Which document is not typically part of an investment adviser's compliance program?

In the context of an investment adviser's compliance program, a compliance framework generally includes mechanisms and strategies designed to ensure that the adviser adheres to relevant regulations and ethical standards. An annual performance review of compliance policies provides a structured process for assessing the effectiveness of those policies, making it a vital component of compliance efforts. Internal audits and assessments further support this by allowing firms to evaluate their compliance processes and identify areas for improvement.

Reporting systems for compliance violations are essential as they create a mechanism for reporting potential breaches of compliance, ensuring that issues can be addressed promptly and effectively. These elements form the foundation of a robust compliance program.

However, while clients' written agreements on service terms are important for establishing the nature of the relationship between the client and the adviser, they do not directly contribute to the compliance program itself. Such agreements typically cover the specifics of services provided, fees, investment objectives, and other client-adviser's terms but do not serve as tools or processes designed to ensure compliance with regulatory standards. Therefore, they are not typically included in the compliance program documentation.