Code of Ethics for depository directors mandates disclosure of securities dealings, trading restrictions, and ethics committee oversight.

The Code of Ethics requires an ethics committee and Compliance Officer oversight, mandates periodic disclosure of securities dealings by directors and key management personnel, enforces trading restrictions for non-public price sensitive information, and imposes a minimum 60-day holding requirement for purchased securities subject to documented pre clearance waivers. It bars use of position for personal gain, requires disclosure of fiduciary and business interests, limits board interference in daily management, and requires confidentiality and prescribed channels with audit trails for access to information.

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