Fiduciary duty requires investment advisers to act honestly, disclose conflicts, protect client confidentiality and comply with regulations. The Code of Conduct requires investment advisers to act honestly and in clients' best interests, exercise due skill, care and diligence, maintain necessary resources and procedures, obtain and keep confidential client financial and investment information, disclose material information to clients, charge fair and reasonable fees within Board-prescribed limits, avoid or disclose conflicts of interest and ensure regulatory compliance; senior management bears primary responsibility for maintaining conduct standards and procedures.