Code of Ethics

Our Board of Trustees approved and adopted an Ethics Program comprised of the following:

  • Code of Ethics and Business Conduct, which establishes guiding standards for conducting business and applies to all our Trustees, employees and agents, including our Management Company; view our Code of Ethics [PDF]. 

  • Code of Ethics For Senior Financial Officers, which applies to our Chief Executive Officer, Chief Accounting Officer, Chief Investment Officer and all of our finance employees, including those employed by our Management Company; view our Code of Ethics for Senior Financial Officers [PDF].

  • Policies and Procedures, which apply to all of our Trustees, employees and agents, including our Management Company.

While each component has a specific purpose, together they provide an integrated approach to the way we conduct our business. We recognize that adherence to the principles in the Code of Ethics is essential to our efforts to gain and keep the confidence and support of all of our shareholders, and to do what is legal and what is ethical. It is also necessary both to manage our business effectively and to meet the constantly changing needs of the marketplace. We believe it is a critical part of the way we do business.

Code of Ethics and Business Conduct

We are committed to observing the spirit and letter of the laws and regulations that apply to our business. Our Code of Ethics and Business Conduct explains our commitment to integrity and to compliance with the law. It is a strong statement about how to behave in a wide range of business settings. With clear policies and guidance for business practices, the Code is the cornerstone for our ethics and compliance program. Following the Code is mandatory for all Trustees, Officers, Employees and Agents. Our Code also strongly prohibits retaliation against anyone who raises a concern, and we are personally committed to fostering an environment that encourages people to raise issues when they arise. We all share responsibility for fostering a culture of integrity. View our Code of Ethics [PDF]..