August 2019

Code of Conduct for the Board of Directors of Asociación de Profesionales de Inversión del Uruguay (“CFA Society Uruguay”)

I. Guiding Principles

The Board of Directors of CFA Society Uruguay has adopted the following Code of Conduct

(“Code”) for Directors of CFA Society Uruguay. The purpose of the Code is to highlight the

duties and responsibilities of Directors on areas of ethical risk, guide Directors to recognize

and deal with ethical issues, and provide methods to report unethical conduct, all with the

goal of fostering a culture of honesty, trust and accountability.

Each Director must comply with both the letter and the spirit of this Code.

As representatives of CFA Society Uruguay, and as persons at the highest levels of

responsibility and trust, Directors are expected to set a “tone at the top” of high ethics and

proper behavior and serve as individual examples to the public and the investment

community of the highest ethics and principles.

Since no code or policy can anticipate every situation that may arise, this Code serves as a

source of guiding principles. Directors are encouraged to bring questions or concerns about

particular circumstances to the attention of the Chair of CFA Society Uruguay. When in

doubt, a Director should act according to the spirit of this Code and CFA Society Uruguay

principles.

II. Scope of Authority

The Board is a collegial body.

The Board may act and give directions to CFA Society Uruguay management, employees, and volunteers only through official actions as a result of Board meetings held with proper notice and a quorum. A Director’s authority is limited to those actions taken during a Board meeting. A Director may not act in an official capacity except in the context of a meeting of the Board unless specifically empowered to do so at a proper meeting of the Board.

A Director’s primary obligation is to participate in the governance and policy making

process of CFA Society Uruguay. A Director does not have any individual authority to waive

compliance with any policy of the Board nor to create any policy on behalf of the Board.

Directors do not represent any constituency or group with their service on the Board; they

perform their duties on behalf of the interests of SOCIETY as a whole.

III. Standards of Conduct

Each Director is elected to contribute to the achievement of the mission of CFA Society

Uruguay in the best interest of its membership, the investment community and the

investing public. Each Director’s contribution shall be made with respect for the law and

with honesty, loyalty, prudence, diligence and fairness. Directors shall act in good faith in

the best interest of CFA Society Uruguay and shall exercise their duty to provide policy

guidance and leadership to the management, employees and membership of CFA Society

Uruguay.

Directors shall comply with and satisfy themselves that appropriate procedures and

policies are in place for compliance by Directors, employees, and volunteers of CFA Society

Uruguay with rules, laws and regulations applicable to CFA Society Uruguay. Directors may

not engage in any conduct or activity that is inconsistent with the best interests of CFA

Society Uruguay or that disrupts or impairs the business relationships of CFA Society

Uruguay.

A Director shall not conduct personal business at a meeting of the Board nor advance their

personal interests at the expense of CFA Society Uruguay. A Director shall, while

encouraged to state his views on all matters under discussion by the Board, at all times act

with dignity and treat fellow Directors, employees, and volunteers of CFA Society Uruguay

with respect and courtesy. Disagreements should be directed to the issue and not to the

individual who raises an opposing point of view.

All Directors shall conduct their professional life in a manner that befits the dignity of a

Director of CFA Society Uruguay and befits their obligation to provide leadership by

example to others.

A. Public Statements

Each Director may speak on behalf of CFA Society Uruguay but only as specifically

authorized by the Board through its policy making role. Directors must be careful that any

public statements made should be identified as personal opinion if there is any reasonable

expectation that the statements may be interpreted as being made on behalf of CFA Society

Uruguay.

B. Political Activity

A Director is free to engage in individual political activity but such activity must be

completely disassociated from their position as a Director of CFA Society Uruguay. A

Director must not use their status to further any political goal unless authorized by the

Board to further the interests of CFA Society Uruguay.

C. Use of SOCIETY Property

A Director may use CFA Society Uruguay property only in furtherance of the interests of

CFA Society Uruguay and the Board; not for personal gain.

D. Confidentiality

Directors shall maintain the confidentiality of information entrusted to them by CFA

Society Uruguay and any other confidential information about CFA Society Uruguay that

comes to them from whatever source in their capacity as a Director, except when

disclosure is authorized or legally mandated. Confidential information includes all non-public information relating to CFA Society Uruguay and shall not be disclosed to third-

parties, including members of CFA Society Uruguay, except as duly authorized by CFA Society Uruguay.

E. Nonpublic Information

Any nonpublic investment information that a Director may learn on account of the

Director’s position on the Board or at any meeting held by or for CFA Society Uruguay shall

be treated confidentially and the Director shall deal with the information consistent with

law and the CFA Institute Code of Ethics and Standards of Professional Conduct.

F. Corporate Opportunities

Directors may not take for themselves business or other opportunities relating to the

business of CFA Society Uruguay or compete with CFA Society Uruguay for business

opportunities, without the express approval of the Directors who are disinterested in the

transaction.

IV. Conflicts of Interest

A Director’s paramount interest must be to promote and preserve the interests of CFA

Society Uruguay. However, Directors may have board, employment, investment, personal

and other relationships that could conflict to some degree or have the appearance of a

conflict with the interests of CFA Society Uruguay. Conflicts may also arise when a Director

receives improper benefits, or takes action or has interests that may make it difficult to

serve objectively and effectively. Conflicts may arise indirectly, such as when a Director

holds a material position in another organization that is affected by the Director’s action as

a member of the Board of CFA Society Uruguay. Such conflicts and interests must be

disclosed to CFA Society Uruguay when the Director joins the Board and whenever they develop. Directors should avoid to the extent possible any conflict between themselves,

their other responsibilities, and CFA Society Uruguay.

Directors are expected to use sound judgment and good faith in identifying actual and

potential conflicts of interest with the objective of disclosing any position or activity that

may give rise to a conflict or the appearance of a conflict.

A. Gifts and Entertainment

No Director shall solicit for their or their family’s benefit any gift or entertainment from any organization or person on account of their position as a Director of CFA Society Uruguay. Directors and members of their family may not accept gifts from persons or entities who deal with CFA Society Uruguay where the gift has more than a nominal value or where the receipt of the gift may create the appearance of a conflict. Gifts of cash, stocks, loans or similar items must not be accepted at any time and should be returned immediately. In some countries, gift giving is an accepted business custom and the refusal of a gift may not be in the best interests of CFA Society Uruguay. In such circumstances the Director may accept the gift; the gift must be disclosed and become the property of CFA Society Uruguay.

Reasonable entertainment in order to foster CFA Society Uruguay business, professional and investment industry relationships is permissible so long as it does not create the appearance of an obligation of the Director to the person or organization providing the entertainment. Lavish or extravagant entertainment, or entertainment provided solely to a Director or their family without the presence of the person or organization financing the entertainment, is not permitted.

B. Handling of Conflicts

Not all conflicts can be avoided in advance, and conflicts may arise or be discovered in the course of the Director’s work on the Board. Each Director is expected, upon learning of a conflict, to disclose the conflict to the Chair of the Board. When in doubt, a Director should err in favor of disclosure.

Upon disclosure, the Chair shall determine the proper handling of the conflict in

consultation with the Board. The conflict may be handled by making a full disclosure

to the Board, recusal from discussion or voting on the matter, absence of the Director from the meeting discussing the matter, or such other means or combination of means as determined by the remaining disinterested Directors.

C. Reporting of Conflicts

Each Director shall provide an annual statement to the Chair attesting to any conflict of interest identified by the Director or the absence of any conflict of interest to the best of knowledge of the Director. In making such statements, a Director shall report in good faith and consistent with the letter and spirit of this Code. Reporting a conflict under this provision is in addition to, and not a replacement for, a Director’s obligation to report the conflict when taking action as a member of the Board.

V. Compliance Reporting and Sanctions

Directors should ensure that CFA Society Uruguay seeks advice about ethical decisions and

reports suspected violations, and assures employees that there will not be retaliation for

reporting violations. Directors should report any suspected violations of this Code

promptly to the CFA Society Uruguay Secretary or President, or any combination of the

above. Alleged violations will be investigated by the Board or by persons designated by the

Board and appropriate action taken in the event of a violation. For any queries, please

consult CFA Institute Society Relations staff.

Appropriate sanctions may be imposed for violations of this Code. Sanctions may include

cautionary admonition, request for remedial action, request for resignation, removal from

office, or such other action as the Board shall deem suitable.

Conflict of Interest Policy

August 2019

Conflict of Interest Policy for the Board of Directors of Asociación de Profesionales de Inversión del Uruguay (“CFA Society Uruguay”)

The Board of Directors of CFA Society Uruguay, officers, committee members, task force

members, volunteers, and employees (“Covered Individuals”) must act at all times in the

best interests of CFA Society Uruguay.

 A conflict of interest is any transaction or relationship which presents, or may present, a conflict between the Covered Individual’s obligations to CFA Society Uruguay and his/her personal, professional, or other interests.

Since conflicts of interests are common, and not all conflicts are harmful to CFA Society

Uruguay, the Board requires full disclosure of all actual and potential conflicts of interest

by all Covered Individuals through the annual Conflict Disclosure Form.

The Board will determine whether or not a conflict of interest exists, and whether such

conflict materially and adversely affects the interests of CFA Society Uruguay. A Covered

Individual whose potential conflict is under review may not debate, vote or participate in

such a determination. If it is determined that a conflict of interest exists, the Board shall

determine the appropriate remedy. Such remedy may include recusal from participating in

certain matters or resignation.

To avoid a conflict of interest, Covered Individuals shall:

• Not place self-interest or the interest of a third party above the interests of

CFA Society Uruguay, and avoid the appearance of placing self-interest or the

interests of a third party above the interests of CFA Society Uruguay;

• Not use CFA Society Uruguay staff, contractors, services, equipments,

materials, resources or property from personal or third party gain, and from

representing to third parties that authority as a representative of CFA Society

Uruguay extends any further than that which it actually extends;

• Not engage in any outside business, professional conduct, or other activities

that may be directly or indirectly adverse to the interests of CFA Society

Uruguay;

• Not solicit or accept for the benefit of the Covered Individual or a family

member any gift or entertainment from any person or entity that is a direct or

indirect inducement to provide special treatment relating to CFA Society

Uruguay;

• Not provide goods or services to CFA Society Uruguay as a paid vendor to CFA

Society Uruguay without disclosing to and receiving approval from the Board;

• Not persuade any employee of CFA Society Uruguay to leave the employ of

CFA Society Uruguay or to become employed by a person or entity other than

CFA Society Uruguay;

• Not persuade or attempt to persuade any person or entity with an actual or

potential relationship with CFA Society Uruguay to terminate, reduce, or not

enter into a relationship with CFA Society Uruguay.

If you have any questions regarding the Conflict of Interest Policy, please contact the

Secretary of the Society. If the potential/perceived conflict involves the Secretary, please

consult the President. For any other queries, you may consult CFA Institute Society

Relations staff.

Whistleblower Policy

Approved on August 19^th 2024

Asociación de Profesionales de Inversión del Uruguay (“CFA Society Uruguay”) is committed to lawful and ethical behavior in all of CFA Society Uruguay’s business activities.  All employees and representatives of CFA Society Uruguay should practice honesty and integrity in performing their responsibilities and complying with all applicable laws and regulations.

1. Purpose. This Policy is intended to encourage and enable employees and others to raise serious concerns so that CFA Society Uruguay can address and correct inappropriate conduct and actions. The Policy:
   1. provides a means for employees and other organization leaders to raise good faith concerns regarding suspected violations of law or CFA Society Uruguay policy;
   1. facilitates cooperation in any inquiry or investigation by any court, agency, law enforcement or other governmental body; and
   1. protects individuals who take such action from retaliation or any threat of retaliation by any other employee or agent of CFA Society Uruguay.

1. Scope.  This Policy applies to all CFA Society Uruguay employees, contractors, directors, officers, and volunteers.

1. Statement of Policy.  No officer, director, employee, or agent of CFA Society Uruguay shall take any harmful action with the intent to retaliate against any person for (a) providing any truthful information relating to the commission or possible commission of any offense in connection with any official inquiry or investigation or (b) reporting in good faith any violation or suspected violation of law or policy.

Efforts will be made to treat a report of unethical or illegal conduct as confidential, consistent with the need to investigate and prevent or correct the action. CFA Society Uruguay will explore anonymous allegations to the extent reasonably practicable.

Any individual reporting a violation or suspected violation pursuant to this Policy must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation.

1. Process for Reporting.  Reports of violations or suspected violations of law or policy or reports of retaliation may be reported directly to the Board Secretary.  In the event that an individual’s concern rises to the level that he/she reasonably believes that notice to the Board Secretary will be disregarded or otherwise not fairly considered, the individual may then report violations or suspected violations to the President of the Board. 

• Process for Handling Reports.  Reports of suspected violations of law or policy and reports of retaliation will be investigated promptly and in a manner intended to protect confidentiality.  The Board Secretary will manage such investigation and may request the assistance of outside counsel or other outside parties as he/she deems necessary.  The Board Secretary will prepare a report of the findings of the investigation and submit the report to the Board of Directors.  In the event that the report concerns the Board Secretary, he/she should recuse himself/herself and the Board of Directors shall select a replacement officer to conduct the investigation. 

Contact information:

Julio Carzoglio

Board Secretary

Cel: 099 620 109

CFA SOCIETY URUGUAY Data Privacy Policy

Approved 19^th August 2024

Asociación de Profesionales de Inversión del Uruguay (“CFA Society Uruguay”) is a not-for-profit professional body for investment professionals with its registered address at Juncal 1378 apt 105, Montevideo, Uruguay

This privacy policy (“Privacy Policy”):

1. Describes how we gather and protect individually identifiable information (“Personal Information”).
2. How we use, process, transfer, and share Personal Information.
3. Describes your personal data privacy rights.

This Privacy Policy applies to Personal Information that we collect through any means, including the CFA Society Uruguay website, digital advertising, events and conferences, employment processes and direct interactions with CFA Society Uruguay staff. When we refer to Personal Information in this Policy, we are also referencing “personal data” as it is defined under Law 18831 of Personal Data Protection.

The Personal Information We Collect

Listed below are the classes of Personal Information that we collect. Please note, however, we do not collect all this Personal Information from everyone.

1. Contact Data (name; personal contact information (phone, email address, physical address)
2. Gender
3. Birthdate
4. Passport information
5. Educational background
6. CFA Institute ID
7. Government identification number
8. Work experience
9. Individual’s status in CFA’s programs
10. Behavioral data (how members use our content and offerings)
11. Work location
12. Job/position title
13. Work contact data (telephone and email address)
14. IP Address or Mobile Device ID
15. Type of Browser
16. Type of Operating System

Personal Data Protection Principles

We adhere to general data privacy principles when collecting and processing personal data that require us to:

• Collect and use personal data fairly and only for lawful and specified purposes related to our legitimate business objectives.
•  Limit our personal data collection to what is adequate, relevant, and not excessive for the intended purpose.
•  Notify individuals about our personal data processing practices in a clear and transparent manner
• Ensure the accuracy of the personal data we collect, hold, and use.
•  Retain personal data only for the time needed to fulfil the established purpose.
•  Respect data subjects’ rights.
• Secure the personal data we hold.

Data Security 

We  are responsible for protecting the personal data we hold. We take reasonable and appropriate security measures against unlawful or unauthorized processing of personal data and against the accidental loss of, or damage to, personal data. We exercise particular care in protecting sensitive personal data from loss and unauthorized access, use, or disclosure.

We follow all procedures and technologies we put in place to maintain the security of all personal data from the point of collection to the point of destruction. We only transfer personal data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, if requested.

We must maintain data security by protecting the confidentiality, integrity, and availability of the personal data, defined as follows:

• Confidentiality means that only people who have a need to know and are authorized to use the data can access it.
•  Integrity means that personal data is accurate and suitable for the purpose for which it is processed.
• Availability means that authorized users are able to access the data when they need it for authorized purposes.

Data Subjects’ rights and requests

You have rights when it comes to how we handle their personal data.These rights but may include rights to:

• Request access to their personal data that we hold.
• Prevent our use of their personal data for direct marketing purposes.
• Ask us to delete personal data or correct inaccurate data.
• Prevent processing that is likely to cause damage or distress to the data subject or anyone else.

You must make a written request to access, correct, or delete the personal data we hold about you. Please send an email to [ info@cfasocietyuruguay.org ]

Notification of Changes

If we would like to use your personally identifiable information in a manner different from that which was stated at the time of collection, we will contact you via email at the address you have provided to get your permission. You will have a choice as to whether or not we use your information in this different manner. In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our web site notifying users of the change. In some cases where we post the notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices.

Links

As a convenience to our users, CFA Society Uruguay websites may contain links to sites or services created and maintained by other organizations. Please note that CFA Society Uruguay does not control, and is not responsible for, the accuracy, timeliness, security or even the continued availability or existence of this outside information. Opinions expressed on other sites are not necessarily those of  CFA Society Uruguay nor does  CFA Society Uruguay  endorse, warrant, or guarantee products or services described or offered on other sites. Neither is CFA Society Uruguay responsible for the contents of any websites that choose to link to [Society Name] websites.

Other companies linked to CFA Society Uruguay websites may collect information about you when you view or click on these sites. CFA Society Uruguay cannot control this collection of information. You should contact these companies directly if you have any questions about their use of the information they collect.

Cookies

Cookies are small pieces of information that a website transfers to your computer. Our site may use session cookies (which expire when you close the browser) and persistent cookies (which remain even after you close the browser) to help our site run more smoothly and tailor content for you. In such a case, our site would include a mechanism to manage the cookies we would use through your profile. Additionally, most web browsers have options that allow you to control whether you accept cookies and give you the option to delete all cookies. However, disabling them may prevent access to some parts of the site. If you wish not to be tracked during your visit to our site, follow your browser’s “Do Not Track” instructions or contact your browser provider for more information. By sending a “Do Not Track” signal, you may not be able to use or access some features of our site