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Code of Ethics

Investment Advisors Act of 1940, Rule 204a-1

All firm employees, full and part time, registered and non-registered, are subject to the firm’s Code of Ethics.  

All firm employees subject to this Code are required to exhibit high ethical standards, and must always place client interests ahead of their own.  All firm employees subject to this Code must comply with all applicable laws related to the firm’s business.  Failure to do so may expose you to civil and/or criminal action by regulators, as well as suspension or termination from this firm.

In addition, all firm employees are bound by the Anti-Fraud Provisions of federal securities law.  As such, the firm and its employees may not:

• Employ any device, scheme or artifice to defraud any client or prospective client;
• Make any untrue statement to any client or prospective client, or omit to state any material fact necessary to any client or prospective client; 
• Engage in any act, practice, or course of business which is fraudulent, deceptive or manipulative
• Engage in any manipulative act or practice with respect to a client or prospective client

As a Fiduciary, you are required to place your client’s interests before those of the firm, its employees or affiliates, or yourself.  Your Fiduciary duties include:

• Making recommendations that are suitable for clients considering individual client needs, financial circumstances, and investment objectives
• Treating all clients fairly and equitably
• Exercising a high degree of care to ensure truthful representations about investments and recommendations presented to client
• Fully disclosing all material facts about investments or recommendations

In addition, all firm employees are specifically prohibited from the following:

1) Placing the firms, any firm employee, or your own, security orders “in front of” client orders to buy or sell securities, thereby receiving a better price than the client (“Front-Running”).
2) Buying or selling based on insider information, or disseminating any insider information.
3) Holding customer funds or securities or acting as custodian for client accounts, securities, money or other property.
4) Transacting or soliciting advisory business in any jurisdiction without proper registration or exemption from registration.
5) Borrowing money or securities from any client.
6) Accepting any cash or checks made out to you, or commingling a client’s funds with your own.
7) Maintaining a joint bank or securities account with any client, or sharing any benefit or loss with a client.
8) Placing any media, advertising, solicitations, seminars, or speaking engagements without prior firm approval.
9) Acting as an IAR for any other firm without prior firm approval.
10) Giving advice or effecting transactions which are not suitable for the client.
11) Guaranteeing the present or future value of any security, or guaranteeing that the projected results or tax benefits of any advice will be achieved.
12) Placing an order to purchase or sell a security for the account of a client upon instruction of a third party without first obtaining a third party trading authorization from the client.
13) Inducing trading in a client’s account that is excessive in size or frequency in view of the financial resources and character of the account (“Churning”).
14) Disclosing to third parties any information received from a client, including a client’s name, unless obligated to do so by law or unless written permission from the client is obtained prior to providing the information, in accordance with the firm’s Privacy Policy.
15) Signing a client or prospective clients name to any document.
16) Falsely stating or misrepresenting your credentials.
17) Representing or implying in any manner whatsoever that you have been ‘sponsored’, ‘recommended’, or ‘approved’, or that any firm product or advice has been ‘sponsored’, ‘recommended, or ‘approved’, by the United States Government or by any agency or regulatory body.

Employee Securities Holdings and Transaction Reports

All firm employees, both registered and non-registered, full and part time, are required to report both their personal securities transactions and their personal securities holdings for review by the firm’s Chief Compliance Officer.  

Holdings reports are due within 30 days of year end (January 30).  The holdings report must contain, at minimum:

• The title and type of security, and as applicable the exchange ticker symbol or CUSIP number, number of shares, and principal amount of each reportable security in which you have any direct or indirect beneficial ownership
• The name or any broker, dealer, or bank with which you maintain an account in which any securities are held for your direct or indirect benefit
• The date that the Holding Report is being submitted to the firm

Holdings reports for new employees are due within ten business days of your effective date of employment, and the report submitted must be current as of a date not more than 45 days prior to your date of employment. 

Transaction Reports are due quarterly within 30 days of the end of each quarter (due dates are January 30, April 30, July 30 and October 30), and the information contained in the reports must cover all transactions for that quarter.   Transaction reports must contain, at minimum:

• The date of the transaction, the title, and as applicable the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares, and principal amount of each reportable security involved
• The nature of the transaction (purchase, sale, or other acquisition/distribution)
• The price at which the transaction was effected
• The name of the broker, dealer or bank with or through which the transaction was effected
• The date that the Transaction Report is being submitted to the firm

The Holding and Transaction reports are reviewed by the Chief Compliance Officer.  All reports are signed and dated by the Chief Compliance Officer to evidence his review, and are maintained in a Reports file.  The Chief Compliance Officer, in reviewing the reports, will look for any transactions that run counter to clients best interests, will review to detect for ‘front running’, and will review to insure that, for those transactions requiring them, the employee received ‘pre-clearance’.

Due to the firm’s minimal size, in lieu of holdings and transaction reports, brokerage statements may be provided for compliance purposes. 

Pre-Clearance For Certain Transactions

All firm employees are required to receive written approval from the Chief Compliance Officer before you directly or indirectly acquire beneficial ownership in any security in an initial public offering (I.P.O.) or in a limited offering.  This includes all Private Placement offerings.  

You must, in writing, provide information about the proposed transaction in the I.P.O. or limited offering to the Compliance Officer, including the proposed amount of the acquisition, and must disclose any relationship that you have with any party to the transaction.  If approved by the Compliance Officer, you will receive a written approval letter, a copy of which will be maintained with your request letter in your employee file.

Violations and Employee Review

All firm employees subject to this Code of Ethics are required to immediately report to the Chief Compliance Officer any violation of the Code of Ethics that they know about or come to know about.  

The Chief Compliance Officer will review the Code of Ethics on an annual basis to ensure that the Code meets all regulatory and legal requirements. Copies of the Code of Ethics will be maintained for five years in the firm’s “Code of Ethics” file. 

In addition, all firm employees subject to the Code are required to review the Code annually (or at the time of any amendment being made to the Code).  An Attestation stating that the employee has received and reviewed the Code will be collected by the Chief Compliance Officer on an annual basis (or at the time of amendment), and will be maintained in the “Code of Ethics” file for a period of five years.