Summerhill Capital Management abides by the Code of Ethics and Standards of Professional Conduct as set out by the Chartered Financial Analysts (CFA) Institute. The CFA works globally, setting high standards of education, integrity, and professional excellence within the investment industry. All Summerhill employees are required to abide by the institute’s standards, regardless of whether or not they hold CFA charters. All employees either hold the CFA designation or are actively pursuing it. To maintain the highest level of professional integrity we have created an extensive employee manual, which is updated at least once a year, and must be read by all employees after every update, in order for everyone to be up to date with any new regulations. This manual clearly outlines our internal compliance with regards to legal standards, as well as our own ethical imperatives.