Code of Conduct

Preamble

This Code of Conduct establishes the ethical principles and standards that govern the conduct of all personnel, leadership, and representatives of Mighty Investment Group. Our commitment to integrity, transparency, and accountability forms the foundation of our relationship with investors, partners, and stakeholders.

Scope and Application

This Code applies to:

All employees, executives, and senior management
Board members and advisors
Independent contractors and consultants acting on behalf of the firm
All individuals representing Mighty Investment Group in professional capacities

Our Guiding Principles

Mighty Investment Group is built on four core principles:

Integrity: Honest and ethical conduct in all dealings
Transparency: Clear, candid communication with all stakeholders
Accountability: Taking responsibility for our decisions and actions
Investor Protection: Prioritizing the interests and welfare of our clients

Core Commitments

Every member of Mighty Investment Group commits to upholding the highest standards of professional conduct. These commitments reflect our dedication to ethical excellence and long-term stakeholder value.

Integrity in All Business Dealings

Conduct business honestly and ethically, rejecting any form of fraud or deception
Avoid conflicts of interest or disclose them promptly when they cannot be avoided
Honor all commitments and agreements with investors, partners, and employees
Report suspected violations through appropriate channels without fear of retaliation

Professionalism and Excellence

Maintain competence through continuous learning and professional development
Uphold the reputation of Mighty Investment Group through exemplary conduct
Treat all colleagues, partners, and investors with respect and dignity
Avoid behavior that could reflect negatively on the firm or undermine trust

Accountability and Responsibility

Take ownership of decisions and actions, including mistakes and their remediation
Report accurate information to management and oversight bodies
Comply with all applicable laws, regulations, and company policies
Support colleagues in maintaining these standards and escalate concerns appropriately

Investor Relations Standards

Our relationship with investors is built on trust, transparency, and unwavering adherence to the highest standards of communication and disclosure. Every interaction must reflect our commitment to investor protection.

Honest and Accurate Communication

Provide timely, accurate information about investment performance, strategies, and risks
Present facts without exaggeration, omission, or misrepresentation
Acknowledge uncertainty and limitations when discussing future performance or projections
Ensure all written and verbal communications are verified for accuracy before dissemination

Prohibition on Misleading Representations

Never claim expertise, qualifications, or track records that are not substantiated
Avoid exaggerating potential returns or understating risks associated with investments
Do not make statements about performance, strategies, or capabilities without proper documentation
Ensure marketing materials comply with all regulatory standards and contain appropriate disclaimers

Full Disclosure of Material Information

Proactively disclose all material risks, fees, and limitations of investment strategies
Inform investors of any conflicts of interest that could affect investment decisions
Provide complete information about fund composition, leverage, and key personnel changes
Update investors promptly when material changes occur in strategy, management, or risk profile

Documentation and Record Keeping

Maintain detailed records of all material communications with investors
Document all commitments, representations, and key conversations
Preserve records in accordance with regulatory requirements and company policy
Ensure records are accessible for compliance review and investor inquiries

Conflicts of Interest

Conflicts of interest can undermine investor trust and compromise decision-making. We are committed to identifying, disclosing, and managing conflicts transparently to protect investor interests.

Definition and Recognition

A conflict of interest exists when personal, financial, or family interests could compromise professional judgment or loyalty to clients
Examples include: personal investments in competing strategies, financial benefits from vendor selection, board memberships at related entities, or family employment
Even the appearance of conflict must be identified and managed appropriately
Employees are responsible for recognizing and reporting potential conflicts in their work

Identification and Disclosure Process

All employees must complete conflict of interest questionnaires during onboarding and annually thereafter
Disclose any new conflicts immediately to your manager or the Compliance Officer
Provide full details of the conflict, parties involved, and potential impact on firm operations
Conflicts will be evaluated and documented within 10 business days of disclosure

Management and Recusal Protocols

When conflicts cannot be eliminated, implement disclosure and management procedures
Recuse yourself from decision-making, voting, or advisory roles when conflicts exist
Do not participate in discussions about affected investments, vendors, or business decisions
Document recusal actions in personnel records and compliance files

Personal Trading and Outside Activities

Obtain pre-approval before engaging in outside employment, board service, or consulting
Restrict personal trading in securities related to firm investments or strategies
Avoid trading ahead of firm transactions or using material non-public information
Submit personal trading reports for compliance review on a periodic basis

Confidentiality & Data Protection

Confidential information is among our most valuable assets. We are committed to protecting investor data, proprietary strategies, and all sensitive business information through rigorous security measures and strict confidentiality practices.

Investor Data and Privacy Protection

Safeguard all investor personal and financial information with strict access controls
Collect only information necessary for investment and regulatory purposes
Protect data against unauthorized access, disclosure, or misuse
Comply with all applicable privacy laws and regulations (GDPR, CCPA, state privacy laws)

Non-Disclosure Agreements and Obligations

Respect all non-disclosure agreements with partners, investors, and third parties
Do not disclose confidential information to competitors or unauthorized parties
Limit sharing of confidential information only to those with legitimate business need
Remember that confidentiality obligations survive employment termination

Proprietary Information and Trade Secrets

Protect investment strategies, research methodologies, and performance models as trade secrets
Do not discuss proprietary strategies or processes in public forums, including social media
Return all proprietary materials and data upon termination of employment
Avoid using proprietary information from previous employers at Mighty Investment Group

Data Security and System Access

Use strong passwords and multi-factor authentication for all system access
Never share login credentials or leave systems unattended without locking
Report suspected security breaches or unauthorized access immediately
Follow secure disposal procedures for documents containing sensitive information

Workplace & Third-Party Conduct

A respectful, inclusive workplace strengthens our firm and enhances decision-making. We hold ourselves and our partners to rigorous standards of professional and ethical conduct.

Respectful Workplace Environment

Treat all colleagues with professionalism, dignity, and respect regardless of position
Value diverse perspectives and create an inclusive environment where all voices are heard
Collaborate professionally and support colleagues in their professional development
Address disagreements constructively and respectfully without personal attacks

Anti-Discrimination and Anti-Harassment Policy

Zero tolerance for discrimination based on race, color, religion, sex, national origin, age, disability, or any other protected characteristic
Harassment of any kind—including sexual harassment, bullying, or intimidation—is prohibited
Report all instances of discrimination or harassment to HR or management immediately
All reports will be investigated promptly and confidentially, with appropriate corrective action taken

Third-Party and Vendor Standards

Require all vendors, consultants, and service providers to comply with equivalent ethical and legal standards
Establish contractual requirements for confidentiality, data protection, and compliance with applicable laws
Monitor third-party conduct and terminate relationships when standards are not met
Ensure partner firms conduct themselves with the same integrity we demand internally

External Representation and Communications

All external communications (media, events, presentations) must reflect firm values and approved messaging
Do not misrepresent the firm, your role, or your expertise in external interactions
Coordinate with marketing and communications before making public statements about the firm
Be mindful of social media conduct; avoid posting content that could damage firm reputation

Reporting Violations

We encourage all employees to report suspected violations of this Code. Multiple reporting channels are available to accommodate different comfort levels and circumstances. All reports will be taken seriously and handled appropriately.

Multiple Reporting Channels

Direct Supervisor: Report concerns to your immediate manager for prompt discussion and resolution
HR Department: Contact Human Resources for workplace, harassment, or discrimination concerns
Compliance Officer: Report potential legal, regulatory, or ethical violations directly to the firm's Compliance Officer
Ethics Hotline: Call the confidential ethics hotline (available 24/7) or submit anonymous concerns online

Non-Retaliation Protection

Mighty Investment Group strictly prohibits retaliation against individuals who report violations in good faith
Protected actions include reporting suspected violations, participating in investigations, and refusing unethical conduct
Retaliation includes termination, demotion, pay reduction, negative evaluations, or any other adverse employment action
Report suspected retaliation immediately to HR or the Compliance Officer

Anonymous and Confidential Reporting

Employees may report violations anonymously through the ethics hotline or secure online portal
Confidentiality will be maintained to the maximum extent possible during investigations
Identify yourself to HR or Compliance only if you wish to receive feedback on the investigation
Anonymous reporters are protected against retaliation with the same strength as identified reporters

Investigation Process and Remediation

All reported violations will be investigated promptly and fairly by qualified personnel
Investigations will be conducted confidentially with access limited to those with legitimate need-to-know
Findings will be documented and appropriate remedial action taken if violations are confirmed
Reporters may request updates on investigation status where confidentiality allows

Enforcement & Amendments

Adherence to this Code of Conduct is a condition of employment. Violations will be addressed through appropriate disciplinary action, and the Code will be reviewed and updated regularly to maintain relevance and effectiveness.

Disciplinary Consequences

Violations of this Code may result in disciplinary action up to and including termination of employment
Consequences depend on the severity of the violation, intent, impact, and history of the individual
Minor violations may result in warnings, additional training, or probation
Serious violations (fraud, data theft, sexual harassment) may result in immediate termination and legal action

Annual Review and Updates

This Code will be reviewed at least annually by management and the Board
Updates will reflect changes in applicable laws, regulations, and industry standards
Lessons learned from investigations and violations will inform improvements
All material amendments will be communicated to employees and require reacknowledgment

Board and Governance Oversight

The Board of Directors maintains oversight of Code compliance and ethical culture
Quarterly reports on violations, investigations, and remedial actions will be presented to the Board
Board members will review trends, patterns, and areas for improvement in the firm's ethical framework
The Board will approve all significant amendments to this Code

Employee Acknowledgment and Training

All employees must acknowledge receipt and understanding of this Code annually
Acknowledgment must be documented in personnel records
Regular ethics training will be provided to all staff, with specialized training for risk areas
Failure to acknowledge this Code or participate in required training may result in disciplinary action

Last Updated: 2026 | Next Review: 2027

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