PA Treasurer Joe Torsella Institutes First Code of Conduct and Conflict of Interest Policy for Treasury Investment Activities

New policy will ensure all investment decisions made by Treasury are solely in the interest of the Commonwealth

Harrisburg, PA – Pennsylvania Treasurer Joe Torsella today announced he is implementing Treasury’s first code of conduct policy related to the Department’s investment activities. The new policy identifies and prohibits actual and perceived conflicts of interest for Treasury investment staff and other personnel.

"Treasury’s investment decisions should be free from outside considerations and influences and made solely on what is in the best interest of Pennsylvania. This policy will give taxpayers confidence that Treasury is investing their hard earned money for their exclusive benefit."

Pennsylvania Treasurer, Joe Torsella

The policy is modeled on both the Pennsylvania Ethics Act as well as a similar policy adopted by the Pennsylvania Public School Retirement System Board and will be revised and updated periodically. It covers all Department personnel involved, directly or indirectly, in investment activities – including the treasurer, members of Treasury’s Investment Advisory Committee, all investment staff, the chief counsel and communications director. The policy also includes the immediate family members of each covered employee.


Specifically, the policy prohibits any covered person from:

  • Purchasing or selling any security identified as a conflict by the Department’s chief investment officer – typically involving any security that may or have been recently purchased or sold by Treasury, or purchased or sold in significant volume;
  • Purchasing an interest in any initial public offering or private placement initiated by Treasury;
  • Disclosing or using for personal benefit any investment information not otherwise available to the public;
  • Participating in investment clubs or day trading unless otherwise approved by the chief investment officer.

In addition, each covered employee will file a quarterly report of all personal investment transactions with the chief investment officer.

The new code of conduct policy supports Treasurer Torsella’s mission to bring accountability to Treasury and fulfills his pledge to require disclosure of private investment trading activities by Treasury employees trading public funds. It follows his placing a formal ban on all investment contracts that include third-party agreements that pay a middleman finder's fee as a reward for acquiring Treasury investment contracts.

Access copy of policy directive here.

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