HUMANITAS - Refinement, Learning, Culture, Civility

DIGNITAS - Dignity, a Sense of Self Worth and Pride.

GRAVITAS - Gravity, Knowing the Importance of the Matters at Hand.

PIETAS - Dutifulness, Piety, Devotion, Respect for the Natural Order.

VERITAS - Truthfullness, Honesty in Dealing With Others.

AEQUITAS - Equity, Impartiality, Fair Dealing.

NOBILITAS - Nobility , Noble Action.

LIBERALITAS - Liberality, Generosity, Open Mindedness.

FIRMITAS - Tenacity, Sterngth of Mind, the Ability to Stick to a Purpose

COMITAS - Humor, Ease of Manner, Openess and Friendship.


Code of Ethics

"A cadet will not lie, cheat, steal, or tolerate those who do."

The Cadet Honor Code - WEST POINT

In keeping with the time honored tradition at West Point, we at SUB~ROSA CAPITAL adopt the spirit of the twelve words above written. In the financial industry, as well as, in military life, trust becomes sacred and integrity becomes a requisite quality for each professional.

An individual who is not trustworthy cannot be tolerated. The cost of dishonesty is measured in lives not dollars. We at SUB~ROSA CAPITAL firmly resolve with the help of God's grace to commit to a lifetime of honorable living and to conduct our affairs with probity.

SUB~ROSA CAPITAL maintains a code of ethics that requires that all personnel act with integrity, competence, dignity and in an ethical manner when dealing with the public, clients and prospective clients. In addition, the code places upon SUB~ROSA CAPITAL the duty to exercise its authority and responsibility for the benefit of clients, to place the interests of clients first and to refrain from having outside interests that conflict with the interests of clients.

SUB~ROSA CAPITAL will not disclose any non-public personal information about a client to any non affiliated third party without the client’s express permission to do so.  SUB~ROSA CAPITAL is also obligated under its code of ethics to maintain the security of client information, including information stored on computers.

The code of ethics provides specific guidance in the areas of disclosure of conflicts of interest, acceptance of gifts, personal securities transactions, prohibited transactions, referral fees, insider trading and other customary matters considered when contemplating ethical standards.  All personnel of SUB~ROSA CAPITAL are covered by the code of ethics and failure to comply will result in disciplinary action, including termination.

SUB~ROSA CAPITAL is a Registered Investment Advisor with the California Department of Corporations. SUB~ROSA CAPITAL may only transact business or render personalized investment advice in those states and international jurisdictions where we have registered, filed notice or where we qualify for an exemption or exclusion from registration requirements.
This site is for informational purposes only and does not constitute an offer to sell or a solicitation of an offer to buy any security which may be referenced herein. We strongly urge that you consult with your financial or tax advisor with regard to your individual situation.