The Blacksmith Fund
Code of Ethics
The Blacksmith Fund LP Code of Ethics
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Introduction
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The Code of Ethics for The Blacksmith Fund LP establishes the ethical framework that governs the conduct of all employees, partners, and stakeholders involved in the business. Our goal is to maintain the highest standards of professionalism, integrity, and accountability while fostering a culture of trust and respect within the firm and with external stakeholders.
This Code serves as a guide for making ethical decisions in the workplace, ensuring that all activities are conducted in a manner consistent with our values and principles.
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Core Values
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1. Integrity: We act with honesty, transparency, and accountability in all interactions and decisions. We ensure that our actions are aligned with the highest ethical standards, both within the firm and in dealing with clients, investors, and other stakeholders.
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2. Accountability: We take responsibility for our actions and decisions, ensuring that we uphold the interests of our clients, investors, and partners. We are committed to delivering value through disciplined investment strategies and sound management practices.
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3. Respect: We treat all individuals with dignity and respect, fostering an inclusive and supportive environment. We recognize the value of diverse perspectives and strive to create a positive, collaborative culture that encourages mutual respect and professionalism.
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4. Excellence: We continually strive to exceed expectations by delivering high-quality work and performance. We are dedicated to maintaining excellence in all aspects of our business, including investment analysis, client service, and operational processes.
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5. Confidentiality: We respect the confidentiality of proprietary information, investor data, and business strategies. We ensure that sensitive information is handled with the utmost care and is only shared with authorized parties when necessary.
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Standards of Conduct
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1. Professional Behavior
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• Honesty and Transparency: All business dealings, including financial transactions, communication with investors, and reporting, must be conducted with complete honesty and transparency. Misrepresentation of facts or data is strictly prohibited.
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• Commitment to Quality: Every member of the firm is expected to uphold the highest standards of quality in their work. This includes conducting thorough research, presenting accurate and reliable information, and delivering results that reflect our commitment to excellence.
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• Respectful Interactions: We are committed to fostering a workplace environment that encourages respect, open communication, and positive relationships. Discrimination, harassment, or any form of inappropriate behavior will not be tolerated.
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2. Compliance with Laws and Regulations
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• Legal Compliance: All employees, partners, and stakeholders must comply with applicable local, state, and federal laws, as well as industry regulations, including those related to investment management, securities trading, financial reporting, and data protection.
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• Regulatory Compliance: We will ensure compliance with relevant regulatory bodies, including the Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), and any other relevant industry regulators. We maintain strict adherence to regulations governing the private equity and investment industry.
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• Anti-Corruption: We maintain a zero-tolerance policy for corruption and unethical practices, including bribery or any illegal incentives. We conduct business in a manner that aligns with ethical and legal guidelines, ensuring that no individual is placed in a position to offer or accept improper payments.
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3. Conflict of Interest
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• Avoiding Conflicts: Employees, partners, and stakeholders must avoid any situation that may create a real or perceived conflict of interest. We expect individuals to prioritize the interests of The Blacksmith Fund LP and its investors above personal or financial gain.
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• Disclosure: Any potential conflict of interest, whether direct or indirect, must be disclosed to the appropriate internal authorities. All relationships, investments, or activities that may compromise an individual’s ability to act in the best interests of the firm must be disclosed promptly.
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• Independent Decision-Making: Employees and partners are expected to make decisions based solely on the best interests of the firm and its investors. Personal relationships, financial interests, or external pressures should not influence investment decisions or business operations.
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4. Confidentiality and Data Protection
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• Protection of Confidential Information: We are committed to safeguarding the confidentiality of sensitive business information, including investment strategies, financial data, and client details. Employees, partners, and contractors are required to maintain the confidentiality of all proprietary information.
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• Data Privacy: The firm will comply with all applicable data protection laws and regulations to protect the privacy of personal and financial data entrusted to us by investors, employees, and other stakeholders. Any misuse of personal or financial data is strictly prohibited.
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• Non-Disclosure: Information related to the firm’s operations, investments, or internal strategies is considered confidential. Such information should not be disclosed to external parties without proper authorization.
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5. Fair Treatment of Investors
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• Investor Trust: The trust and confidence of our investors are paramount. We commit to transparent and honest communication regarding investment performance, risks, and strategic decisions. All investors are to be treated fairly, with equal access to material information.
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• Confidential Investor Information: Investor information will be handled with the utmost care. We will never disclose any investor-specific data or financial information to third parties unless required by law or with explicit consent.
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• Fiduciary Duty: We recognize the fiduciary responsibility we hold to our investors. We will act in good faith and with the utmost care in making investment decisions, ensuring that we always act in the best interests of our clients.
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Continuous Improvement
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• Training and Education: The firm is committed to ongoing training and education on ethical standards, legal compliance, and risk management for all employees and partners. Regular ethics training will be provided to ensure everyone is aware of their responsibilities and obligations.
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• Code of Ethics Review: The Code of Ethics will be reviewed periodically and updated as necessary to reflect changes in laws, regulations, and best practices. All stakeholders will be informed of any updates or revisions to the Code.
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Conclusion
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The Code of Ethics for The Blacksmith Fund LP is a cornerstone of our commitment to maintaining the highest standards of professionalism and integrity. By adhering to this Code, we ensure that our operations remain ethical, transparent, and accountable to our investors, employees, and the broader financial community. We are dedicated to creating an environment that fosters trust, respect, and ethical conduct, ensuring the long-term success of our firm and the prosperity of our stakeholders.
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