Code of Ethics · Conflicts policy
A clearing house runs on perceived fairness.
- Policy
- Code of Ethics · v1.0
- Reference
- 17 CFR 204A · IA Rule 204A-1
- Review cadence
- Annually · Audit Committee
- Training
- Annually · mandatory
Personal trading
Employees do not trade against the house.
Personal trading controls
- Pre-clearance
- Required for every covered transaction. Requests submitted through the compliance system and reviewed within one business day.
Blackout windows apply before and after material non-public information events.
- Holding period
- 30 calendar days minimum on covered securities
Short-holding-period gains are disgorged to a Wavestar-nominated charity.
- Initial public offerings
- Prohibited participation in IPOs of operators or ground-station providers
Extends to pre-IPO private placements of operators expected to onboard as members.
- Reporting
- Initial holdings report on hire; quarterly transaction reports; annual holdings report
Consistent with IA Rule 204A-1(b)(1)(iii). Late reports escalated to the CCO.
- Restricted list
- Maintained dynamically · all current members and imminent onboards
Access to the list is walled off from business teams; only compliance maintains it.
- Approved brokers
- Trading is limited to brokers that provide duplicate confirms and statements to compliance
Brokers in jurisdictions that cannot provide duplicate statements are not approved.
Cooling-off periods
Movement between roles carries a defined pause.
- 01
Revolving-door cooling off
Employees joining from a regulator (FinCEN, SEC, CFTC, FCC, ITU staff) cannot have decision-making authority over matters in which they were personally involved in government service for 24 months. For senior government roles, the period is extended. - 02
Departing to a member
Employees departing Wavestar to join a clearing member or market counterparty are placed on a six-month notice period with restricted access. Non-compete and non-solicit terms apply where enforceable. - 03
Pre-clearance after change
On any material change of role inside Wavestar, the employee's personal-trading pre-clearance is re-assessed and a new restricted list issued. - 04
Board directors
Directors with affiliations to member firms recuse from rulebook votes, margin-methodology decisions, and default-waterfall governance. Recusals are logged and included in the annual governance disclosure.
Related-party transactions
Every related-party transaction is disclosed and approved.
A related-party transaction is any transaction between Wavestar and a member, counterparty, vendor, or investor in which an officer, director, senior employee, or their immediate family has a direct or indirect material interest. All such transactions are disclosed to the Audit Committee in advance, reviewed for arm's-length economics, documented, and approved before execution. Related-party transactions above the materiality threshold are disclosed in the annual governance report.
Related-party thresholds and treatment
- Immediate family
- Spouse, partner, child, parent, sibling, or household member
- Indirect material interest
- ≥ 5% ownership, director or officer role, or beneficial interest
- Disclosure threshold
- Any amount · disclosed on annual attestation
- Pre-approval threshold
- USD 120,000 aggregated per fiscal year · Audit Committee approval required
- Arm's-length test
- Terms at least as favorable to Wavestar as would be obtained from an unrelated party
- Public disclosure
- Material transactions disclosed in the annual governance report
Gifts, entertainment, and travel
Modest, transparent, and recorded.
- 01
Gifts received
Gifts of up to USD 100 per year per counterparty may be accepted and must be logged. Above USD 100, pre-approval by the CCO is required. Cash, cash-equivalents, or gifts from a party in active RFP or negotiation are never accepted. - 02
Entertainment
Business meals and reasonable entertainment are permitted if business-related and the host attends. Extravagant or recurring entertainment is not. Annual entertainment value per counterparty is capped at USD 500 without pre-approval. - 03
Travel paid by third parties
Regulator-sponsored or industry-association-sponsored travel may be accepted with CCO pre-approval. Travel paid by members or vendors is not accepted except at genuinely open events on open terms. - 04
Gifts given
Wavestar does not give gifts to regulators, government officials, or foreign government officials. Gifts to members are limited to branded items of nominal value. FCPA and UK Bribery Act training is annual.
Political contributions
Transparent. Limited. Non-directed.
Wavestar does not make corporate political contributions. The company does not maintain a corporate Political Action Committee. Employees are free to participate in the political process on their own time with their own resources, and the company neither directs nor reimburses individual political contributions. Where an employee's role involves regulatory engagement, contributions to the relevant office-holder are disclosed to compliance in advance, consistent with SEC pay-to-play Rule 206(4)-5 principles adopted as best practice.
Code of Ethics
Read the full Code of Ethics.
The Code of Ethics sets the governing standard for every employee, officer, and director. The full text, including the personal-trading policy, gifts and entertainment rules, and related-party procedures, is published in the governance section.