The goal of each firm's Investment Advisors' Code of Ethics is to set forth the policies and procedures required pursuant to Rule 204A-1 under the Investment Advisers Act of 1940 (the "Advisers Act"). The IA Code of Ethics is intended to assist the advisory firm's advisers and associates involved in investment advisory activities in meeting the high standards the firm follows in conducting its business. One of the advisory firm's most important assets is its reputation for integrity and professionalism. The responsibility of maintaining that reputation rests with all advisory firm associates.

The advisory firm's business is built on a foundation of trust. Maintaining the trust of the firm's clients, regulators, and the general public is an associate's first obligation. Associates must comply with applicable federal and state securities laws and understand the level of ethical behavior that is expected of them.

Most IA Codes of Ethics are based upon the fundamental principle that the advisory firm and its associates must put clients' interests first. Firms' IA Codes of Ethics and other written policies and procedures contain procedural requirements that affiliated associates must follow to meet legal and regulatory requirements.