I P E X Code of Ethics                    

This Code has been adopted to promote and maintain the highest standards of personal and professional conduct in all aspects of investment consulting in which IPEX personnel may be engaged.  All IPEX personnel are required to subscribe to the Code, which serves to assure public confidence in the services offered by IPEX, and to report any violations of the Code promptly to the IPEX Compliance Officer. IPEX personnel shall provide the Compliance Officer with a written acknowledgment of receipt of their copy of the Code. 

FUNDAMENTAL RESPONSIBILITIES

Legal Compliance

IPEX personnel shall maintain knowledge of and comply with all applicable federal and state laws, rules and regulations issued any government, government agency, regulatory organization, licensing agency, or professional association governing their profession. IPEX personnel shall not knowingly participate or assist in any violation of such laws, rules or regulations.

Standards of Conduct

IPEX personnel shall maintain the highest standards of personal and professional conduct; act with integrity, competence, dignity, and in an ethical manner when dealing with the public, clients, prospects, fellow employees and IPEX; act and encourage others to act in a professional and ethical manner that will reflect credit on IPEX; and use reasonable care and exercise independent professional judgment.

RESPONSIBILITIES TO THE PROFESSION

Professional Misconduct

IPEX personnel shall not engage in any professional conduct involving dishonesty, fraud, deceit, or misrepresentation or commit any act that reflects adversely on their honesty, trustworthiness, or professional competence.

Prohibition against Plagiarism

IPEX personnel shall not copy or use, in substantially the same form as the original, material prepared by another without acknowledging and identifying the name of the author, publisher, or source of such material. IPEX personnel may use, without acknowledgment, factual information published by recognized financial and statistical reporting services or similar sources.

RESPONSIBILITIES TO IPEX

Independent Practice

IPEX personnel shall not undertake any independent practice that could result in compensation or other benefit in competition with IPEX, unless they obtain prior written consent from both IPEX and the entities for which they undertake such independent practice.

Disclosure of Conflicts

IPEX personnel shall disclose to IPEX all matters, including beneficial ownership of securities or other investments, which reasonably could be expected to interfere with their duty to IPEX or ability to make unbiased and objective recommendations, and comply with any prohibitions on activities imposed by IPEX if a conflict of interest exists. IPEX personnel shall report their personnel securities transactions and holdings to IPEX in accordance with the IPEX “Personnel Transactions Protocol”.  

Responsibilities of Supervisors

IPEX personnel with supervisory responsibility, authority, or the ability to influence the conduct of others shall exercise reasonable supervision over those subject to their oversight to prevent any violation of applicable statutes, regulations, or the Code. In so doing, IPEX personnel are entitled to rely on reasonable procedures designed to detect and prevent such violations.

RESPONSIBILITIES TO CLIENTS AND PROSPECTS

Fair Dealing

IPEX personnel shall deal fairly and objectively with all clients and prospects when disseminating investment recommendations and taking investment action. All client inquiries shall be answered promptly, completely, and truthfully.

Fiduciary Duties

In relationships with clients, IPEX personnel shall use care in determining applicable fiduciary duty and shall comply with such duty as to those persons and interests to whom the duty is owed. IPEX personnel shall always place the financial interests of the client first. All recommendations to clients and decisions on behalf of clients shall be solely in the interest of providing the highest value and benefit to the client.

Independence and Objectivity

IPEX personnel shall use reasonable care and judgment to achieve and maintain independence and objectivity in making investment recommendations.

Preservation of Confidentiality

IPEX personnel shall preserve the confidentiality of information communicated by clients, prospects, or other employees concerning matters within the scope of the particular relationship to the full extent permitted by law, and in accordance with the “IPEX Privacy Policy”, unless the  information concerns illegal activities on the part of the client, prospect, or employee.

Prohibition against Misrepresentation

IPEX personnel shall not make any statements, orally or in writing, that misrepresent the services that they or IPEX are capable of performing; their qualifications or the qualifications of IPEX; or their academic or professional credentials. IPEX personnel shall not make or imply, orally or in writing, any assurances or guarantees regarding any investment, except to communicate accurate information regarding the investment, and shall distinguish between facts and opinions in presenting investment recommendations.

Disclosure of Compensation

IPEX personnel shall disclose fully to clients and prospects all compensation received and the terms of such compensation.  IPEX personnel shall not accept or receive any compensation from any third party other than the client. IPEX personnel shall disclose to clients and prospects any consideration or benefit that is delivered to others for the recommendation of any services to the client or prospect.

Disclosure of Conflicts to Clients and Prospects

IPEX personnel shall disclose to the clients and prospects all matters, including beneficial ownership of securities or other investments, which reasonably could be expected to impair their ability to make unbiased and objective recommendations. All financial relationships, direct or indirect, between IPEX and any third party or any other potential conflicts of interest shall be fully disclosed on a timely basis.

Performance Presentation

IPEX personnel shall not make any statements, orally or in writing, that misrepresent the investment performance that any course of action has accomplished or can reasonably be expected to achieve. If IPEX personnel communicate performance information directly or indirectly to clients or prospects, or in a manner intended to be received by clients or prospects, IPEX personnel shall make every reasonable effort to assure that such performance information is a fair, accurate, and a complete presentation of such performance.

Reasonable Basis and Representations

IPEX personnel shall exercise diligence and thoroughness in making investment recommendations; have a reasonable and adequate basis, supported by appropriate research and investigation, for such recommendations; make reasonable and diligent efforts to avoid any material misrepresentation in any investment recommendation; maintain appropriate records to support the reasonableness of such recommendations; and provide  clients all information related to the investment decision making process that they may need to make informed decisions based on realistic expectations.

Portfolio Investment Recommendations and Actions

IPEX personnel shall consider the appropriateness and suitability of investment recommendations or actions for each portfolio or client. In determining appropriateness and suitability, IPEX personnel shall consider applicable relevant factors, including the needs and circumstances of the portfolio or client, the characteristics of the investments involved, and the characteristics of the total portfolio. IPEX personnel shall not make a recommendation unless they reasonably determine that the recommendation is suitable to the client’s financial situation, investment experience, and investment objectives.

 Adopted January 10th, 2005

 The I P E X Code of Ethics is based upon the “Code of Professional Responsibility” adopted by the Investment Management Consultants Association, and the “Code of Ethics” and “Standards of Professional Conduct” adopted by the CFA Institute.