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 encourages all employees to limit their investments to the portfolios run by Brick Financial [the same portfolios in which our clients are invested], unless granted clearance by an independent compliance officer. All employees must report their securities transactions annually and quarterly. Generally we do not make specific recommendations of investments. Our blackout periods prevent us from taking action on an investment before our clients have had the opportunity. We can not comment on an investment within several days of buying or selling the investment. In all cases, should we in fact comment on any investment, we will reveal our interest or non-interest in the investment. Our Code of Ethics is reviewed annually and we record any violations.

Our Code of Ethics can be viewed in its entirety by clicking here.

Although our Code of Ethics stands on its own, we are additionally guided by and adhere to the Code of Ethics and Standards of Professional Conduct of the CFA Institute, the details of which can be viewed here.