Ethics Accountabilities

At Moriarty every associate and partner has the responsibility to uphold our ethical standards.

We have countless opportunities to demonstrate our ethics through our daily work and activities. To help us make ethical business decisions, all of us must follow the Moriarty Code of Conduct, comprised of the Statement of Business Ethics, The General Policy Statement, and the responsibilities described below. These responsibilities reinforce our commitment to each other, our stockholders, clients, service providers, and communities in which we do business.

Anyone failing to comply with our Code of Conduct is subject to disciplinary action, up to and including separation, subject to local laws and existing agreements governing the terms of employment. While it communicates clear standards for ethical behavior, it’s important for everyone at Moriarty to understand that the Code of Conduct does not change the fundamental nature of the employment relationship between Moriarty and our associates or partners, or create new or additional contractual rights between Moriarty, its associates or partners, or any third party.

Except as explicitly restricted by applicable contract or law, each associates’ employment relationship with Moriarty is “at will”. This means that Moriarty or the associate may terminate the relationship at any time for any reason, with or without cause or prior notice.The responsibilities outlined below apply to all associates and partners at Moriarty in accordance with the Moriarty Code of Conduct. Adhering to these responsibilities will cause us to be recognized worldwide for upholding high ethical standards.

As the above relates to:

Clients

•Do not compromise our ethics.
•Represent our products and services accurately.
•Be honest and trustworthy with our clients and their data.
•Provide solutions that are in our clients’ best interests and deliver what we promise.
•Maximize the value of our services for our clients and for Moriarty.



Service Providers/Suppliers

•Select service providers by balancing cost, quality, and needs in order to provide the most value.
•Act fairly and honestly.
•Do not accept any gifts.



Competitors

•Focus on our abilities and refrain from broad criticism.
•Use facts and accurate information when making comparisons with our competitors.
•When a competitor is also a client, treat each relationship as distinct and do not compromise either.



Partnering

•Treat all potential business partners fairly and negotiate in good faith.
•Be honest, trustworthy, and open with business partners.



Working with each other

•Treat each other with respect and honesty.
•Value every persons experience.



Working with the Media and Investor community

•Direct all inquiries to Public Relations or Investor Relations as appropriate.
•Be truthful and forthcoming with information to the media and our investors.



Recording and reporting financial information

•Accurately record all information in a timely manner.
•In a timely and accurate way, publicly report revenues and expenses.



Resources and company assets

•Use all business assets appropriately and prudently.
•Use all resources for serving our external and internal clients.
•Protect all Moriarty assets and trade secrets.

Security and privacy of information

•Protect the security of all data as private and confidential.
•Ensure that the Moriarty procedures and practices are protected as private and confidential.

Fundamental Obligations

The Moriarty Code of Conduct can’t possibly address every ethical dilemma an associate or partner  may face. Regardless of the situation, you must always consider how your actions reflect on the integrity and credibility of the firm and how your decisions drive business results without compromising our ethical standards. The above responsibilities apply to all contexts in which we interact with others in our day-to-day work -- our clients, each other, our suppliers, our competitors, other organizations, the media, and our investors. To adhere to these responsibilities, you must comply with the following fundamental obligations that drive these behaviors

Conflicts of Interest

A conflict of interest occurs when your personal interests interfere, or appear to interfere, with the interests of Moriarty as a firm. Conflicts of interest can also arise when you or a member of your family or someone with whom you have a personal relationship have interests that may make it difficult for you to perform your Moriarty duties effectively.

Although it’s not possible to list every conceivable conflict, following are examples of some common scenarios that must be reported:

Improper personal benefits from Moriarty

Conflicts of interest can arise when you or a member of your family or someone with whom you have a personal relationship receives improper personal benefits as a result of your position in Moriarty. You may not accept any personal benefits from Moriarty or others (e.g., service providers) that have not been approved pursuant to Moriarty policy and procedure, including any loans or guarantees of your personal obligations

 
Personal relationships/Conflict of interest

Certain personal relationships (such as family or intimate relationship) between associates, between an associate and an employee of a client (that the associate supports), or an associate and a service provider (which the associate has the ability to influence decisions regarding the vendor relationship) may create an actual or perceived conflict of interest. You are responsible for reporting to your manager or HR if you are in any situation that has a potential for a conflict of interest as described above. Your manager or HR will work with you to determine an appropriate resolution

 
Financial or employment interests in other businesses

You may not have an employment or ownership interest in any other enterprise if that interest compromises, or appears to compromise, your loyalty to Moriarty. For example, you may not be employed by or own an interest in a company that competes with Moriarty. Nor should you be employed by or own an interest in any company that does business with Moriarty (e.g., a supplier) where you have any involvement in the decision to retain that business. However, it is not a conflict of interest to invest in clients, competitors, or suppliers indirectly through a mutual fund or a registered investment company that owns publicly listed stock of such entities. Unless directed otherwise by Moriarty (e.g., participating in a Moriarty-sponsored charity), you may not conduct business for other organization during hours you are working for Moriarty nor should you use the Moriarty facilities, supplies, or other assets in connection with any other business

 
Business arrangements with Moriarty

Without the prior written approval of the General Counsel, you may not participate in a joint venture, partnership, or other business arrangement with Moriarty

 
Using the Moriarty name with activities outside the firm

You are not authorized to use the Moriarty name or that of any associated companies in any activity outside of those involved in the fulfillment of your Moriarty duties, unless authorized in advance by Moriarty in writing.

Corporate Opportunities

If, as a result of your Moriarty employment (such as from a competitor, an actual or potential supplier, or a business associate of Moriarty), you learn of a business or investment opportunity that could reasonably be considered by Moriarty, you must inform your manager of the opportunity and you may not use such information for your personal gain (including sharing such information with potential competitors of Moriarty.

Adherence to Laws, Rules, and Regulations

You are expected to adhere to all applicable laws, regulations, and professional standards that govern our business. This includes not only  laws that are applicable to the services we provide our clients, but also laws and regulations regarding the operation of our business, such as securities laws and rules regarding the reporting of financial information.