Promise

CODE OF ETHICS

We must:

  • Act with integrity, competence, diligence, respect and in an ethical manner with the public, clients, prospective clients, employees, colleagues in the investment profession and other participants in the global capital markets.
  • Place the integrity of the investment profession and the interests of clients above our own personal interests.
  • Use reasonable care and exercise judgement when conducting investment analysis, making investment recommendations, taking investment actions and engaging in other professional activities.
  • Practice and encourage others to practice in a professional and ethical manner that will reflect credit on ourselves and the profession.
  • Promote the integrity of and uphold the rules governing capital markets.
  • Maintain and improve our professional competence and strive to maintain the competence of other investment professionals.

Knowledge of the Law. We must understand and comply with all applicable laws, rules and regulations of any government, regulatory organization, licensing agency or professional association governing our professional activities. In the event of conflict, we must comply with the more strict law, rule or regulation. We must not knowingly participate or assist in and must disassociate ourselves from any violation of such laws, rules or regulation.

Independence and Objectivity. We must use reasonable care and judgement to achieve and maintain independence and objectivity in our professional activities. We must not offer, solicit or accept any gift, benefit, compensation or consideration that could be expected to compromise our own or another’s independence and objectivity.

Misrepresentation. We must not knowingly make any misrepresentations relating to investment analysis, recommendations, actions or other professional activities.

Misconduct. We must not engage in any professional conduct involving dishonesty, fraud or deceit or commit any act that reflects adversely on our professional reputation, integrity or competence.

Material Nonpublic Information. If we possess material nonpublic information that could affect the value of an investment, we must not act or cause others to act on the information.

Market Manipulation. We must not engage in practices that distort prices or artificially inflate trading volume with the intent to mislead market participants.

Loyalty, Prudence and Care. We have a duty of loyalty to our clients and must act with reasonable care and exercise prudent judgment. We must act for the benefit of our clients and place our clients’ interests before our employer’s or our interests.

Fair Dealing. We must deal fairly and objectively with all clients when providing investment analysis, making recommendations, taking investment action or engaging in other professional activities.

Suitability.

  1. When we are in an advisory relationship with a client, we must:
    • Make a reasonable inquiry into a client’s or prospective client’s investment experience, risk and return objectives, and financial constraints prior to making any investment recommendations or taking investment action and must reassess and update this information regularly.
    • Determine that an investment is suitable to the client’s financial situation and consistent with the client’s written objectives, mandates and constraints before making an investment recommendation or taking action.
    • Judge the suitability of investments in the context of the client’s total portfolio.
  2. When we are responsible for managing a portfolio to a specific mandate, strategy or style, we must make only investment recommendations or take only investment actions that are consistent with the stated objectives and constraints of the portfolio.

Performance Presentation. When communicating investment performance information, we must make reasonable efforts to ensure that it is fair, accurate and complete.

Preservation of Confidentiality.

  1. We must keep information about current, former and prospective clients confidential unless:
    The information concerns illegal activities on the part of the client or prospective client.
  2. Disclosure is required by law, or
  3. The client or prospective client permits disclosure of the information.

Loyalty. In matters related to our employment, we must act for the benefit of our employer and not deprive them of the advantage of our skills and abilities, divulge confidential information or otherwise cause harm to our employer.

Additional Compensation Arrangements. We must not accept gifts, compensation, benefits or consideration that competes with or might reasonably be expected to create a conflict of interest with our employer’s interest unless we obtain written consent from all parties involved.

Responsibilities of Supervisors. We must make reasonable efforts to detect and present violations of applicable laws, rules and regulations by anyone subject to our supervision or authority.

Diligence and Reasonable Basis. We must:

  1. Exercise diligence, independence and thoroughness in analyzing investments, making investment recommendations and taking investment actions.
  2. Have a reasonable and adequate basis, supported by appropriate research and investigation, for any investment analysis, recommendation or action.

Communication with Clients and Prospective Clients. We must:

  1. Disclose to clients and prospective clients the basic format and general principals of the investment processes we use to analyze investments, select securities and construct portfolios, and must promptly disclose any changes that materially affect those processes.
  2. Use reasonable judgment in identifying which factors are important to our investment analysis, recommendations or actions, and include those factors in communications with clients and prospective clients.
  3. Distinguish between fact and opinion in the presentation of investment analysis and recommendations.

Record Retention. We must develop and maintain appropriate records to support the investment analysis, recommendations, actions and other investment-related communications with clients and prospective clients.

Disclosure of Conflicts. We must make full and fair disclosure of all matters that could reasonably be expected to impair our independence and objectivity or interfere with respective duties to our clients, prospective clients and employer. We must ensure that such disclosures are prominent, delivered in plain language and communicate the relevant information effectively.

Priority of Transactions. Investment transactions for clients and employers must have priority over investment transactions in which we are the beneficial owner.

Referral Fees. We must disclose to our employer, clients, and prospective clients, as appropriate, any compensation, consideration or benefit received from or paid to others for the recommendation of products or services.

1737 Georgetown Road, Unit H Hudson, Ohio 44236

Advisory Services and Retirement Plan Consulting Program offered through Ellsworth Advisors, LLC, a Registered Investment Advisor.