Item 7. Types of Clients
compensation exist, employees are incented to favor
products for which they are more highly compensated.
TIP markets the services of its affiliated registered
investment advisers to intermediaries for consideration by
Certain intermediaries to whom we market the services of
intermediaries for their clients.
our affiliated investment advisers may be solicited by our
related persons to invest in investment-related limited
partnerships or limited liability companies for which one of
our related persons serves as the general partner or
manager and for which an affiliated investment adviser Code of Ethics
serves as the investment manager. A conflict of interest We have adopted a Code of Ethics (“Code”) for all of our
exists to the extent TIP solicits clients to invest in any private supervised persons describing our standards of business
funds sponsored by TCA or its affiliates because TCA or the conduct, and fiduciary duty to our clients. The Code
affiliate receives advisory fees for managing these private includes provisions relating to the confidentiality of client
funds and the affiliated general partner may own an interest information, a prohibition on insider trading, restrictions on
in the private fund and receive a carried interest in the acceptance of significant gifts and business
distributions by the private fund. entertainment items, and personal securities trading
procedures, among other things. All of our supervised
In addition to the above material relationships and persons must acknowledge the terms of the Code at least
arrangements with affiliated advisers, we share the annually.
premises at our principal office address, as well as certain
personnel, with certain of our affiliated investment advisors. We permit our employees to engage in personal securities
Accordingly, such persons may need to allocate their time transactions. Personal securities transactions by an
and resources across multiple affiliated entities. employee raise an actual or potential conflict of interest if an
employee trades in a security that is considered for
Broker/Dealer purchase or sale by a client. Our Code is designed to
ensure that our employees who are responsible for
We are under common control with TortoiseEcofin developing or implementing our investment advice or who
Securities, LLC (formerly Tortoise Securities, LLC) (CRD provide investment advice to clients are not able to act on
No. 285411) (“TortoiseEcofin Securities”), a broker/dealer such information to the disadvantage of clients. The Code
registered with the SEC and various state jurisdictions, and further prohibits our employees from using any material
member of the Financial Industry Regulatory Authority non-public information in securities trading.
(FINRA). However, no securities transactions for clients
of our affiliated registered advisers are executed through Under the Code, our employees are prohibited from using
TortoiseEcofin Securities. Certain of our employees are knowledge of portfolio transactions made or contemplated
officers or directors of TortoiseEcofin Securities. for any client to profit by the market effect of such
transactions or otherwise engage in fraudulent conduct in
The majority of our employees are also registered connection with the purchase or sale of a security sold or
representatives of TortoiseEcofin Securities. acquired by a client. Further, employees are prohibited
TortoiseEcofin Securities acts as placement agent for from taking advantage of an opportunity of any client for
certain affiliated private funds, and markets the affiliated personal benefit, or taking any action inconsistent with our
open-end funds and UCITS funds, all managed by the fiduciary obligations. Our employees must avoid any actual
affiliated registered investment adviser(s), and receives or potential conflict of interest or any abuse of their position
compensation from the affiliated registered investment of trust and responsibility.
adviser. In addition, certain employees of ours, in their role
as registered representatives of TortoiseEcofin Securities, Employees must pre-clear all securities transactions with
receive compensation from TortoiseEcofin Securities for the our Chief Compliance Officer (“CCO”) with certain
sale and marketing of funds that an affiliate manages. This exceptions. Employees may not purchase or sell any
presents a conflict of interest and gives the affiliated broker- securities which we are considering for client accounts until
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