Code of Conduct


At J.A.F., ethical conduct and legal compliance are the foundation for our position of industry leadership. J.A.F.'s ability to maintain its leadership position requires that each partner, manager and employee exhibit a high level of personal integrity when interacting with J.A.F. clients, business partners, and each other. Partners, managers and employees must allow honesty, common sense and good judgment to govern their conduct.

As a condition of employment, each officer and employee is expected to comply with this Code of Business Ethics and will be held accountable if he or she fails to do so. Any violation of this Code, or any conduct that violates any law, rule, regulation, or ethical or professional norm, is subject to disciplinary action, up to and including termination of employment. Partners, managers and employees are also expected to cooperate fully with any company audits or investigations and to answer all questions fully and truthfully. It is a violation of company policy to intimidate or impose any other form of retaliation on any employee who, in good faith, reports any actual or suspected legal, ethical, or policy violation.

This Code provides the standards of conduct that guide all partners, managers and employees of J.A.F. All of our partners, managers and employees must conduct themselves appropriately and seek to avoid even the appearance of improper behavior. Our officers and employees are also subject to the J.A.F. Employee Handbook, as may be modified from time to time.

Our Ethics Statement serves as the benchmark by which each of our daily business decisions should be measured and lies at the very core of the J.A.F. way of doing business.


Compliance with Laws, Rules and Regulations

J.A.F. partners, managers and employees are required to comply with all applicable laws, rules and regulations.


The Recording and Reporting of J.A.F. Information

At J.A.F., we are committed to ensuring that all business-related information is recorded and reported accurately, honestly and in a timely manner. Partners, managers and employees must ensure that information is reported truthfully and correctly, and also exercise diligence in ensuring that reported information is organized in a way that is understandable and does not mislead or misinform those who receive the information. Our policy relating to accuracy of company records extends to policy information, personal information and servicing records prepared on behalf of our clientele, and to information provided to insurance carriers.

Nowhere is J.A.F.'s commitment to ethical standards more evident than in how we communicate our financial position and operational results. We strive to ensure full, fair, accurate, timely and understandable disclosure in our presentations.

We provide our employees the means to confidentially, anonymously report concerns about questionable matters by either contacting one of the partners or the New York State Insurance Department directly at 518-473-0833.


Unfair Business Practices

J.A.F.'s commitment to high ethical standards in its business practices with clients, business partners and competitors is reflected in our dedication to candid and forthright communications about our products and services. Unfair and deceptive business practices (e.g., the misuse of proprietary information or the misrepresentation of material facts) are strictly prohibited.


Anti-Trust and Anti-Competitive Activities

J.A.F. offers its products and services to clients in compliance with antitrust laws, which prohibit J.A.F. from entering into any agreement with its carriers to restrict the free market system by fixing prices, allocating territories or clients or refusing to provide service to particular clients. J.A.F.'s clients conduct business with the Company on the basis of its industry reputation. Our clients choose J.A.F. as their insurance broker because of the quality of its services and products.

J.A.F. and its partners, managers and employees must, at all times, conduct business openly and avoid any situation that might even create the appearance that J.A.F. has made any agreement that improperly impacts industry prices or the competition.


Confidential and Proprietary Information

Because of the nature of our business, J.A.F. possesses sensitive and confidential information about our customers, business partners and the Company itself. All partners, managers and employees have a duty to protect against the disclosure of such information unless disclosure is authorized and within the law.

With respect to our customers, who entrust us with confidential personal and financial information, J.A.F. is committed to safeguarding all such information, including information gathered through fact finders and supporting documents, account information obtained in the course of our ongoing relationships with customers, and information exchanged through the Company's Web sites.

Similarly, J.A.F.'s partners, managers and employees may be exposed to proprietary or otherwise confidential information about a business partner. J.A.F. partners, managers and employees accept responsibility for maintaining the confidentiality of business partner information, neither using it for personal gain nor disclosing the information to others without proper authorization.

Finally, J.A.F.’s partners, managers and employees may be privy to sensitive and confidential information about their fellow employees or J.A.F. as a whole. Unauthorized disclosure of such information is strictly prohibited.


Improper Influence

At J.A.F., all clients and business partners receive the same high level of assistance and service. J.A.F. partners, managers and employees are strictly prohibited from giving, soliciting or accepting business courtesies or gifts intended to influence business decisions. All business decisions are to be made on the basis of the merit of the transaction and in compliance with any legal and regulatory requirements.


Protection and Proper Use of Company Assets

All employees have an obligation to protect J.A.F.'s assets (e.g., computer equipment and software, intellectual property, etc.) and ensure that those assets are efficiently used. All of J.A.F.’s assets must only be used for legitimate business purposes.


Waivers of Code

Any waiver of this Code for partners, managers and employees may be made only by Joseph Faccibene and must be promptly disclosed to other partners regardless of percentage of ownership.



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