Code of Ethics

As members of the Financial Industry Regulatory Authority (FINRA), we recognize the importance of codifying and making known to the profession and to the general public the ethical principles that guide the work of management, registered representatives, registered investment advisors and their support staff.

Ethical dilemmas occur when values are in conflict. FINRA and the Securities Exchange Commission (SEC) Code of Ethics states the values to which we are committed, and embodies the ethical responsibilities of the profession in this changing financial investment environment.

We strive to pursue the selection of employees with high morals and integrity. We strive to provide excellent personalized investment service to all our clients. In recent years our industry has had incidents (Enron, Mutual fund scandal, etc) that have shaken the faith of the public. We are members of a profession explicitly committed to providing fair and truthful securities information. We have a special obligation to ensure that we safeguard our clients’ assets as best we can in order to preserve principal, gain value and encourage growth for our present clients and their future generations.

The principles of this Code are expressed in broad statements to guide ethical decision-making. These statements provide a framework; they cannot and do not dictate conduct to cover particular situations.

• We provide the highest level of service to all clients through all methods of communication, mail, phone calls, meeting, and email. We provide this service in an accurate, unbiased, and courteous response to all requests.
• We uphold the principles of knowing our clients, fair trades, and resist all efforts to allow any unethical behavior such as churning or switching.
• We protect each client’s right to privacy and confidentiality with respect to information sought or received.
• We recognize and respect each client’s individual financial investment needs.
• We treat co-workers and other colleagues with respect, fairness and good faith, and advocate conditions of employment that safeguard the rights and welfare of all employees of our firm.
• We do not advance private interests at the expense of clients, colleagues, staff, or our firm. This includes no employee acquiring beneficial ownership in any security in an initial public offering or limited offering without prior approval from the Chief Compliance Officer.
• We distinguish between our personal convictions and professional duties and do not allow our personal beliefs to interfere with fair representation of the aims of our client’s investment goals.
• We strive for excellence in the profession by maintaining and enhancing our own knowledge and skills, by requiring and encouraging the continued professional development of co-workers, and by fostering the aspirations of potential members of the profession.

Adopted by Cascade Investment Group, Inc.
March 16, 2009