Firm Policy

The firm’s CCO shall be responsible for handling the hiring, registration if required, and training of IARs and unregistered employees.

Hiring

The firm’s CCO will:

• Conduct background checks and due diligence to ensure new advisers will not pose compliance or regulatory problems;
• Verify whether or not the activities of new hires will require registration as “IARs” in any jurisdiction;
• Verify whether or not the activities of new hires will require them to be considered access persons for compliance with personal securities transactions requirements;
• Review outside business activities of new hires; and
• Collect attestations from new hires that they have read and will abide by CP’s Policies and Procedures Manual, Code of Ethics, Privacy Policy and any applicable corporate policies.

Registration

If the CCO determines that IAR registration is required, the following steps will be taken:

• Determine the submission requirements for registration, which may include depending on jurisdiction:
• Reviewing the Form U4 and submitting it to the IARD system in order to request registration;
• Create a Form ADV Part 2B Supplement; and
• Ensure the new hire does not engage in activity that would require registration until such time that the individual’s IAR registration is approved.

The CCO will continually monitor the activities of unregistered employees to ensure they do not engage in any activity that would require registration as an IAR.

Training

Ongoing training for unregistered employees and IARs may be provided by the CCO. Ongoing training may include but is not limited to topics relating to: CP’s Policies and Procedures and Code of Ethics, privacy issues, services offered by the firm or general compliance topics.