GIPS and Business Disclosures

Wells Fargo Asset Management (WFAM) is the trade name for certain investment advisory/management firms owned by Wells Fargo & Company. These firms include but are not limited to Wells Capital Management Incorporated and Wells Fargo Funds Management, LLC. Certain products managed by WFAM entities are distributed by Wells Fargo Funds Distributor, LLC (a broker-dealer and Member FINRA). Associated with WFAM is Galliard Capital Management, Inc. (an investment advisor that is not part of the WFAM trade/GIPS firm).

Wells Fargo Asset Management (WFAM) has well-established, and clearly stated policies that set guidelines on how we conduct business. When ethical situations arise in the normal course of doing business, WFAM encourages all team members to make decisions that are consistent with our Code of Ethics. WFAM adheres to the highest ethical standards and regulatory requirements in the industry. Specifically on these polices:

  • Performance Standards: WFAM* (formerly named Wells Capital Management) claims compliance with the Global Investment Performance Standards (GIPSĀ®). WFAM has been independently verified for the periods from January 1, 1997 through December 31, 2018. Verification assesses whether (1) the firm has complied with all the composite construction requirements of the GIPS standards on a firm-wide basis and (2) the firm’s policies and procedures are designed to calculate and present performance in compliance with the GIPS standards.

    • Review a complete list of composite descriptions.
    • For a GIPS compliance presentation on any of our composites, please call 617-377-7219.
    • The verification and performance examination reports are available upon request.

    *For the purpose of complying with GIPS, the GIPS firm is defined as WFAM. Since the GIPS firm’s creation in 1996, the firm has acquired a number of investment teams and/or assets through mergers or acquisitions which include assets and/or investment teams from Wells Capital Management, Norwest Investment Management Inc., Sutter Advisors, LLC, Montgomery Asset Management, Benson Associates, Strong Financial Corporation, Evergreen Investments, Wells Fargo Asset Management, LLC (International) (formerly named First International Advisors, LLC), Metropolitan West Capital Management, LLC, EverKey Global Partners, Wells Fargo Asset Management (International) Limited (formerly named ECM Asset Management Limited), Analytic Investors, LLC and Golden Capital Management, LLC (GCM). Effective July 1, 2018, the GIPS firm also includes assets under management of Wells Fargo Asset Management Luxembourg S.A. and Wells Fargo Funds Management, LLC (WFFM). Effective August 1, 2018, the GIPS firm also includes assets under management of the LT Equity team.

  • Proxy Voting: Per Rule 206(4) under the Investment Advisors Act of 1940, WFAM has made a copy of our Proxy Voting Policies and Procedures available upon request.
  • For a copy of Wells Capital Management’s Form ADV Part 2, please visit www.adviserinfo.sec.gov/iapd/ or call 415-396-8000.