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EXHIBIT 12(a)(1)
CLOUGH GLOBAL ALLOCATION FUND
CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND FINANCIAL OFFICERS
I. PURPOSE OF THE CODE
The Clough Global Allocation Fund (the "Fund") code of ethics (this
"Code") is intended to serve as the code of ethics described in Section 406 of
the Sarbanes-Oxley Act of 2002 and Item 2 of Form N-CSR. This Code shall be the
sole code of ethics adopted by the Fund for purposes of Section 406 of the
Sarbanes-Oxley Act and the rules and forms applicable to registered investment
companies thereunder. Insofar as other policies or procedures of the Fund, the
Fund's adviser, principal underwriter, or other service providers govern or
purport to govern the behavior or activities of the Covered Officers, as defined
herein, who are subject to this Code, they are superseded by this Code to the
extent that they overlap or conflict with the provisions of this Code. The
Fund's and its investment adviser's, and principal underwriter's codes of ethics
pursuant to Rule 17j-1 under the Investment Company Act of 1940 (the "1940 Act")
are separate requirements applying to the Covered Officers and others, and are
not part of this Code.
All Covered Officers must become familiar and fully comply with this
Code. Because this Code cannot and does not cover every applicable law or
provide answers to all questions that might arise, all Covered Officers are
expected to use common sense about what is right and wrong, including a sense of
when it is proper to seek guidance from others on the appropriate course of
conduct.
The purpose of this Code is to set standards for the Covered Officers
that are reasonably designed to deter wrongdoing and to promote:
- honest and ethical conduct, including the ethical handling of
actual or apparent conflicts of interest between personal and
professional relationships;
- full, fair, accurate, timely, and understandable disclosure in
reports and documents that the Fund files with, or submits to,
the Securities and Exchange Commission (the "SEC") and in any
other public communications by the Fund;
- compliance with applicable governmental laws, rules and
regulations;
- the prompt internal reporting of violations of the Code to the
appropriate persons as set forth in the Code; and
- accountability for adherence to the Code.
II. COVERED PERSONS
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This Code applies to the Fund's Principal Executive Officers and
Principal Financial Officers, or any persons performing similar functions on
behalf of the Fund (the "Covered Officers"). Each Covered Person should adhere
to a high standard of business ethics and should be sensitive to situations that
may give rise to actual as well as apparent conflicts of interest. Covered
Officers are expected to act in accordance with the standards set forth in this
Code.
2. HONEST AND ETHICAL CONDUCT
A. HONESTY, DILIGENCE AND PROFESSIONAL RESPONSIBILITY
Covered Officers are expected to observe both the form and the spirit
of the ethical principles contained in this Code. Covered Officers must perform
their duties and responsibilities for the Fund:
- with honesty, diligence, and a commitment to professional and
ethical responsibility;
- carefully, thoroughly and in a timely manner; and
- in conformity with applicable professional and technical
standards.
Covered Officers who are certified public accountants are expected to
carry out their duties and responsibilities in a manner consistent with the
principles governing the accounting profession, including any guidelines or
principles issued by the Public Company Accounting Oversight Board or the
American Institute of Certified Public Accountants from time to time.
B. OBJECTIVITY/AVOIDANCE OF UNDISCLOSED CONFLICTS OF INTEREST
Covered Officers are expected to maintain objectivity and avoid
undisclosed conflicts of interest. In the performance of their duties and
responsibilities for the Fund, Covered Officers must not subordinate their
judgment to personal gain and advantage, or be unduly influenced by their own
interests or by the interests of others. Covered Officers must avoid
participation in any activity or relationship that constitutes a conflict of
interest unless that conflict has been completely disclosed to affected parties
and waived by the Trustees on behalf of the Fund. Further, Covered Officers
should avoid participation in any activity or relationship that could create the
appearance of a conflict of interest.
A conflict of interest would generally arise if, for instance, a
Covered Officer directly or indirectly participates in any investment, interest,
association, activity or relationship that may impair or appear to impair the
Covered Officer's objectivity or interfere with the interests of, or the Covered
Officer's service to, the Fund.
Any Covered Officer who may be involved in a situation or activity that
might be a conflict of interest or give the appearance of a conflict of interest
must report such situation or activity using the reporting procedures set forth
in Section VI of this Code.
Each Covered Officer must not:
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- - use his or her personal influence or personal relationships improperly
to influence investment decisions or financial reporting by the Fund
whereby the Covered Officer would benefit personally to the detriment
of the Fund;
- - cause the Fund to take action, or fail to take actions, for the
individual personal benefit of the Covered Officer rather than the
benefit of the Fund; or
- - use material non-public knowledge of portfolio transactions made or
contemplated for the Fund to trade personally or cause others to trade
personally in contemplation of the market effect of such transactions.
Each Covered Officer is responsible for his or her compliance with this
conflict of interest policy.
C. PREPARATION OF FINANCIAL STATEMENTS
Covered Officers must not knowingly make any misrepresentations
regarding the Fund's financial statements or any facts in the preparation of the
Fund's financial statements, and must comply with all applicable laws,
standards, principles, guidelines, rules and regulations in the preparation of
the Fund's financial statements. This section is intended to prohibit:
- making, or permitting or directing another to make, materially
false or misleading entries in the Fund's financial statements or
records;
- failing to correct the Fund's financial statements or records
that are materially false or misleading when he or she has the
authority to record an entry; and
- signing, or permitting or directing another to sign, a document
containing materially false or misleading financial information.
Covered Officers must be scrupulous in their application of generally
accepted accounting principles. No Covered Officer may (i) express an opinion or
state affirmatively that the financial statements or other financial data of the
Fund are presented in conformity with generally accepted accounting principles,
or (ii) state that he or she is not aware of any material modifications that
should be made to such statements or data in order for them to be in conformity
with generally accepted accounting principles, if such statements or data
contain any departure from generally accepted accounting principles then in
effect in the United States.
Covered Officers must follow the laws, standards, principles,
guidelines, rules and regulations established by all applicable governmental
bodies, commissions or other regulatory agencies in the preparation of financial
statements, records and related information. If a Covered Officer prepares
financial statements, records or related information for purposes of reporting
to such bodies, commissions or regulatory agencies, the Covered Officer must
follow the requirements of such organizations in addition to generally accepted
accounting principles.
If a Covered Officer and his or her supervisor have a disagreement or
dispute relating to the preparation of financial statements or the recording of
transactions, the Covered Officer should take the following steps to ensure that
the situation does not constitute an impermissible subordination of judgment:
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- The Covered Officer should consider whether (i) the entry or the
failure to record a transaction in the records, or (ii) the
financial statement presentation or the nature or omission of
disclosure in the financial statements, as proposed by the
supervisor, represents the use of an acceptable alternative and
does not materially misrepresent the facts or result in an
omission of a material fact. If, after appropriate research or
consultation, the Covered Officer concludes that the matter has
authoritative support and/or does not result in a material
misrepresentation, the Covered Officer need do nothing further.
- If the Covered Officer concludes that the financial statements or
records could be materially misstated as a result of the
supervisor's determination, the Covered Officer should follow the
reporting procedures set forth in Section VI of this Code.
D. OBLIGATIONS TO THE INDEPENDENT AUDITOR OF THE FUND
In dealing with the Fund's independent auditor, Covered Officers must
be candid and not knowingly misrepresent facts or knowingly fail to disclose
material facts, and must respond to specific inquiries and requests by the
Fund's independent auditor.
Covered Officers must not take any action, or direct any person to take
any action, to fraudulently influence, coerce, manipulate or mislead the Fund's
independent auditor in the performance of an audit of the Fund's financial
statements for the purpose of rendering such financial statements materially
misleading.
3. FULL, FAIR, ACCURATE, TIMELY AND UNDERSTANDABLE DISCLOSURE
It is the Fund's policy to provide full, fair, accurate, timely, and
understandable disclosure in reports and documents that the Fund files with, or
submits to, the SEC and in any other public communications by the Fund. The Fund
has designed and implemented Disclosure Controls and Procedures to carry out
this policy.
Covered Officers are expected to familiarize themselves with the
disclosure requirements generally applicable to the Fund, and to use their best
efforts to promote, facilitate, and prepare full, fair, accurate, timely, and
understandable disclosure in all reports and documents that the Fund files with,
or submits to, the SEC and in any other public communications by the Fund.
Covered Officers must review the Fund's Disclosure Controls and
Procedures to ensure they are aware of and carry out their duties and
responsibilities in accordance with the Disclosure Controls and Procedures and
the disclosure obligations of the Fund. Covered Officers are responsible for
monitoring the integrity and effectiveness of the Fund's Disclosure Controls and
Procedures.
4. COMPLIANCE WITH APPLICABLE LAWS, RULES AND REGULATIONS
Covered Officers are expected to know, respect and comply with all
laws, rules and regulations applicable to the conduct of the Fund's business. If
a Covered Officer is in doubt about the legality or propriety of an action,
business practice or policy, the Covered Officer should seek advice from the
Covered Officer's supervisor or the Fund's legal counsel.
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In the performance of their work, Covered Officers must not knowingly
be a party to any illegal activity or engage in acts that are discreditable to
the Fund.
Covered Officers are expected to promote the Fund's compliance with
applicable laws, rules and regulations. To promote such compliance, Covered
Officers may establish and maintain mechanisms to educate employees carrying out
the finance and compliance functions of the Fund about any applicable laws,
rules or regulations that affect the operation of the finance and compliance
functions and the Fund generally.
5. REPORTING AND ACCOUNTABILITY
All Covered Officers will be held accountable for adherence to this
Code. Each Covered Officer must, upon the Fund's adoption of this Code (or
thereafter as applicable, upon becoming a Covered Officer), affirm in writing to
the Board that he/she has received, read, and understands this Code by signing
the Acknowledgement Form attached hereto as Appendix A. Thereafter, each Covered
Officer, on an annual basis, must affirm to the Board that he/she has complied
with the requirements of this Code.
Covered Officers may not retaliate against any other Covered Officer of
the Fund or their affiliated persons for reports of potential violations that
are made in good faith.
The Fund will follow these procedures in investigating and enforcing
this Code:
A. Any Covered Officer who knows of any violation of this Code or
who questions whether a situation, activity or practice is
acceptable must immediately report such practice to the Fund's
Audit Committee. The Audit Committee shall take appropriate
action to investigate any reported potential violations. If,
after such investigation, the Audit Committee believes that no
violation has occurred, the Audit Committee is not required to
take any further action. Any matter that the Audit Committee
believes is a violation will be reported to the Chairman of the
Board of Trustees. The Audit Committee shall respond to the
Covered Officer within a reasonable period of time.
B. If the Covered Officer is not satisfied with the response of the
Audit Committee, the Covered Officer shall report the matter to
the Chairman of the Board of Trustees. If the Chairman is
unavailable, the Covered Officer may report the matter to any
other member of the Board of Trustees. The person receiving the
report shall consider the matter, refer it to the full Board of
Trustees if he or she deems appropriate, and respond to the
Covered Officer within a reasonable amount of time. If the Board
of Trustees concurs that a violation has occurred, it will
consider appropriate action, which may include review of and
appropriate modifications to applicable policies and procedures
or notification to appropriate personnel of the investment
adviser or its board.
C. If the Board of Trustees determines that a Covered Officer
violated this Code, failed to report a known or suspected
violation of this Code, or provided intentionally false or
malicious information in connection with an alleged violation of
this Code, the Board of Trustees may take disciplinary action
against any such Covered Officer to the extent the Board of
Trustees deems appropriate. No Covered Officer will be
disciplined for reporting a concern in good faith.
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To the extent possible and as allowed by law, reports will be treated
as confidential. The Fund may report violations of the law to the appropriate
authorities.
6. DISCLOSURE OF THIS CODE
This Code shall be disclosed to the public by at least one of the
following methods in the manner prescribed by the SEC, unless otherwise required
by law:
- Filing a copy of this Code as an exhibit to the Fund's annual
report on Form N-CSR;
- Posting the text of this Code on the Fund's Internet website and
disclosing, in its most recent report on Form N-CSR, its Internet
address and the fact that it has posted this Code on its Internet
website; or
- Providing an undertaking in the Fund's most recent report on Form
N-CSR to provide a copy of this Code to any person without charge
upon request, and explaining the manner in which such a request
may be made.
7. WAIVERS
Any waiver of this Code, including an implicit waiver, granted to a
Covered Officer may be made only by the Board of Trustees or a committee of the
Board to which such responsibility has been delegated, and must be disclosed by
the Fund in the manner prescribed by law and as set forth above in Section VII
(Disclosure of this Code).
8. AMENDMENTS
This Code may be amended by the affirmative vote of a majority of the
Board of Trustees, including a majority of the independent Trustees. Any
amendment of this Code must be disclosed by the Fund in the manner prescribed by
law and as set forth above in Section VII (Disclosure of this Code), unless such
amendment is deemed to be technical, administrative, or otherwise
non-substantive. Any amendments to this Code will be provided to the Covered
Officers.
9. CONFIDENTIALITY
All reports and records prepared or maintained pursuant to this Code
will be considered confidential and shall be maintained and protected
accordingly. Except as otherwise required by law or this Code, such matters
shall not be disclosed to anyone other than the Board of Trustees of the Fund,
the Audit Committee, the legal counsel to the Fund, legal counsel to the
independent trustees and such other persons as a majority of the Board of
Trustees, including a majority of the independent Trustees, shall determine to
be appropriate.
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APPENDIX A
CLOUGH GLOBAL ALLOCATION FUND
Certification and Acknowledgment of Receipt of Code of Ethics for Principal
Executive Officers and Principal Financial Officers
I acknowledge and certify that I have received a copy of the Clough Global
Allocation Fund's Code of Ethics for Principal Executive Officers and Principal
Financial Officers (the "Code"). I understand and agree that it is my
responsibility to read and familiarize myself with the policies and procedures
contained in the Code and to abide by those policies and procedures.
I acknowledge and certify that I have read and understand the Code.
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Officer Name (Please Print) Officer Signature
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Date
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