Conflict of Interest Policy and Guidelines

The firm has detailed policies and procedures for dealing with conflicts of interest as part of the compliance infrastructure. The firm is not conflicted with business objectives or evaluation standards designed to meet revenue or sales targets imposed by external stake holders. The firm does not have any ownership interest or affiliation with third party manufacturers or distributors of investment products. This business model is designed to maintain a high level of transparency and promote a culture of confidence and trust with participating clients.