TRADERS A.I., INC.
Code of Ethics
Access Person Training
CRD # 331700 | SEC File No. 801-130642 Effective: July 10, 2024 | Confidential
By the end of this training, Access Persons will understand their obligations under the Code of Ethics, including personal trading rules, reporting requirements, and prohibited conduct.
Today's Agenda
Who We Are & Our Fiduciary Duty
Gifts, Entertainment & Political Contributions
01
05
Who Are Access Persons?
Conflicts of Interest & Outside Activities
02
06
Personal Trading Rules
Reporting Requirements & Certifications
03
07
Insider Trading Policy
Violations & Sanctions
04
08
Our Fiduciary Duty
TradersAI owes a fiduciary duty to its client, Tidal Investments. Every Access Person must uphold this duty.
Client First
Loyalty & Honesty
Full Disclosure
Comply with Law
Place client interests ahead of the Firm's. You may not benefit at the expense of advisory clients.
Act with care, loyalty, and good faith. Avoid activities that conflict — or appear to conflict — with client interests.
Do not withhold material information. Disclose any personal interest in securities you are recommending.
Abide by the Advisers Act, 1940 Act, SEC Rules 204A-1 and 17j-1, and this Code of Ethics at all times.
⚠ When in doubt, ask the CCO — Dr. Ashok Margam — before acting.
Who Are Access Persons?
Definition
Currently Designated Access Persons
Any Associated Person who:
- Has access to nonpublic information about client securities purchases/sales
- Has access to nonpublic portfolio holdings of any reportable fund
- Makes securities recommendations to clients
- Has access to nonpublic recommendations
Dr. Ashok Margam
Chief Executive Officer Portfolio Manager Chief Compliance Officer (CCO)
Geetika Iyer
Assistant Portfolio Manager Director
Note: Household members of Access Persons are also subject to many Code provisions. Beneficial ownership extends to immediate family sharing the same household.
Presumption: All directors, officers & partners of TradersAI are Access Persons.
Personal Trading Rules – Key Restrictions
90-Day Hold (ETF)
7-Day Blackout Rule
Pre-Clearance Required
Any sub-advised ETF (HFSP) you purchase must be held for 90 days. Applies to you and household members.
No personal trading within 7 days before/after the Firm executes a client trade in the same security.
Most personal securities transactions require CCO approval before execution. Approval expires in 48 hours.
IPOs Prohibited
No Short Selling
No Investment Clubs
Access Persons and household members may never acquire securities in an Initial Public Offering.
Prohibited from short-selling any security held in a client portfolio.
Participation in investment clubs is prohibited for you and household members.
Restricted Security List: No one may trade a security on the list without prior CCO consent.
Pre-Clearance: What Requires Approval?
REQUIRES Pre-Clearance
EXEMPT from Pre-Clearance
- Most personal securities transactions (individual stocks, bonds, etc.)
- Limited offerings and private placements (submit request 1 week in advance)
- Option writing
- Sub-advised ETF (HFSP) purchases and sale
- Trustee position acceptance
- Individual equity securities ≥ 500 shares (even large-cap)
- Non-proprietary open-end mutual funds & ETFs (not managed by TradersAI)
- Broad-based index and commodity options & futures
- Fixed income < $100,000 over 30 days
- Individual equities (market cap ≥ $1B) up to 500 shares
- Discretionary accounts managed by independent third parties
- Automatic investment/withdrawal programs & auto rebalancing
- Bitcoin and Ether (not deemed securities)
Approved orders must be executed within 48 hours. After that, re-submit a new pre-clearance request.
Insider Trading — Strictly Prohibited
Trading on MNPI
Tipping
Front-Running
Trading in any account on the basis of Material Non-Public Information (MNPI) is prohibited — even if you received it by accident at a social event.
Communicating MNPI to anyone — inside or outside the Firm — in breach of a fiduciary duty is prohibited. You can become a 'tippee' even by overhearing a conversation.
Buying or selling a security for a personal account ahead of client transactions to profit from expected price movement ('scalping') is strictly prohibited.
Examples of Material Non-Public Information (MNPI)
Earnings / dividend announcements • Mergers & acquisitions • New product launches • Criminal or regulatory investigations Write-downs, debt problems, or bankruptcy • Stock repurchase / tender offers • Pending labor disputes • Research discoveries
MNPI must be secured. Do not discuss confidential information in elevators, restaurants, or other public places.
Gifts, Entertainment & Political Contributions
Gift & Entertainment Rules
Quick Reference
- De minimis threshold: $100 or less (per person per year) — no approval needed
- Occasional meals, sports/theater tickets also considered de minimis
- Giving a gift > $100 to a client or business partner requires written CCO pre-approval
- Cash gifts or cash equivalents are strictly prohibited — no exceptions
- Bribes and kickbacks are criminal acts — always prohibited
Meal with a vendor
Sports ticket (occasional)
Gift ≤ $100
Cash or gift cards
Gift > $100 (no approval)
Any political donation
Political Contributions — All Access Persons are Covered Associates
Bribe or kickback
- No political contributions to any candidate, officeholder, political party, or PAC
- This includes donations to political action committees (PACs) and inaugural/transition expenses
- Violation could bar TradersAI from advising government entities for 2 years (SEC Rule 206(4)-5)
Conflicts of Interest & Outside Business Activities
A conflict exists whenever personal interests interfere — or appear to interfere — with the Firm's or client's interests. Appearance matters as much as reality.
Prohibited Conflicts
Outside Business Activities
- Using knowledge of pending client trades to profit personally
- Recommending securities without disclosing personal interest in the issuer to the CCO
- Serving on a board of a public company without CCO approval
- Spreading false rumors about securities, funds, or the Firm
- All outside activities require prior CCO approval (submit email with details)
- Annual certification of outside business activities required (Appendix 2)
- Outside activity must never: create client confusion, damage Firm reputation, create a conflict, or use proprietary information
- Private company director? Must resign if company goes public during your term
Confidentiality: All client information — including identity, holdings, and advice — must be kept strictly confidential. No sharing with third parties without written authorization.
Reporting Requirements & Certifications
One-time + annual
Annual
Quarterly
Annual
Initial Account Report
Initial & Annual Holdings
Quarterly Transactions
Annual Code Certification
When:
When:
When:
When:
Within 10 days of becoming an Access Person
Within 10 days; then annually
Within 30 days after each quarter end
Annually
What:
What:
What:
What:
List all personal securities accounts (Appendix 4)
All reportable securities held — title, ticker, CUSIP, shares, custodian (Appendix 5). Must be current as of 45 days before submission.
All reportable securities transactions: date, security, price, broker, nature (buy/sell). Appendix 6 or brokerage statements.
Certify you have read, understood, and complied with the Code. Sign Appendix 1.
Missing a deadline is itself a Code violation and may result in disciplinary action. The reporting obligation is yours — the CCO's reminders do not relieve you of responsibility.
Violations, Reporting & Sanctions
How to Report a Violation
Examples of Violations to Report
- Report promptly to the CCO (Dr. Ashok Margam)
- If the CCO is involved or unreachable, report to Firm Management
- Anonymous reporting is permitted
- No retaliation for good-faith reporting — retaliation is itself a Code violation
- Whistleblower rights are preserved and not limited by this Code
- Noncompliance with laws, rules, or regulations
- Fraud or illegal acts in any aspect of Firm business
- Material misstatements in regulatory filings or client records
- Activity harmful to clients
- Deviations from required controls or procedures
Potential Sanctions (escalating severity)
Letter of Censure
Trade Reversal + Profit Disgorgement
Suspension or Termination of Employment
Referral to Law Enforcement or Regulatory Authorities
Both intentional and inadvertent violations may result in sanctions depending on severity and frequency.
Key Takeaways
You are a fiduciary. Client interests always come first.
Pre-clear most personal trades. When uncertain — ask the CCO first.
Never trade on MNPI. Stop, secure the information, and contact the CCO immediately.
Gifts > $100 require CCO approval. No cash gifts. No political contributions.
File your initial, annual, and quarterly reports on time. Late filing = Code violation.
Report violations promptly. Good-faith reporting is protected. Retaliation is prohibited.
Next Steps: Sign Appendix 1 Certification • Submit Appendix 4 (Account) & Appendix 5 (Holdings) within 10 days • Questions → CCO
TradersAI_Ethics_TrainingV1.pptx
Mounaraga Annavaram
Created on June 25, 2026
Start designing with a free template
Discover more than 1500 professional designs like these:
View
Essential Business Proposal
View
Project Roadmap Timeline
View
Step-by-Step Timeline: How to Develop an Idea
View
Artificial Intelligence History Timeline
View
Pictures quiz
View
Big Data: The Data That Drives the World
View
Mind Map: The 4 Pillars of Success
Explore all templates
Transcript
TRADERS A.I., INC.
Code of Ethics
Access Person Training
CRD # 331700 | SEC File No. 801-130642 Effective: July 10, 2024 | Confidential
By the end of this training, Access Persons will understand their obligations under the Code of Ethics, including personal trading rules, reporting requirements, and prohibited conduct.
Today's Agenda
Who We Are & Our Fiduciary Duty
Gifts, Entertainment & Political Contributions
01
05
Who Are Access Persons?
Conflicts of Interest & Outside Activities
02
06
Personal Trading Rules
Reporting Requirements & Certifications
03
07
Insider Trading Policy
Violations & Sanctions
04
08
Our Fiduciary Duty
TradersAI owes a fiduciary duty to its client, Tidal Investments. Every Access Person must uphold this duty.
Client First
Loyalty & Honesty
Full Disclosure
Comply with Law
Place client interests ahead of the Firm's. You may not benefit at the expense of advisory clients.
Act with care, loyalty, and good faith. Avoid activities that conflict — or appear to conflict — with client interests.
Do not withhold material information. Disclose any personal interest in securities you are recommending.
Abide by the Advisers Act, 1940 Act, SEC Rules 204A-1 and 17j-1, and this Code of Ethics at all times.
⚠ When in doubt, ask the CCO — Dr. Ashok Margam — before acting.
Who Are Access Persons?
Definition
Currently Designated Access Persons
Any Associated Person who:
Dr. Ashok Margam
Chief Executive Officer Portfolio Manager Chief Compliance Officer (CCO)
Geetika Iyer
Assistant Portfolio Manager Director
Note: Household members of Access Persons are also subject to many Code provisions. Beneficial ownership extends to immediate family sharing the same household.
Presumption: All directors, officers & partners of TradersAI are Access Persons.
Personal Trading Rules – Key Restrictions
90-Day Hold (ETF)
7-Day Blackout Rule
Pre-Clearance Required
Any sub-advised ETF (HFSP) you purchase must be held for 90 days. Applies to you and household members.
No personal trading within 7 days before/after the Firm executes a client trade in the same security.
Most personal securities transactions require CCO approval before execution. Approval expires in 48 hours.
IPOs Prohibited
No Short Selling
No Investment Clubs
Access Persons and household members may never acquire securities in an Initial Public Offering.
Prohibited from short-selling any security held in a client portfolio.
Participation in investment clubs is prohibited for you and household members.
Restricted Security List: No one may trade a security on the list without prior CCO consent.
Pre-Clearance: What Requires Approval?
REQUIRES Pre-Clearance
EXEMPT from Pre-Clearance
Approved orders must be executed within 48 hours. After that, re-submit a new pre-clearance request.
Insider Trading — Strictly Prohibited
Trading on MNPI
Tipping
Front-Running
Trading in any account on the basis of Material Non-Public Information (MNPI) is prohibited — even if you received it by accident at a social event.
Communicating MNPI to anyone — inside or outside the Firm — in breach of a fiduciary duty is prohibited. You can become a 'tippee' even by overhearing a conversation.
Buying or selling a security for a personal account ahead of client transactions to profit from expected price movement ('scalping') is strictly prohibited.
Examples of Material Non-Public Information (MNPI)
Earnings / dividend announcements • Mergers & acquisitions • New product launches • Criminal or regulatory investigations Write-downs, debt problems, or bankruptcy • Stock repurchase / tender offers • Pending labor disputes • Research discoveries
MNPI must be secured. Do not discuss confidential information in elevators, restaurants, or other public places.
Gifts, Entertainment & Political Contributions
Gift & Entertainment Rules
Quick Reference
Meal with a vendor
Sports ticket (occasional)
Gift ≤ $100
Cash or gift cards
Gift > $100 (no approval)
Any political donation
Political Contributions — All Access Persons are Covered Associates
Bribe or kickback
Conflicts of Interest & Outside Business Activities
A conflict exists whenever personal interests interfere — or appear to interfere — with the Firm's or client's interests. Appearance matters as much as reality.
Prohibited Conflicts
Outside Business Activities
Confidentiality: All client information — including identity, holdings, and advice — must be kept strictly confidential. No sharing with third parties without written authorization.
Reporting Requirements & Certifications
One-time + annual
Annual
Quarterly
Annual
Initial Account Report
Initial & Annual Holdings
Quarterly Transactions
Annual Code Certification
When:
When:
When:
When:
Within 10 days of becoming an Access Person
Within 10 days; then annually
Within 30 days after each quarter end
Annually
What:
What:
What:
What:
List all personal securities accounts (Appendix 4)
All reportable securities held — title, ticker, CUSIP, shares, custodian (Appendix 5). Must be current as of 45 days before submission.
All reportable securities transactions: date, security, price, broker, nature (buy/sell). Appendix 6 or brokerage statements.
Certify you have read, understood, and complied with the Code. Sign Appendix 1.
Missing a deadline is itself a Code violation and may result in disciplinary action. The reporting obligation is yours — the CCO's reminders do not relieve you of responsibility.
Violations, Reporting & Sanctions
How to Report a Violation
Examples of Violations to Report
Potential Sanctions (escalating severity)
Letter of Censure
Trade Reversal + Profit Disgorgement
Suspension or Termination of Employment
Referral to Law Enforcement or Regulatory Authorities
Both intentional and inadvertent violations may result in sanctions depending on severity and frequency.
Key Takeaways
You are a fiduciary. Client interests always come first.
Pre-clear most personal trades. When uncertain — ask the CCO first.
Never trade on MNPI. Stop, secure the information, and contact the CCO immediately.
Gifts > $100 require CCO approval. No cash gifts. No political contributions.
File your initial, annual, and quarterly reports on time. Late filing = Code violation.
Report violations promptly. Good-faith reporting is protected. Retaliation is prohibited.
Next Steps: Sign Appendix 1 Certification • Submit Appendix 4 (Account) & Appendix 5 (Holdings) within 10 days • Questions → CCO