Code of Ethics

In today's environment you are inundated with examples of those entrusted with your money demonstrating a failure to adhere to ethical standards. Managers of your money have a fiduciary responsibility to you yet are far too often guided by their own self-serving interests.

As stewards of your money, we hold ourselves to the highest fiduciary standards. In addition to striving to realize our vision and mission and following our stated business and investment principles, we hold ourselves to our own Code of Ethics.

To align our interests with those of our clients and prevent conflicts of interest, our Code of Ethics can be stated simply:

• Act with integrity, competence, diligence, respect, and in an ethical manner with the public, clients and prospective clients.
• Place the interests of clients first.
• Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities.