145.The following persons, in addition to the adviser, are deemed to have access to information on the investment program of an adviser who is a portfolio manager if they participate in formulating the adviser’s investment decisions or recommendations to the client for whom the portfolio is managed or have knowledge of them before they are implemented:
(1) a partner of the adviser;
(2) an affiliate of the adviser;
(3) an officer or director of the adviser or of an affiliate of the adviser; and
(4) a member of the staff of the adviser or of an affiliate of the adviser.