AIF® and AIFA® Designee Code of Ethics

I recognize that this Code of Ethics, and its principles and obligations, are in addition to those set forth by any other Code that governs my professional and ethical conduct.

To my clients, I will:

1. Employ and provide the client information on the Prudent Practices when serving as an investment fiduciary and/or advising other investment fiduciaries.

2. Act with honesty and integrity and avoid conflicts of interest, real or perceived.

3. Ensure the timely and understandable disclosure of relevant information that is accurate, complete, and objective.

4. Be responsible when determining the value of my services and my form of compensation; taking into consideration the time, skill, experience, and special circumstances involved in providing my services.

5. Know the limits of my expertise, and refer my clients to colleagues and/or other professionals in connection with issues beyond my knowledge and skills.

6. Respect the confidentiality of information acquired in the course of my work, and not disclose such information to others, except when authorized or otherwise legally obligated to do so. I will not use confidential information acquired in the course of my work for my personal advantage.

7. Not exploit any relationship or responsibility that has been entrusted to me.

To my community (whether defined by work, family, and/or friends), I will:

1. Proactively promote and be a steward of ethical behavior as a responsible partner among my peers in the work environment and in my community.

2. Ensure that the overall promotion of my practice is implemented in the best interests of my profession.

3. Seek, accept, and offer honest criticism of technical work; acknowledge and correct errors; and properly credit the contributions of others.

4. Use corporate assets and resources employed or entrusted to me in a responsible manner.

5. Continue to improve my knowledge and skills, share ideas and information with colleagues, and assist them in their professional development.