Governance Documents

Adamas's primary business purpose is to manage a portfolio of investments that will deliver stable distributions to our stockholders over diverse economic conditions. In pursuing this purpose, we are committed to conducting our business in a manner consistent with the best practices of corporate governance.

One governing principle is that of simplicity and transparency. Simplicity in that we focus on what we do best: invest in liquid, high-quality mortgage loans and securities, mitigate earnings and book value volatility by managing interest rate risk and avoiding exotic or esoteric mortgage securities and derivatives structures. Transparency – the dissemination of operating and financial information to the public in order to form an informed opinion as to our performance – in order to earn the trust of our investors.

We maintain an ethical workplace in which the highest standards of professional conduct are practiced and applied to our customers, our employees and the investing public. In many cases, we have exceeded the minimum standards required by the SEC and other regulatory mandates. We would like to emphasize the following corporate governance facts:

• Our Board of Directors consists of a majority of independent directors.
• We have adopted a Code of Business Conduct and Ethics as well as Corporate Governance Guidelines in order to promote the highest standards of conduct and ethics in all our business activities and relationships by our employees, officers and directors.
• We have an Insider Trading Policy prohibiting any of our employees, officers or directors from buying or selling our stock on the basis of material nonpublic information and to prohibit the communication of material nonpublic information to others.
• We have established a corporate governance email address and a third-party, anonymous whistleblower hotline to address concerns and complaints regarding internal controls, auditing and compliance matters. Concerns and complaints can be submitted by calling our hotline at 866-265-3859 or by e-mail at [email protected].