Code of Ethics

All employees of Moneywatch are required to abide by the Moneywatch Advisors Code of Ethics. Each of our employees has acknowledged by signature that they are aware of and abide by these ethics.

A copy of our entire Code of Ethics is available by request.

Key Points

• All employees are required to be in compliance with all applicable federal securities laws at all times.
• Clients’ interests are to be placed first and foremost. All clients are to be treated fairly and equally.
• All client trades precede those of employees. Pre-approval for employee trading is required by the President and Chief Compliance Officer.
• Any non-public information collected on clients or former clients will not be disclosed to any person except permitted by law or at the request of the client.
• All employees are required to restrict access of any non-public personal information about clients. This includes physical, electronic, and procedural safeguards.