Code of Ethics
The Company's Code, as adopted, is as follows:
- The general conduct of the Company's personnel must at all times reflect the professional nature of the Company's business. The Company's personnel must be judicious, accurate, objective and reasonable in dealing with both clients and other parties. The personal integrity of all employees must be beyond the slightest shadow of a doubt.
- All personnel of Company must act within the spirit and the letter of all relevant federal, state and local laws and regulations pertaining to a registered investment adviser and to the general conduct of business.
- At all times, the interest of the Company's clients have precedence over personal interests. This applies particularly in the case of purchases and sales of stocks and other securities that are owned, purchased or sold in client accounts.
- Supervised Persons must immediately report any violations of the Code to the CCO.
- All Supervised Persons will be provided with a copy of the Code and any amendments thereto and must acknowledge their receipt of same in writing.
- The Company has adopted Insider Trading Policies, which set parameters for the establishment, maintenance and enforcement of policies and procedures to detect and prevent the misuse of material non-public information by the Company's personnel. The Insider Trading Policies are in addition to and do not supersede this Code.
- When a Supervised Person finds that his or her personal interests conflict with the interests of the Company and its clients, he or she will report the conflict promptly to the CCO for resolution.
- Employees and owners shall not receive or give any gift or other thing of more than $100 value from any person or entity that does business with the Company or on its behalf.
- The recommendations and actions of the Company are confidential and private matters between the Company and its clients. Accordingly, it is the policy of the Company to prohibit the release, transmission, distribution or communication of any information regarding securities transactions of client accounts except to broker/dealers or other custodians of client assets in the ordinary course of business. In addition, no information obtained during the course of employment regarding particular securities (including reports and recommendations of the Company) may be transmitted, distributed, or communicated to anyone who is not affiliated with the Company, without the prior written approval of the CCO.
- The policies and guidelines set forth in this Code must be strictly adhered to by all the Supervised Persons. Severe disciplinary actions, including dismissal, may be imposed for violations of this Code.