The purpose of this Code is to deter wrongdoing and to promote: (i) honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships, (ii) full, fair, accurate, timely and understandable disclosure in our regulatory reporting and other public communications, (iii) compliance with applicable laws, rules and regulations, (iv) prompt internal reporting of violations of the code to appropriate persons identified in the code and (v) accountability for adherence to the code.
Our business depends on the quality of the Company’s reputation and in turn on all of us to exhibit integrity and engage only in principled business conduct. Thus, in many instances, the policies referenced in this Code go beyond the requirements of the law.
Standards of Conduct. Central to this Code is the concept that Starwood and its Advisory Representatives owe fiduciary duties to Starwood’s advisory clients. These duties are created by underlying principles of the securities laws and the relationship of trust presumed between the Company and its advisory clients. As fiduciaries, Advisory Representatives must conduct themselves with honesty and integrity, bearing in mind that their conduct reflects on the Company’s reputation. Advisory Representatives must refrain from any activity that places or appears to place their interests ahead of the interests of the Company’s advisory clients. Advisory Representatives must observe ethical standards of honesty and integrity and comply with the Advisers Act, as well as other provisions of the federal securities laws pertaining to their conduct and the Company’s business.