analysts’ activities worldwide. The association also places emphasis
on investment analysts’ independence from any external undue pressure which
could impair their objectivity.
The ACIIA’s recognition of the governing role of national/regional associations in
their own countries/regions – irrespective of their size or the development stage of
the local market – is a key factor which differentiates the association from any other
entity in global capital markets. The association’s policy to respect the cultural and
regulatory aspects of each country/region also helps investment analysts better
understand the local factors which could affect an investment decision and thus
limits the risk of such decisions being taken on the basis of wrong or incorrect views
or perceptions. The close relation that the ACIIA promotes among its members,
encourages not only the ongoing exchange of knowledge and experience between
markets of different sizes and stages of development, but also the assimilation of
the technical and ethical practices adopted in various countries/regions, thus
converging towards best practice. The global CIIA program is adopted and implemented
by each of the national/regional member associations of the ACIIA, in
compliance with the common principles laid down by the latter. The global CIIA
education program was developed, and is continuously reviewed, through the
democratic collaboration between national/regional ACIIA member associations,
which represent investment analysts around the world. The CIIA program combines
international common examinations comprising two levels (Foundation and Final)
administered by ACIIA, with a national specific examination, covering national
specific components, administered by each national/regional association.
In this context, the ACIIA has established Principles of Ethical Conduct, which incorporate
globally-accepted best practices. Each national/regional association is
encouraged to adopt the Principles and to use them as a model to develop or improve
their own ethical codes and standards as necessary.
For the purpose of these Principles, ‘Investment analysts’ are individuals who
evaluate or use financial, economic or statistical data as part of the professional
practice of financial analysis, investment management, portfolio management,
securities analysis, investment counselling, or other similar professions.
The ACIIA Principles consist of Fundamental Principles which lay down fundamental
ethical behaviour for investment analysts and Specific Key Principles, which
apply these Fundamental Principles to investment analysts’ activities. Lastly, Key
Recommendations have been defined as standards which each national/regional
association is recommended to adopt to give effect to each Specific Key Principle.
The ACIIA Principles seek to ensure the highest ethical conduct of investment
analysts. Primarily, these principles are directed at investment analysts which are
members of ACIIA associations, but they aim at setting standards for everyone of
the profession, thus contributing to the integrity of global capital markets as a
whole.

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孙业栋

A. Fundamental Principles

1. Honesty, Integrity, and Fairness
Investment analysts shall observe high standards of honesty, integrity, and fairness
in dealings with clients, prospective clients, and others related to professional
activities, so as to enhance public confidence in the profession.

2. Reasonable Care and Diligence
Investment analysts shall perform their professional activities with reasonable
care, prudence and diligence.

3. Interests of Clients First
Investment analysts shall always act in the best interests of their clients and
prospective clients, and place the interests of clients and prospective clients before
their own or that of their employers, or those of any third party.
ACIIA Principles of Ethical Conduct © 2005 ACIIA 3
ACIIA Principles of Ethical Conduct © 2005 ACIIA

4. Independence and Objectivity
Investment analysts shall take reasonable care to maintain independence and
objectivity and to make fair judgments in performing their professional activities.

5. Professional Competence
Investment analysts shall continuously strive to maintain and improve their professional
competence.

6. Required Knowledge and Compliance
Investment analysts shall maintain knowledge of and comply with all applicable
laws, rules, regulations, and the codes of ethics and standards of professional
conduct of national or regional associations, and shall not consciously partake
in any violation of an ethical or legal nature.

B. Specific Key Principles

1. Reasonable Basis and Fair Representation
Principle: Investment analysts shall have a reasonable basis for, and provide fair
representation in, their investment research, recommendations, and investment
management.

Key recommendations:
a. Investment analysts shall have a reasonable basis for their investment
research, recommendations, and investment management, supported by
thorough and diligent research and analysis.
b. Facts and opinions shall be clearly distinguished; forecasts shall be labelled
as such.
c. Analysis shall be presented clearly and structured logically so as to avoid
any misinterpretation.
d. Analysis shall be prepared with professional diligence; investment analysts
shall make every reasonable effort to check the reliability and truthfulness
of information from external sources.
e. The basic principles and methods used for valuation, securities’ selection,
and portfolio construction, and any material changes to them, shall be disclosed;
all material facts and risk factors shall be adequately disclosed.
f. Investment analysts shall not give assurances or guarantees, either orally or
written, regarding the performance of an investment.
g. When using material prepared by another, investment analysts shall take
prudent and thorough care acknowledging the name of the author, publisher,
or source of such material.
h. Investment analysts shall maintain appropriate records to support the reasonableness
of their investment research, recommendations, and investment
management.

2. Suitability
Principle: Investment analysts shall assess the appropriateness of an investment
recommendation or investment action for their clients and prospective
clients.

Key recommendations:
a. Investment analysts shall make a reasonable inquiry into clients’ and
prospective clients’ financial situations, and know their needs and investment
experiences.
b. Investment analysts shall consider the appropriateness of investment
recommendations or actions for clients’ investment objectives and portfolios.
c. Investment analysts shall clearly indicate the basic features of an investment
and its associated risks to clients and prospective clients.
d. When an investment recommendation is made to the public (not specified
clients), investment analysts shall indicate information such as provided
under B.2.c. above so that the recipients of the recommendation can determine
whether the recommendation is appropriate for them or not.

3. Prohibition Against Misrepresentation
Principle: Investment analysts shall accurately present all relevant facts to
avoid any misrepresentation as to their professional services.

Key recommendations:
a. Investment analysts shall not make any statements that could be misleading
as to the services offered to clients and prospective clients, and any other
important facts relevant to professional activities.
b. Investment analysts shall present investment performance fairly, accurately,
and completely to their clients and prospective clients.

4. Prevention and Disclosure of Conflicts of Interest
Principle: Investment analysts shall take all necessary steps to avoid conflicts
of interest that could reasonably be expected to impair their independence and
objectivity.

Key recommendations:
a. Investment analysts shall disclose to their clients, prospective clients, and
employers all matters that could reasonably be expected to impair their independence
and objectivity.
b. Investment analysts shall inform their supervisors of any form of pressure
arising in the course of their professional duties.
c. Investment analysts shall refrain from ownership of securities in their coverage
sectors, unless such ownership is reasonably judged not to impair
research objectivity and is disclosed to clients and prospective clients.
d. Investment analysts assigning recommendations shall allow their clients and
prospective clients adequate time to act on their recommendations before
acting on their own behalf or their employers.
e. Investment analysts shall not trade inconsistently with their firm’s published
recommendations, except in cases of clear personal necessity and only in
compliance with the employer’s disclosure procedures.
f. Investment analysts shall give priority to investment transactions for clients
over their personal or employers’ account transactions.

5. Compensation
Principle: Investment analysts shall not accept compensation that could reasonably
be expected to impair their independence and objectivity.

Key recommendations:
a. Investment analysts shall disclose to their clients, prospective clients, and
employers all monetary compensation or other benefits for services provided
to clients from any source other than their firms.
b. Investment analysts shall not accept from companies that they cover, gifts or
other benefits which could reasonably be expected to impair their independence
and objectivity.

6. Fair Dealing with Clients
Principle: Investment analysts shall deal fairly with all clients and prospective
clients when disseminating investment recommendations and taking investment
actions.

7. Prohibition Against Use of Material, Non-Public Information
Principle: : Investment analysts, whilst in the possession of material non-public
information relating to issuers of financial instruments, shall not trade on, or
communicate to others, such information, or use such information in investment
analysis.

8. Proper Use of Professional Qualifications
Principle: Investment analysts shall use their qualifications with due care so
as to enhance the standing of and confidence in such qualifications and their
related associations.

Key recommendations:
When using the CIIA designation in their professional activities, investment analysts
shall take due care so as to enhance the standing of and confidence in the
qualification and its related associations.

9. Preservation of Client Confidentiality
Principle: Investment analysts shall preserve the confidentiality of information
about clients and prospective clients.

ACIIA PRINCIPLES OF ETHICAL CONDUCT AT A GLANCE

A. Fundamental Principles
Investment analysts shall:
A.1 Observe high standards of honesty, integrity, and fairness in dealings with
clients, prospective clients, and others related to professional activities, so
as to enhance public confidence in the profession.
A.2 Perform their professional activities with reasonable care, prudence and
diligence.
A.3 Always act in the best interests of their clients and prospective clients, and
place the interests of clients and prospective clients before their own or that
of their employers, or those of any third party.
A.4 Take reasonable care to maintain independence and objectivity and to make
fair judgments in performing their professional activities.
A.5 Continuously strive to maintain and improve their professional competence.
A.6 Maintain knowledge of and comply with all applicable laws, rules, regulations,
and the codes of ethics and standards of professional conduct of
national or regional associations, and shall not consciously partake in any
violation of an ethical or legal nature.

B. Specific Key Principles
Investment analysts shall:
B.1 Have a reasonable basis for, and provide fair representation in, their investment
research, recommendations, and investment management.
B.2 Assess the appropriateness of an investment recommendation or investment
action for their clients and prospective clients.
B.3 Accurately present all relevant facts to avoid any misrepresentation as to their
professional services.
B.4 Take all necessary steps to avoid conflicts of interest that could reasonably
be expected to impair their independence and objectivity.
B.5 Not accept compensation that could reasonably be expected to impair their
independence and objectivity.
B.6 Deal fairly with all clients and prospective clients when disseminating investment
recommendations and taking investment actions.
B.7 Whilst in the possession of material non-public information relating to
issuers of financial instruments, not trade on, or communicate to others,
such information, or use such information in investment analysis.
B.8 Use their qualifications with due care so as to enhance the standing of and
confidence in such qualifications and their related associations.
B.9 Preserve the confidentiality of information about clients and prospective
clients.