An essential part of our investment process is to look for companies with meaningful insider ownership. We believe high insider ownership provides tangible evidence of executives’ personal commitment to their company.
This belief also applies to Heartland with employees investing alongside our shareholders and owning a personal stake in the Funds. In this way, we demonstrate our commitment to shareholders and conviction to our investment process.
The above individuals are Registered Representatives of ALPS Distributors, Inc.
Additional information regarding portfolio managers' and the Heartland Board of Directors' ownership in the Heartland Funds is available in our SAI.
Heartland’s Code of Ethics requires employees to obtain pre-authorization from our compliance department for personal trading in Heartland Fund shares. A number of other restrictions on personal trading are also outlined in the Code. The Code is posted on our website, as part of our Business Conduct Rules, for convenient public access. The Heartland Code of Ethics generally prohibits all employees from purchasing securities of any company with a market capitalization of less than $2 billion, which includes many of the securities in which we invest.
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