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The following broad ethical principles are based on our core values of integrity, competence, objectivity, confidentiality, fairness and diligence. These principles set forth ideals to which all employees, officers and directors should aspire.

Value 1: Integrity. You shall behave in a trustworthy manner. Integrity is the cornerstone for sound judgment and establishing trust with a client. Integrity demands honesty and candor, which must not be subordinated to personal gain and advantage. Integrity cannot co-exist with deceit or subordination of one’s principles. Acting with integrity is not only the responsibility of those persons that may have been placed by clients in positions of trust and confidence; such responsibility is directed to all employees, officers and directors. You are to continually be aware of our mission, values, ethical principles and standards, and perform your duties in such a manner that is not only compliant with the letter but also the spirit of this Code of Ethics.

Value 2: Competence. You shall engage only in those services for which you have the necessary knowledge, skills and experience. We are all finite beings; you must be aware of your personal limitations. Competence is recognizing one’s level of expertise and only providing service within those boundaries, or only after taking reasonable steps to acquire that level of knowledge, skill or experience, offer such service. You will endeavor to improve your proficiency and commitment to learn and increase your professional knowledge.

Value 3: Objectivity You shall act without prejudice or bias, and labor in good faith for the best interest of all persons. Objectivity requires you to act impartially where your behavior toward others is unaffected by your personal feelings. You must protect the integrity of your work, maintain objectivity, and avoid subordination of your judgment that would violate this Code of Ethics. You will endeavor to avoid circumstances where a conflict of interest might exist. If unavoidable, whenever possible, make full disclosure of such conflict(s).

Value 4: Confidentiality You shall respect the confidentiality of any information entrusted to, or obtained in the course of, your business or professional activities. Confidentiality is having another’s confidence where you are entrusted with their private affairs. Confidence implies full trust and belief that one is a reliable person worthy of keeping matters private. As an employee, officer, advisors or director, you are to maintain at all times the confidentiality of others. You are not to share confidential information with anyone, including family and friends, or with other employees who do not need the information to carry out their duties. You are only to use such confidential information for the business purpose intended.

Value 5: Fairness You shall perform your duties in a manner that is fair, just and reasonable to all persons. To be fair requires your decisions to be free from bias, dishonesty or injustice and to fully disclose any conflicts of interest. Fairness is treating others in the manner that you would want to be treated. You are not to take advantage of another through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing. To do so would violate this Code of Ethics.

Value 6: Diligence You shall proceed with patience, timeliness and consistency, and do so in a prompt and thorough manner in the service of others. Diligence is making a constant and earnest effort to attain a given objective. You are to strive for, in this case, a distinguished record of professional service. Determining Illegal or Unethical Behavior We must work to ensure prompt and consistent action against violations of this Code of Ethics. However, there are instances where it is difficult to know if a violation has occurred. Since we cannot anticipate every situation that will arise, it is important that we have a way to approach any new dilemma. These are steps to consider when making that judgment call:
• Make sure you have all the facts. In order to reach the right conclusion, you must be as informed as possible.
• Ask first, act later. If you are unsure of what to do in a given situation, seek guidance before you act.
• Question your actions. What specifically am I being asked to do? Does it seem unethical or improper? These questions will enable you to focus on the situation you are facing, and the alternatives you have. Use your judgment and common sense; if something seems unethical or improper, it probably is.
• Clarify your responsibilities. In most situations, there is shared responsibility. Are your colleagues informed? It may help to get others involved and discuss the problem.
• Discuss the problem with your manager. This is the basic guidance for all situations. In many cases, your manager will be more knowledgeable about how to address the problem. Remember that it is your manager’s responsibility to assist with problem solving.
• Seek assistance from firm resources. In the event it is not appropriate to discuss an issue with your manager, or where you do not feel comfortable approaching your manager with your questions, you can discuss your problem with other managers, the Chief Compliance Officer or the President.
• Reporting violations. You may report violations of our Code in confidence and without fear of retaliation. If your situation requires your identity be kept secret, your anonymity will be protected. Reporting Illegal or Unethical Behavior You are required to report any illegal or unethical behavior in violation of this Code of Ethics to your manager or the Chief Compliance Officer. Violations can also be reported to any manager, officer or director if your concerns are directly related to those persons in authority over you. Any report of questionable conduct or violation will be treated confidentially to the extent permitted by law and investigated promptly and appropriately. All employees, officers and directors are expected to cooperate fully in internal investigations of misconduct. You may submit a good faith concern regarding questionable conduct or suspected violation without fear of dismissal or retaliation. We will not permit retaliation of any kind by our officers and directors against good faith reports or complaints of violations to this Code or other illegal or unethical conduct.