Code of Ethics

I recognize that this Code of Ethics, and its principles and obligations, are in addition to those set forth by any other Code that governs my professional and ethical conduct.

To my clients, I will:

• Employ and provide the client information on the Prudent Practices when serving as an investment fiduciary and/or advising other investment fiduciaries.
• Act with honesty and integrity and avoid conflicts of interest, real or perceived.
• Ensure the timely and understandable disclosure of relevant information that is accurate, complete, and objective.
• Be responsible when determining the value of my services and my form of compensation; taking into consideration the time, skill, experience, and special circumstances involved in providing my services.
• Know the limits of my experience, and refer my clients to colleagues and/or other professionals in connection with issues beyond my knowledge and skills.
• Respect the confidentiality of information acquired in the course of my work, and not disclose such information to others, except when authorized or otherwise legally obligated to do so. I will not use confidential information acquired in the course of my work for my personal advantage.