Corporate Transparency

At Heartland, we are strong believers in transparency. We have thorough policies, procedures and oversight bodies in place for critical business functions, both in investment management and operations:

• Our Brokerage Committee reviews trade execution and allocation to ensure a fair and equitable process. They also review commissions paid in the context of research or other services provided for the benefit of our clients.
   
• We utilize a Pricing Committee charged with ensuring that valuations are consistent with our policies and procedures.
   
• Our Investment Policy Committee reviews portfolio and market risks, as well as operational and procedural risk.
   
• The Investment Management Team meets weekly to discuss various issues related to investment concepts, including cash management.
   
• We have implemented the Charles River Development (CRD) system for trade processing. The CRD system has one of the best compliance monitoring systems available for trade management. It enables us to review each trade prior to execution to ensure compliance.
   
• We share the following documents and policies openly on our website:
   
  • Business Conduct Rules and Code of Ethics
  • Proxy Voting Policy and Proxy Voting Records
  • Quarterly Portfolio Holdings
  • Statement of Additional Information (SAI)
    

We have a tendency to be conservative and to stay away from trend or fad type solutions, opting for time-tested methods that have proven their utility in both bull and bear markets.* However, we tend to be quick to embrace risk mitigation processes that can add value even if it is only during certain parts of a market cycle.

We take pride in our operational abilities and our commitment to serving our shareholders.

* Such activities or choices do not guarantee successful results.