Code of Ethics

We are fiduciaries. Our duty at all times is to place the interests of our clients first. We will assist the Client to discharge this responsibility with the care, skill, and diligence that a prudent person, acting in a like capacity and familiar with such matters, would use under such circumstances.

All employees must comply with applicable federal and state securities laws. Employees are not permitted, to defraud such client in any manner; to mislead such client, including by making a statement that omits material facts: to engage in any act, practice or course of conduct which operates or would operate as a fraud or deceit upon such a client; to engage in any manipulative practice with respect to such client; or to engage in any manipulative practice with respect to securities, including price manipulation.

All personal securities transactions will be conducted in such a manner as to avoid any actual or potential conflict of interest or any abuse of an employee’s position of trust and responsibility.

We adhere to the fiduciary principle that information regarding any client is confidential. All personal information about clients is kept in strict confidence, including the client’s identity (unless the client consents), and the client’s investment holdings.

The principle of discipline in the investment decision-making process is paramount.