Simpson Capital Management (SCM) is a “fiduciary” to its advisory clients. This means SCM has a fundamental obligation to act in the best interests of its clients and provide investment advice in its clients’ best interests. SCM owes its clients a duty of undivided loyalty and utmost good faith. The firm does not engage in any activity in conflict with the interest of any client and takes steps reasonably necessary to fulfill its obligations.
SCM employs reasonable care to avoid misleading clients and provides full and fair disclosure of all material facts to its clients and prospective clients. Generally, facts are “material” if a reasonable investor would consider them to be important. SCM seeks to eliminate, or at least disclose, all conflicts of interest which might incline the firm — consciously or unconsciously — to render advice which is not disinterested. SCM does not use its clients’ assets for its own benefit or the benefit of other clients, without client consent