Code of Ethics
The standards of conduct expected of every officer, director, employee, contractor, and affiliated person of MajorWave, reflecting the firm's duty to act in the best interests of its limited partners.
- Policy Owner
- Chief Compliance Officer
- Approving Body
- Board of Directors
- Effective Date
- January 1, 2026
- Last Reviewed
- June 1, 2026
- Next Review
- January 1, 2027
- Version
- 1.0
Purpose
The Code of Ethics establishes the standards of conduct expected of every officer, director, employee, contractor, and affiliated person of MajorWave and its managed funds. The Code reflects the firm's fundamental duty to act in the best interests of its limited partners and to place limited partner interests ahead of the firm's and its personnel's interests in every material respect.
Scope
This Code applies to all Personnel, defined as all officers, directors, partners, employees, contractors, secondees, and persons designated as Access Persons under the Investment Advisers Act of 1940. The Code applies to conduct on the firm's behalf and to personal conduct that could reasonably be expected to reflect on the firm.
Fiduciary Standard
Every Person subject to this Code owes a fiduciary duty to the funds and to the limited partners. This duty includes the duty of loyalty, the duty of care, the duty of good faith, the duty of confidentiality, and the duty of full and fair disclosure of all material facts.
Personal Trading
All Access Persons must submit initial and annual holdings reports, quarterly transaction reports, and pre-clearance requests for any transaction in a reportable security. A blackout window applies around firm and portfolio-company transactions. Prohibited transactions include initial public offerings, private placements without pre-clearance, and any transaction in an issuer subject to a firm restricted list.
Gifts, Entertainment, and Political Contributions
Personnel may not accept or offer gifts, entertainment, or hospitality that could reasonably be perceived to influence a business decision. All gifts and entertainment in excess of the de minimis threshold require pre-clearance from Compliance. Political contributions by covered persons are subject to the firm's Pay-to-Play Policy and must be pre-cleared.
Outside Activities and Conflicts
All outside business activities, board seats, and material personal interests must be disclosed to Compliance and, where a conflict is identified, mitigated in accordance with the Conflicts of Interest Policy.
Confidentiality and Material Non-Public Information
All Personnel are custodians of the firm's, portfolio companies', and limited partners' confidential information. Any material non-public information must be handled in accordance with the firm's Insider Trading procedures and applicable law.
Reporting Violations
Every Person subject to this Code has an affirmative obligation to report suspected violations of this Code, applicable law, or firm policy. Reports may be made to Compliance, Legal, Internal Audit, or the Audit Committee Chair, or anonymously through the channels described in the Whistleblower Policy. Retaliation is prohibited.
Sanctions
Violations of this Code are subject to disciplinary action up to and including termination of employment, clawback of compensation, and referral to regulatory or law-enforcement authorities where appropriate.
Annual Certification
Every Person subject to this Code shall certify annually that they have received, read, and understood the Code, that they have complied with the Code, and that they will continue to comply with the Code.