Maintaining high ethical standards of integrity in the Manager’s business must be the responsibility of senior management and each employee.

Particularly important to creating a culture of compliance are the
following:

1. encouragement by senior management to personnel to raise any concerns or questions (facilitated by an environment that is free from fear of retribution);
2. ability to communicate concerns to senior management;
3. active participation by senior management in compliance meetings and training sessions;
4. the role of the Chief Compliance Officer (or other person with similar responsibilities) should be regarded as institutionally significant; and
5. senior management should consult regularly and encourage employees to consult regularly with the Chief Compliance Officer and his or her delegates whenever issues arise that could raise compliance issues.