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Apex Leaders  has implemented a Compliance Manual and Code of Ethics. The purpose of this program is to protect sensitive non-public client information by adhering to a written compliance policies and supervisory procedures . All employees are trained and expected to conduct their work in a way that protects our clients against undue risk. This is an abbreviated summary of key rules we follow:

Conflicts of Interest

  • Employees are required to identify and attempt to mitigate conflicts of interest in order to provide clients with objective and unbiased services.


  • Employees of Apex are subject to confidentiality requirements in accordance with their employment agreement.
  • Clients and advisors also receive confidential treatment of their information when working with Apex.

Material Non-Public Information

  • Employees are educated on material non-public information, including rules under relevant securities laws that prohibit the misuse of such information.

Employee Personal Investments and Outside Business Activities

  • In order to avoid conflicts of interest, employees must follow certain procedures for their personal investments and outside business activities. For example, employees should not invest in funds managed by Apex’s clients without proper preclearance.

Advertising and Communicating with the Public

  • Apex employees must be fair and not misleading with any advertisements or communications concerning Apex and its services.

Information Technology and Cybersecurity

  • Apex has adopted certain physical safeguards concerning the company and its information, and requires employees to follow certain procedures in order to implement these precautionary measures.



Duff and Phelps

We retained the services of Duff and Phelps to develop a compliance manual, which provides a comprehensive set of internal policies and procedures related to conflicts of interest, confidentiality, documentation, and cybersecurity.