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Interested Fund Trustee means the trustees of the Carillon Funds who are interested In addition to the provisions applicable to all Carillon Employees promptly review, and either approve or disapprove, in writing, each request of an employee for clearance to meeting, information relating to the violation and any sanctions imposed. on a transaction in Securities, including, but not limited to, all joint accounts, partnerships, and trusts. Regarding IPO Allocations which is attached as (Appendix 5) to this Code. coordinate the review of such reports with other appropriate employees of Eagle Asset Management, Inc. Authorizations provided by the Pre-Clearance Officer for personal Carillon Tower Advisers, Inc., is an investment adviser registered with the U.S. Securities and Exchange Commission (SEC). duty arises only where there is a fiduciary relationship. securities of a company about which you may have potential inside information, ask yourself the following questions: Is the information material? Employees and Carillon Access Persons are encouraged to address particular circumstances that are unclear with the CCO. The Code of Ethics Review Committee (the Committee) is charged with the responsibility of conducting informal hearings, assessing I do not have a beneficial ownership in any account(s) with any financial services firm. Head of Investment Insights and Development, JOY FACOS subsequent market movements or based upon any factors or guidelines not articulated in the applicable compliance policies and applicable disclosures. This Code may be amended from time to time by the CCO. Such affiliations include directorships, other business activities This Domestic for Profit company is located at 880 Carillon Parkway, St. Petersburg, FL, 33716, US and has been running for nineteen years. I made no political contributions in the past year. Securities Transaction means a purchase or sale of Securities. The following transactions are prohibited: No Carillon Employee shall open a brokerage account (or one in which they hold a beneficial interest or trading Monetary policymakers really do not have an easy job these days. BrokerCheck - Find a broker, investment or financial advisor has access to such recommendations that are nonpublic. you have any questions you should consult the Compliance Department or CCO. nonpublic information to others in violation of the law. Carillon Tower Advisers Inc Email Formats and Examples Accordingly, it is unlawful for such I maintain the following directorships, other business activities or investments in securities that cannot ordinarily be made through I fully understand the provisions of the Codes as described therein and agree to abide by them. investment decisions. Carillon Fund Distributors, Inc. , Member FINRA 3TY +). Was founded on May 11, 2005 with identification number P05000069969 based on 880 Carillon Parkway, St. Petersburg, FL33716. read and understands this Code of Ethics by executing the Initial Holdings Report set forth as Appendix 4. To detect insider trading, the Chief Compliance Officer or his designee, should: review the trading activity reports filed by each employee. President, Raymond James Investment Management, MIKE EDWARDS personal investments and outside business affiliations, should be directed to the Compliance Department. The concept of insider is broad. refrain from trading. stock obtained through an employee stock purchase plan. I do not have any affiliated Fund holdings other than what is held in my Raymond James 401k plan and/or Raymond James affiliated Is the information nonpublic? Raymond James Investment Management is the trade name for Carillon Tower Advisers, Inc., an investment adviser registered with the U.S. Securities and Exchange Commission (SEC). PROCEDURES TO IMPLEMENT CARILLON INVESTMENT ADVISERS POLICY, Procedures to Implement Carillon Investment Advisers Policy against Insider Trading. Head of Corporate Development and Strategy, MATT ORTON, CFA PDF Carillon Mutual Funds Advisory Clients of Carillon. Carillon Fund Distributors, Inc. in Saint Petersburg, FL - (800) 237-3101 also called a broker-dealer, is in the business of buying and selling securities - stocks, bonds, mutual funds, and certain other investment products - on behalf of its customer (as broker . Raymond James Investment Management is a global asset-management company that combines the exceptional insight and agility of individual investment teams with the strength and stability of a full-service firm. Outside Business Affiliations/Directorships. You may attach a copy of your most recent statement and then complete any information that is not included on the statement in the chart below. Within 30 days of their hire date, each newly-hired Carillon Employee and Carillon Access Person shall certify that he or she has received, Every Carillon Access Person must arrange for the Compliance Department to receive directly from the broker, dealer, mutual fund company, or and investments in securities that cannot ordinarily be made through an RJF affiliated (Raymond James& Associates, Inc. or Raymond James Financial Services, Inc. brokerage account) (i.e., a private placement or a limited partnership). exclusively in unaffiliated mutual funds; securities which are not eligible for purchase or sale by an investment company or other investment advisory clients; other Securities that may from time to time be designated in writing by the Code of Ethics Review Committee on No Carillon Employee shall purchase or sell a Security (see exceptions noted below in Section V Pre-Clearance Requirements) on any day during which that Carillon Employee has knowledge that an Advisory Client has a pending buy or sell order in the same Security (or an Equivalent Beneficial Interest means the opportunity to share, directly or indirectly, in any profit or loss Such directors must provide an annual certification that with respect to all security transactions during the . background:url(/-/media/rj/affiliate-sites/raymond-james-investment-management/about-us/our-firm-header.png); Somewhat stricter restrictions on certain activities and/or transactions apply to Carillon Access Persons due to their more direct involvement and greater influence on portfolio trading activities of Advisory Clients. Please contact the Compliance Department or the CCO if you have any questions about this Code or any other compliance-related matters. St, Petersburg, FL, March 11, 2021 (GLOBE NEWSWIRE) -- Carillon Tower Advisers ("Carillon"), a global, multi-boutique asset management firm, and its partner affiliate Reams Asset Management. larger IPO allocations by generating more commission business for brokers that provide access to IPOs. make the statements made to a Fund, in light of the circumstances under which they are made, not misleading; Engage in any act, practice, or course of business that operates or would operate as a fraud or deceit upon any Thus, it would be a violation of this Code for any Carillon Employee or Carillon Access Person to perform any act This The Committee also shall review the Code at least once a year, in light of legal and business developments and experience in implementing the Code. Carillon or Eagle. Before trading for yourself or others, including investment companies, separate accounts or private accounts managed by Carillon, in the Quarterly Transaction Reports / Duplicate Confirmations and Statements. Raymond James Investment Management is not responsible for the content of the website or the collection or use of information regarding the website's users and/or members. limited partnership interests, registered investment companies, investment contracts, and all derivative instruments, such as options and warrants. Head of Sustainable Investing and Corporate Responsibility, MATT SPERBER Raymond James or RJF includes Carillons parent company, Raymond James Financial, of the Code, provided they have no knowledge of pending or current EAM program trading activity in the securities they are trading. Limited Offering means a limited offering exempt from registration pursuant to Rules 504, 505 or comply with applicable laws and regulations. Portfolio managers and traders may not make IPO allocation decisions regarding client accounts based upon Any person who becomes a Carillon Access Person must submit, within 10 days of The information in the Initial Holdings Report must be current as of a date no more than 30 days prior to the selling the Security for a Carillon Fund. trade in specified securities. teams with the strength and stability of a full-service firm. No Carillon Employee shall conduct a transaction while in possession of inside material nonpublic All third-party marks are the property of their respective owners. CARILLON FUND DISTRIBUTORS, INC. CRD#: 139749 880 CARILLON PARKWAY ST. PETERSBURG, FL 33716 . No credit card required. CFD enters into selling agreements with affiliated and unaffiliated broker-dealers and other financial intermediaries to distribute and provide other services relative to the purchase of Carillon Mutual Fund shares. Carillon Fund Distributors Inc - Company Profile and News - Bloomberg Markets Bloomberg Connecting decision makers to a dynamic network of information, people and ideas, Bloomberg quickly and. procedures to this Code in order to provide additional assurance that the purposes of this Code are fulfilled and/or to assist the CCO in administration of the Code. holiday, job event - such as a promotion or retirement, life event - such as a wedding, or a business event - such as a conference, sports or cultural Any questions relating to the firms policies, including the requirement to seek pre-approval for Specific restrictions under this Code are based on the extent to which a person has access to investment-related data or has the ability to influence width: 100%. The following transactions are not subject to pre-clearance: After the initial pre-clearance, subsequent pre-clearance of a Carillon Fund is not required if such transaction is a part of an Automatic Investment Plan, automatic rebalancing or redemption plan (i.e. identifies any recommended changes in existing restrictions or procedures based on the experience under Carillon mutual funds may be offered only to persons in the United States and its territories, and by way of a prospectus. Hot IPOs generally may not be allocated to accounts where Carillon, its principals or its affiliates maintain an If approval is granted, the Carillon Employee must arrange to have periodic statements sent to the CCO or his designee. I fully understand the provisions of the Codes as described therein and agree to abide 5 . brokerage account(s). Retention of Records. including options, rights, warrants, preferred stock, restricted stock, bonds, and other obligations of that issuer. so-designated individual at CTA, EAM, CFD and/or the Funds (or that persons designee) as set forth in Appendix 2, as amended from time to time. (2)regulatory authorities who have appropriate jurisdiction with respect to such matters, or (3)third parties who utilize such information for ratings or performance analysis or who provide services pursuant to a written contract. a description of Carillons internal communications regarding insider trading, including the dates of such } 880 Carillon Parkway, St. Petersburg, FL 33716 Reams Asset Management is a division of Scout Investments. decision for an Advisory Client that the Carillon Access Person is recommending or participating in, the Carillon Access Person must disclose that interest to persons with authority to make investment decisions or to the CCO. Carillon Tower Advisers and Reams Asset Management Win 2021 U.S mitigating factors, and imposing sanctions consistent with the Codes Sanction Guidelines. Such affiliations include directorships, other business activities Securities Transaction is placed. (Misappropriated - properly come into contact with insider information and then improperly use information). If, after consideration of the above, you believe that the information is material and nonpublic, or if you have questions as to whether the For example, files containing material nonpublic information should be sealed; access to computer files containing material nonpublic 2023 Raymond James Investment Management All rights reserved. Carillon Fund Distributors, Inc. is in the Nondurable Goods, nec business. the $100 limit. and/or CFS and the Carillon Funds Boards of Trustees that: initially summarizes existing procedures concerning personal investing and, thereafter, any changes in margin-bottom: 0px; include, among others, a companys attorneys, accountants, consultants, bank lending officers, and the employees of such organizations. Access Persons, Sanctions applicable to Investment Personnel. All reports or information supplied will be order to establish rules of conduct for persons who are associated with CTA, EAM, CFD, CFS (collectively Carillon) and the Funds and in order to comply with Rule 17j-1 under the Investment Company establishes an Investment Account during the quarter must complete the required section pertaining to new accounts in the Quarterly Transaction Report. Restricted Securities Transactions. private accounts managed by Carillon. } should comply with applicable policies and procedures and should be consistent with information disclosed to clients. Gifts may not be part of a pattern of frequent giving. James Financial, Inc.). This Code applies to all Carillon Employees, Carillon any unresolved question as to the applicability or interpretation of the foregoing procedures, or as to the propriety of any action, it must be discussed with the Chief Compliance Officer before trading or communicating the information to anyone. Each confirmation or statement must Fund Independent Trustees should consult with their independent legal counsel with regard to any questions concerning their All persons subject to this Code, including Carillon Employees and Carillon Access persons, are subject to the general anti-fraud prohibitions Cougar Global Investments LLC is registered as a Portfolio Manager with the Ontario Securities Commission (OSC) and with the SEC as a Non-Resident Investment Advisor. and their subsidiaries including Carillon Fund Distributors, Inc. (CFD), affiliate Carillon Fund Services, Inc. (CFS) and those registered investment companies advised by EAM, Carillon Mutual Funds (the Funds), in Security) until that order is executed or withdrawn, unless the Carillon Employee provides an explanation of why the trade is necessary and provision is made for the Advisory Client trade to take precedence (in terms of price) over the Carillon nonpublic information to trade in securities (whether or not one is an insider) or to communications of material nonpublic information to others. bank in question, duplicate copies of each confirmation and periodic statement for any Securities Transaction during the quarter for which that Carillon Access Person is required to obtain pre-clearance. Advisers Act). Sanctions applicable to All Carillon violates this provision, then the Carillon Access Person must sell the position and must forfeit all profits on the transaction to a charitable organization designated by Carillon and/or CFD. Contrary Trades. CARILLON FUND DISTRIBUTORS, INC. - P05000069969 - Florida - B2BHint specific sanctions for failure to comply with the Code. I'm happy to share that I'm starting a new position as Global Head of Insurance Specialists at Allianz Global Investors! EAM, CFD and Carillon Tower Advisers logo materials (golf balls, etc.) All employees of Carillon shall be in compliance with the Carillon Code of Ethics Personal Security Transaction Guidelines. These records will be reviewed by Compliance and reported to the material nonpublic information that was stolen or misappropriated from any other person. width: 825px; Carillon Tower Advisers Inc Email Format | carillontower.com Emails Whalewisdom has at least 13 13F filings Summary Holdings Ind. the information is generally public. copies must be received no later than 15 business days after the end of the calendar quarter, or submit a Quarterly Transaction Report within 15 business days after the completion of each calendar quarter. are authorized by this Code. Reveal Latest update September 26, 2021 Location St Petersburg, Florida, United States Matthew's current employer Export Carillon Tower Advisers Website carillontower.com Industry Investment Management Number of employees 201-500 Description The CCO will arrange for a meeting of the Committee in cases where a violation of one or more applicable provisions of this Code has occurred and the Material information need not be derived directly from the company whose securities are at issue. 12 Years of Experience . Carillon Tower Advisers, Inc., Eagle Asset Management, Inc. and its subsidiaries Carillon Fund Distributors, Inc. (collectively Pre-Clearance Officer means the so-designated individual at Carillon (or that persons designee) as set forth in Appendix2 as amended from time to time. Carillon Fund Distributors serves as the underwriter and distributor of the Carillon Family of Funds and is a wholly owned subsidiary of Eagle Asset Management. All Carillon Employees (Including Immediate Family), Transactions in Carillon Mutual Fund and Mutual Funds subadvised by Eagle . Check the background on Carillon Fund Distributors, Inc . account(s), I have disclosed below the name of the Fund, account, relationship, shares owned and the account number for each. Securities Transaction for a reason that is confidential. SECTION I. member knows or has reasonable grounds to believe shall affect the market. including employees who serve as Fund officers, trustees or directors working in any CTA, EAM, CFD or CFS business unit (including sales staff or other personnel performing duties for Carillon, even if employed by another entity such as Raymond Our teams have exhibited strong absolute returns over cycles from a historical standpoint, as well as strong risk-adjusted returns. The following procedures have been established to aid the employees of Carillon in avoiding insider trading, and to aid While the law concerning insider trading is not static, it is generally understood that the law prohibits: Trading by an insider while in possession of material nonpublic information, or. an RJF affiliated brokerage account. Carillon Fund Distributors Inc - Company Profile and News Year End Distributions Record Date: 12/17/2020 EX Date: 12/18/2020 Payment Date: 12/21/2020 Fund Cusip Reinvest NAV Income Short-Term1 Long-Term Total Carillon ClariVest Capital Appreciation Fund - Class A 14214L106 50.63 0.054437 7.708250 7.762687 Carillon ClariVest Capital Appreciation Fund - Class C 14214L205 32.26 7.708250 7.708250 3 Firms . Exemptions from Pre-Clearance Requirements. Raymond James Investment Management is not responsible for the content of the website or the collection or use of information regarding the website's users and/or members. Registry number 20-2867072. Report the matter immediately to the Chief Compliance Officer. The initial set up of an Automatic Investment Plan, including any allocation methodology involving a Carillon This Report must be submitted to the Compliance Department within 15 business days after the In general no associate or third party acting on behalf Penalties can include jail and civil fines. Portfolio managers and traders should not engage in excessive trading or increase portfolio turnover in order to All six entities are affiliates of Raymond James Investment Management. To prevent insider trading, Chief Compliance Officer or his designee, should: provide, on a regular basis, communications to familiarize employees of Carillons policy and procedures. household as the employee; accounts in which the employee otherwise has a financial interest that allows the employee directly or indirectly to profit or share in any profit; a legal vehicle of which the employee is the controlling equity holder; If a Carillon Access Person or an Immediate Family member stands to materially benefit from an investment important in making his or her investment decisions, or information that is reasonably certain to have a substantial effect on the price of a companys securities. There are currently three active principals. After the Chief Compliance Officer has reviewed the issue, instructions will be provided about the next course the sale of that Security (or an Equivalent Security) by a Fund or sell a Security within 60 calendar days of the purchase of the Security (or an Equivalent Security) by a Fund if the transaction would result in a profit. (However, subject to best execution standards and appropriate disclosures in EAMs Form ADV registration statement and any applicable mutual fund registration statements, portfolio managers Employee or Carillon Access Person; any joint or tenant-in-common account in which the Carillon Employee or Carillon Access Person has a Beneficial Interest or is a .quote-text { completion of each calendar quarter unless the Annual Holdings Report is also being completed during that quarter. Any increase or decrease in the 2023 Raymond James Investment Management All rights reserved. In that case, a Wall Street Journal reporter The benefit does not have to be pecuniary, but can be a gift, a reputational benefit that will translate into future earnings, or even evidence of a relationship that suggests a quid To whom has this information been provided? Carillon Tower Advisers, Inc., is an investment adviser registered with the U.S. Securities and Exchange Commission (SEC). All those, as well as access to veteran independent investment teams, each with their own philosophy and process, are available through a single point of contact. Material Investigation means an investigation that leads to the imposition of a significant approved for trading by the appropriate federal authority (for example, options on the S&P 500 Index); Securities directly issued by the U.S. Government; Raymond James Financial, Inc. (RJF) stock; transactions in units of a unit investment trust (UIT) if the unit investment trust is invested List of Reportable Securities for Carillon Fund Independent Fund Trustees. Head of Advisory Solutions and Market Strategy, MATT JOHNSON are prohibited from causing or attempting to cause an Advisory Client to purchase, sell or hold any Security in a manner calculated to create any personal benefit to the Carillon Access Person. If not pro rata, allocations Please reference Eagles Anti-Bribery& Corruption policy for further details. Chartwell Investment Partners, ClariVest Asset Management LLC, Eagle Asset Management, Inc. and Scout Investments are registered investment advisers with the SEC. Additionally, the CCO may establish, in his or her discretion, certain supplemental authorization is granted (such as in the case of a limit order), a new request must be submitted. including the requirement to seek pre-approval for personal investments and outside business affiliations, should be directed to the Compliance Department. Persons to specific disciplinary action including termination, monetary penalties, criminal penalties and/or civil penalties, as outlined in this Code. Raymond James Investment Management is the trade name for Carillon Tower Advisers, Inc., an investment adviser registered with the U.S. Securities and Exchange Commission (SEC). Chartwell Investment Partners, ClariVest Asset Management LLC, Eagle Asset Management, Inc. and Scout Investments are registered investment advisers with the SEC. for legal, regulatory or business reasons as described in this section. purchase from certain brokers additional shares of an IPO in the immediate after-market trading in order to obtain larger IPO allocations. Carillon Fund Distributors, Inc. filed as a Domestic for Profit Corporation in the State of Florida on Wednesday, May 11, 2005 and is approximately seventeen years old, as recorded in documents filed with Florida Department of State. This is also known as the blackout period. Code of Ethics Review Committee to discuss any violations and any corresponding waivers. Inc. (RJF), and affiliated broker dealers of RJF including Raymond James& Associates, Inc. (RJA) and Raymond James Financial Services, Inc. (RJFS). PDF Carillon Funds Income Cap Gains Distributions Carillon Tower The Code also applies to any other account over which the Carillon Employee is deemed to have beneficial ownership. [last] (ex. The information may be available for inspection by the Trustees of the Carillon Funds, the President of EAM, President of CFD, the President of CFS, the Code of Ethics Review If you have any questions about these procedures you should consult the Compliance jackson national life distributors llc (crd#: 40178) :: 11/8/2010 - 8/23/2017 :: denver, co RedFlags, Allegations and Complaints against Leonid Nemanov Disclosure #1 for Leonid Nemanov Failure to provide the required data in a timely fashion will subject the Carillon Access Person to Carillon Fund Services, Inc. and Carillon Mutual Funds, which is included together with this document. Annual Holdings Report. accountants), or they can acquire a fiduciary duty to the companys shareholders as tippees if they are aware or should have been aware that they have been given confidential information by an insider who has violated his fiduciary Disclosures . transactions in RJF securities, including common stock. All third-party marks are the property of their respective owners. information given, a decision will be made as to whether to restrict the Carillon Access Persons participation in causing the Advisory Client to purchase or sell a Security in which the Carillon Access Person has an interest. Access Person has a direct or indirect Beneficial Interest (other than such accounts over which the Carillon Access Person has no investment discretion and cannot otherwise exercise control). The most common Carillon Tower Advisers Inc email format is [first]. Investment Personnel should not purchase or commit to Reams Asset Management is a division of Scout Investments. Fund; or. Written approval will be required to satisfy certain regulatory requirements. Has the obtain larger IPO allocations by generating more commission business for brokers that provide access to IPOs. trades of all Security Transactions authorizations are valid through the current trading session on which the authorization was sought or revoked by the Pre-Clearance Officer, which ever happens first. Leonid Nemanov at CARILLON FUND DISTRIBUTORS, INC. - View Complaints, Disclosures, Scams and Audit Report (Updated 2023) By The Dirt April 2, 2023 3 Mins Read. Board of Trustees of the Funds for approval. trading. whom they acquired the IPO shares. ClariVest Asset Management is the subadviser to certain of the funds and Eagle Asset Management owns 100% of ClariVest Asset Management. persons in connection with the purchase or sale, directly or indirectly, by the person of a Security held or to be acquired by the Fund to: Employ any device, scheme or artifice to defraud a Fund; Make any untrue statement of a material fact to a Fund or omit to state a material fact necessary in order to