Employee Personal Trading Program

Oyster will provide the firm with access to Protegent PTA Software and provide maintenance services, training and support related to the implementation of the software.

This software will facilitate the supervision and oversight of access persons of the firm including trade approvals, reviews, attestations, gift tracking and approval, and publishing of the Code of Ethics and other compliance policies. We will be a resource for the firm’s compliance program, providing expertise, support and working with the Firm’s senior management and staff to develop, implement and maintain procedures and software to maintain compliance with the Firm’s Code of Ethics. Oyster will assist in monitoring personal trading reviews, attestations, gift tracking, outside activity approvals and other compliance workflow related to the supervision and oversight of access persons. We will obtain key information from statements and confirmations if data feeds are not available.