Corvus Financial
Code of Ethics
1. Statement of General Principles
Corvus Financial (“Corvus,” the “Firm,” “we,” or “us”) is a fee-only investment adviser that provides financial planning and investment advisory services, with a specialization in equity compensation and concentration-risk planning for clients in the technology industry. As a fiduciary, Corvus owes each client a duty of undivided loyalty and utmost good faith, and must act at all times in the best interest of its clients, placing client interests ahead of the interests of the Firm.
This Code of Ethics sets the standard of business conduct that Corvus and every Supervised Person must follow, built on the principle that Corvus owes clients fiduciary duties including care, loyalty, honesty, and good faith. All Supervised Persons must comply with applicable federal and Texas securities laws.
2. Standards of Business Conduct
Corvus places client interests first, exercises independent judgment free from conflicting interests, and discloses any conflict that could reasonably impair that judgment. Corvus does not accept custody of client funds or securities and does not exercise discretionary trading authority — clients implement advice in accounts they own and control at their own qualified custodians. Corvus is compensated exclusively through client-paid fees and does not accept commissions, referral fees, or performance-based compensation.
3. Confidentiality of Client Information
Supervised Persons keep confidential all information concerning clients’ security holdings, financial circumstances, and other nonpublic personal information, except as required to serve the client or as required by law.
4. Personal Securities Transactions and Reporting
Supervised Persons report personal securities holdings and transactions on an ongoing basis and must obtain prior approval before acquiring securities in an initial public offering or private placement — a heightened-conflict category given Corvus’s work with clients’ own equity and liquidity events.
5. Prohibition on Insider Trading
No Supervised Person may trade, or cause others to trade, while in possession of material nonpublic information about a security or issuer. This is especially relevant given Corvus’s work with clients who hold equity in their employers and may from time to time possess material nonpublic information about them.
6. Gifts, Entertainment, and Outside Business Activities
Supervised Persons may not accept gifts beyond nominal value from parties doing business with Corvus, and any outside business activity must be disclosed and must not create an undisclosed conflict with client interests.
7. Identifying and Managing Conflicts of Interest
Corvus identifies, discloses, and mitigates conflicts of interest as they arise, including those related to outside employment, asset-based fees, and personal investing.
8. Reporting Violations
Any violation or suspected violation of this Code is documented and addressed as part of Corvus’s annual compliance review, conducted with outside compliance counsel.
9. Sanctions
Violations may result in remedial action appropriate to the severity of the violation.
10. Acknowledgment and Recordkeeping
Corvus maintains records related to this Code, including personal trading reports and any violations, for at least five years, consistent with SEC and Texas recordkeeping requirements. A complete copy of this Code of Ethics is available upon request.