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Atel 15, LLC – ‘10-K’ for 12/31/20 – ‘EX-14.1’

On:  Tuesday, 3/30/21, at 6:47am ET   ·   For:  12/31/20   ·   Accession #:  1558370-21-3673   ·   File #:  0-54931

Previous ‘10-K’:  ‘10-K’ on 3/26/20 for 12/31/19   ·   Next:  ‘10-K’ on 3/18/22 for 12/31/21   ·   Latest:  ‘10-K’ on 3/21/24 for 12/31/23   ·   1 Reference:  To:  Atel 15, LLC – ‘424B3’ on 11/1/11

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  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 3/30/21  Atel 15, LLC                      10-K       12/31/20   69:6.2M                                   Toppan Merrill Bridge/FA

Annual Report   —   Form 10-K
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 10-K        Annual Report                                       HTML    557K 
 2: EX-4.1      Instrument Defining the Rights of Security Holders  HTML     23K 
 3: EX-14.1     Code of Ethics                                      HTML     28K 
 4: EX-31.1     Certification -- §302 - SOA'02                      HTML     27K 
 5: EX-31.2     Certification -- §302 - SOA'02                      HTML     27K 
 6: EX-32.1     Certification -- §906 - SOA'02                      HTML     23K 
 7: EX-32.2     Certification -- §906 - SOA'02                      HTML     23K 
14: R1          Document and Entity Information                     HTML     55K 
15: R2          Balance Sheets                                      HTML     68K 
16: R3          Statements of Operations                            HTML     86K 
17: R4          Statements of Changes in Members' Capital           HTML     36K 
18: R5          Statements of Changes in Members' Capital           HTML     22K 
                (Parenthetical)                                                  
19: R6          Statements of Cash Flows                            HTML    105K 
20: R7          Organization and Limited Liability Company Matters  HTML     27K 
21: R8          Summary of Significant Accounting Policies          HTML     85K 
22: R9          Concentration of Credit Risk and Major Customers    HTML     57K 
23: R10         Notes Receivable, Net                               HTML     22K 
24: R11         Equipment Under Operating Leases, Net               HTML    155K 
25: R12         Allowance for Credit Losses                         HTML     57K 
26: R13         Related Party Transactions                          HTML     38K 
27: R14         Non-Recourse Debt                                   HTML     48K 
28: R15         Borrowing Facilities                                HTML     22K 
29: R16         Commitments                                         HTML     23K 
30: R17         Guarantees                                          HTML     23K 
31: R18         Members' Capital                                    HTML     38K 
32: R19         Fair Value Measurements                             HTML    270K 
33: R20         Global Health Emergency                             HTML     23K 
34: R21         Summary of Significant Accounting Policies          HTML    117K 
                (Policy)                                                         
35: R22         Summary of Significant Accounting Policies          HTML     61K 
                (Tables)                                                         
36: R23         Concentration of Credit Risk and Major Customers    HTML     59K 
                (Tables)                                                         
37: R24         Equipment Under Operating Leases, Net (Tables)      HTML    158K 
38: R25         Allowance for Credit Losses (Tables)                HTML     57K 
39: R26         Related Party Transactions (Tables)                 HTML     35K 
40: R27         Non-Recourse Debt (Tables)                          HTML     45K 
41: R28         Members' Capital (Tables)                           HTML     36K 
42: R29         Fair Value Measurements (Tables)                    HTML    271K 
43: R30         Organization and Limited Liability Company Matters  HTML     54K 
                (Narrative) (Details)                                            
44: R31         Summary of Significant Accounting Policies          HTML     67K 
                (Narrative) (Details)                                            
45: R32         Summary of Significant Accounting Policies          HTML     26K 
                (Schedule of Differences Between Book Value and                  
                Tax Basis of Net Assets) (Details)                               
46: R33         Summary of Significant Accounting Policies          HTML     36K 
                (Reconciliation of Net Income (Loss) Reported in                 
                Financial Statements and Federal Tax Return)                     
                (Details)                                                        
47: R34         Concentration of Credit Risk and Major Customers    HTML     43K 
                (Schedule of Leasing and Lending Revenues)                       
                (Details)                                                        
48: R35         Equipment Under Operating Leases, Net (Narrative)   HTML     35K 
                (Details)                                                        
49: R36         Equipment Under Operating Leases, Net (Investment   HTML     35K 
                in Leases) (Details)                                             
50: R37         Equipment Under Operating Leases, Net (Property on  HTML     52K 
                Operating Leases) (Details)                                      
51: R38         Equipment Under Operating Leases, Net (Future       HTML     33K 
                Minimum Lease Payments Receivable) (Details)                     
52: R39         Equipment Under Operating Leases, Net (Schedule of  HTML     45K 
                Useful Lives of Lease Assets) (Details)                          
53: R40         Allowance for Credit Losses (Activity in Allowance  HTML     33K 
                for Doubtful Accounts) (Details)                                 
54: R41         Related Party Transactions (Managing Member and/or  HTML     26K 
                Affiliates Earned Commissions and Billed for                     
                Reimbursements Pursuant to Operating Agreement)                  
                (Details)                                                        
55: R42         Non-Recourse Debt (Narrative) (Details)             HTML     36K 
56: R43         Non-Recourse Debt (Future Minimum Payments of       HTML     55K 
                Non-Recourse Debt) (Details)                                     
57: R44         Borrowing Facilities (Narrative) (Details)          HTML     22K 
58: R45         Commitments (Narrative) (Details)                   HTML     21K 
59: R46         Members' Capital (Narrative) (Details)              HTML     44K 
60: R47         Members' Capital (Distributions to Other Members)   HTML     28K 
                (Details)                                                        
61: R48         Fair Value Measurements (Narrative) (Details)       HTML     24K 
62: R49         Fair Value Measurements (Fair Value, Warrants       HTML     27K 
                Measured on Recurring Basis) (Details)                           
63: R50         Fair Value Measurements (Fair Value, Investment     HTML     30K 
                Securities Measured on Recurring Basis) (Details)                
64: R51         Fair Value Measurements (Fair Value Measurement of  HTML     24K 
                Assets and Liabilities Measured at Fair Value on a               
                Non-Recurring Basis) (Details)                                   
65: R52         Fair Value Measurements (Summary of Valuation       HTML     66K 
                Techniques and Significant Unobservable Inputs                   
                Used) (Details)                                                  
66: R53         Fair Value Measurements (Estimated Fair Values of   HTML     40K 
                Financial Instruments) (Details)                                 
68: XML         IDEA XML File -- Filing Summary                      XML    123K 
67: EXCEL       IDEA Workbook of Financial Reports                  XLSX     78K 
 8: EX-101.INS  XBRL Instance -- atel-20201231                       XML   1.81M 
10: EX-101.CAL  XBRL Calculations -- atel-20201231_cal               XML    171K 
11: EX-101.DEF  XBRL Definitions -- atel-20201231_def                XML    373K 
12: EX-101.LAB  XBRL Labels -- atel-20201231_lab                     XML    822K 
13: EX-101.PRE  XBRL Presentations -- atel-20201231_pre              XML    677K 
 9: EX-101.SCH  XBRL Schema -- atel-20201231                         XSD    162K 
69: ZIP         XBRL Zipped Folder -- 0001558370-21-003673-xbrl      Zip    128K 


‘EX-14.1’   —   Code of Ethics


This Exhibit is an HTML Document rendered as filed.  [ Alternative Formats ]



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Exhibit 14.1

ATEL 15, LLC

CODE OF ETHICS FOR CHIEF EXECUTIVE OFFICER AND CHIEF FINANCIAL AND OPERATING OFFICER

A. SCOPE

This Code of Ethics is applicable to ATEL 15, LLC (“Fund 15”), including the Chief Executive Officer and Chief Financial Officer and Chief Operating Officer of its Manager, ATEL Managing Member, LLC (“AMM”), or persons acting in such capacity (collectively the “Covered Officers”) on behalf of Fund 15, referred to herein as the “Company.”

Accordingly, under the Securities and Exchange Commission’s interpretation of its disclosure rules, the Board of Directors of the Manager of AMM, ATEL Financial Services, LLC (“AFS”), functions as the de facto audit committee for the Company with respect to all procedural and disclosure requirements applicable to audit committees under Securities and Exchange Commission rules. The Board of Directors shall have oversight responsibility over the activities of the Company for purposes of this Code of Ethics.

B. PURPOSE

The Company is proud of the values with which it conducts business. It has and will continue to uphold the highest levels of business ethics and personal integrity in all types of transactions and interactions. To this end, this Code of Ethics serves to (1) emphasize the Company’s commitment to ethics and compliance with the law; (2) set forth basic standards of ethical and legal behavior; (3) provide reporting mechanisms for known or suspected ethical or legal violations; and (4) help prevent and detect wrongdoing. This Code of Ethics is intended to augment and supplement the standard of ethics and business conduct expected of all Company employees, and its limitation to Covered Officers is not intended to limit the obligation of all Company employees to adhere to the highest standards of business ethics and integrity in all transactions and interactions conducted while in the Company’s employ.

Given the variety and complexity of ethical questions that may arise in the course of business of the Company, this Code of Ethics serves only as a rough guide. Confronted with ethically ambiguous situations, the Covered Officers should remember the Company’s commitment to the highest ethical standards and seek independent advice, where necessary, to ensure that all actions they take on behalf of the Company honor this commitment.

C. ETHICS STANDARDS

1. Honest and Ethical Conduct

The Covered Officers shall behave honestly and ethically at all times and with all people. They shall act in good faith, with due care, and shall engage only in fair and open competition, by treating ethically competitors, suppliers, customers, and colleagues. They shall not misrepresent facts or engage in illegal, unethical, or anti-competitive practices for personal or professional gain.

2. Conflicts of Interest

This fundamental standard of honest and ethical conduct extends to the handling of conflicts of interest. The Covered Officers shall avoid any actual, potential, or apparent conflicts of interest with the Company, and any personal activities, investments, or associations that might give rise to such conflicts. They shall not compete with or use the Company, for personal gain, self-deal, or take advantage of any corporate opportunities. They shall act on behalf of the Company free from improper influence or the appearance of improper influence on their judgment or performance of duties. A Covered Officer shall disclose any material transaction or relationship that reasonably could be expected to give rise to such a conflict to the Company’s General Counsel or a member of the Company’s Board of Directors. No action may be taken with respect to such transaction or party unless and until the Company’s Board of Directors has approved such action.


Notwithstanding the foregoing, it is understood, as fully disclosed in the offering documents for the Company, that AMM as managing member of the Company has certain inherent conflicts of interest. The provisions of the Company’s Operating Agreement have been drafted to address the obligations, restrictions and limitations on the power and authority of AMM to manage the Company’s affairs, including restrictions prohibiting or limiting the terms of any transactions in which conflicts of interest may arise. Furthermore, AMM has a fiduciary duty to the Company as its manager. It is therefore expressly understood by the Company and the Covered Officers that any and all actions by AMM and its personnel that comply with the provisions of the Company’s Operating Agreement, and which are consistent with AMM’s fiduciary duty to the Company, will not be considered material transactions or relationships which require disclosure or reporting under this Code of Ethics.

3. Timely and Truthful Disclosure

In reports and documents filed with or submitted to the Securities and Exchange Commission and other regulators by the Company and in other public communications made by the Company, the Covered Officers shall make disclosures that are full, fair, accurate, timely, and understandable. The Covered Officers shall provide thorough and accurate financial and accounting data for inclusion in such disclosures. The Covered Officers shall not knowingly conceal or falsify information, misrepresent material facts, or omit material facts necessary to avoid misleading the Company’s independent public auditors or investors.

4. Legal Compliance

In conducting the business of the Company, the Covered Officers shall comply with applicable governmental laws, rules, and regulations at all levels of government in the United States and in any non-U.S. jurisdiction in which the Company does business, as well as applicable rules and regulations of self-regulatory organizations of which the Company is a member. If the Covered Officer is unsure whether a particular action would violate an applicable law, rule, or regulation, he or she should seek the advice of inside counsel (if available), and, where necessary, outside counsel before undertaking it.

D. VIOLATIONS OF ETHICAL STANDARDS

1. Reporting Known or Suspected Violations

The Covered Officers will promptly bring to the attention of the Company’s General Counsel or the Board of Directors any information concerning a material violation of any of the laws, rules or regulations applicable to the Company and the operation of its businesses, by the Company or any agent thereof, or of violation of this Code of Ethics. The Company’s General Counsel will investigate reports of violations and the findings communicated to the Company’s Board of Directors.

2. Accountability for Violations

If the Company’s Board of Directors determines that this Code of Ethics has been violated, either directly, by failure to report a violation, or by withholding information related to a violation, it may discipline the offending Covered Officer for non-compliance with penalties up to and including termination of employment. Violations of this Code of Ethics may also constitute violations of law and may result in criminal penalties and civil liabilities for the offending Covered Officer and the Company.



1 Previous Filing that this Filing References

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

11/01/11  Atel 15, LLC                      424B3                  1:4.4M                                   Toppan Merrill/FA
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Filing Submission 0001558370-21-003673   –   Alternative Formats (Word / Rich Text, HTML, Plain Text, et al.)

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