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I. Introduction & Overview

In our efforts to ensure Means Wealth Management (“Means”) develops and maintains a reputation for integrity and high ethical standards, Means and its employees must comply with relevant federal and state securities laws. Also, we must maintain high standards of personal and professional conduct. Means’ Code of Ethics (the “Code”) is designed to ensure that we conduct our business consistent with these high standards.

This Code is based on the principle that the officers, directors, employees, or supervised persons of Means must place the clients’ interests ahead of their interests. The Code applies to all employees and focuses principally on monitoring and reporting of personal transactions in securities.

Means holds to the following principles:

  • Employees must scrupulously avoid serving their interests ahead of the interests of the clients. An employee may not induce or cause a client to take action, or not to take action, for personal benefit rather than for the client’s benefit. For example, an employee would violate this Code by causing a client to purchase a Security they owned to increase that Security price.
  • All personal securities transactions will be conducted in such a manner as to be consistent with the Code of Ethics and to avoid any actual or potential conflict of interest or any misuse of an employee’s position of trust and responsibility.
  • Employees may not, for example, use their knowledge of portfolio transactions to profit from the market effect of such transactions.
  • The principle that independence in the investment decision-making process is paramount.

II. Standards of Business Conduct

All employees must comply with all applicable federal and state securities laws. Employees are not permitted, in connection with the purchase or sale, directly or indirectly, of a security held or to be acquired by a client:

  • To defraud such clients in any manner.
  • To mislead such clients, including by making a statement that omits material facts.
  • To engage in any act, practice, or course of conduct which operates or would operate as a fraud or deceit upon such a client.
  • To engage in any manipulative practice concerning such clients.
  • To engage in any manipulative practice concerning securities, including price manipulation.

Conflicts of Interest

Means has an affirmative duty of care, loyalty, honesty, and good faith to act in its clients’ best interests. At the same time, the way we make money creates some conflict with client interests.

Compliance with this duty can best be achieved by fully disclosing all material facts concerning any client conflict. Employees should try to avoid any situation that has even the appearance of conflict or impropriety.

Gifts & Entertainment

A conflict of interest occurs when employees’ interests interfere or could potentially interfere with their responsibilities to the firm and its clients.

The overriding principle is that supervised persons should not accept inappropriate gifts, favors, entertainment, accommodations, or other things of material value that could influence decision-making or make them feel accountable to a person or firm.

Similarly, employees should not offer gifts, favors, entertainment, or other things of value that could be viewed as overly generous or aimed at influencing decision-making or making a client feel indebted to the firm or the supervised person.


No supervised person may receive any gift, service, or other things of more than de minims value from any person or entity that does business with or on behalf of the adviser. No supervised person may give or offer any gift of more than de minimis value to existing clients, prospective clients, or any entity that does business with or on behalf of the adviser without pre-approval by the Chief Compliance Officer.


No supervised person may give or accept cash gifts or cash equivalents to or from a client, prospective client, or any entity that does business with or on behalf of the adviser.


No supervised person may provide or accept extravagant or excessive entertainment to or from a client, prospective client, or any person or entity that does or seeks to do business with or on behalf of the adviser. A supervised person may provide or accept a business entertainment event, such as dinner or a sporting event, of reasonable value if the person or entity providing the entertainment is present.


Employees are prohibited from revealing information relating to the clients’ investment intentions, activities, or portfolios except to persons whose responsibilities require knowledge of the information.

Marketing & Promotional Activities

All oral and written statements, including those made to clients, prospective clients, their representatives, or the media, must be professional, accurate, balanced, and not misleading in any way. Any promotional materials must be pre-approved.

III. Personal Securities Transactions

Prohibited Transactions

Initial Public Offerings

Any purchase of Securities by an employee in an initial public offering other than a new offering of a registered open-end investment company is prohibited. However, if authorized, the Compliance Officer may maintain a record of the reasons for such authorization.

Always Prohibited Securities Transactions

The following Securities Transactions are prohibited. They will not be authorized under any circumstances.

  • Inside Information. Any transaction in Security while in possession of material nonpublic information regarding the Security or the issuer of the Security.
  • Market Manipulation. Transactions intended to raise, lower, or maintain any Security or create a false appearance of active trading.
  • Others. Any other transactions deemed by the Compliance Officer or a designee involve a conflict of interest, possible diversions of a corporate opportunity, or an appearance of impropriety.

Private Placements

Acquisition of Beneficial Interests in Securities in a private placement by supervised persons is strongly discouraged. The Compliance Officer (or a designee) may give permission only after considering, among other facts, whether the investment opportunity should be reserved for a client and whether the opportunity is being offered to the person by the person’s position as a supervised person. If a private placement transaction is permitted, the Compliance Officer may maintain a record of the reasons for such approval.


The following Securities Transactions are exempt from restrictions:

  • Mutual Funds. Any registered open-end investment companies issue securities.
  • No Knowledge. Securities Transactions where neither the employee nor an immediate family member knows the transaction before it is completed. For example, Securities Transactions affected an employee by a trustee of a blind trust or discretionary trades involving an investment partnership or investment club. The employee is neither consulted nor advised of the trade before it is executed.
  • Certain Corporate Actions. Any acquisition of Securities through stock dividends, dividend reinvestments, stock splits, reverse stock splits, mergers, consolidations, spin-offs, or other similar corporate reorganizations or distributions generally applicable to all holders of the same class of Securities.
  • Rights. Any acquisition of Securities through the exercise of rights issued by an issuer pro rata to all holders of a class of its Securities, to the extent the rights were acquired in the issue.
  • Miscellaneous. Any transaction in the following:
    • Bankers’ acceptances
    • Bank certificates of deposit
    • Commercial paper
    • High-quality short-term debt, including repurchase agreements
    • Securities that are direct obligations of the U.S. Government
    • Other Securities as designated in writing by the Compliance Officer because the risk of misuse is minimal or non-existent

IV. Reporting Requirements

The Compliance Officer will receive duplicate confirms and statements for all Securities accounts of employees held at Means. Any employee who holds Securities accounts away from Means must submit to the Compliance Officer within 10 days of becoming an employee, establishing such an Outside Accounts Disclosure Form for all accounts in which that employee or an immediate family member has Beneficial Interest. All Employees are required to authorize the issuance of duplicate confirms and statements for all Securities accounts held away.

Annual Reporting Requirements

Every employee must submit an Outside Brokerage Account disclosure form annually.


Any report of a Securities Transaction for the benefit of a person other than the individual in whose account the transaction is placed may contain a statement that the report should not be construed as an admission by the person making the report that they have any direct or indirect beneficial ownership in the Security to which the report relates.

V. Other Outside Activities


Employees are prohibited from engaging in outside business or investment activities that may interfere with their duties with the firm. Outside business affiliations, including directorships of private companies, consulting engagements, or public/charitable positions, must be approved in writing by the Chief Compliance Officer.

Fiduciary Appointments

Approval must be obtained from the Chief Compliance Officer before accepting executorship, trusteeship, or attorney power, other than concerning a family member. Fiduciary appointments on behalf of family members must be disclosed at the inception of the relationship.

Creditors’ Committees

Employees are prohibited from serving on a creditors committee except as approved by the firm as part of their employment duties.


Employees should disclose any personal interest that might present a conflict of interest or harm the firm’s reputation.

VI. Chief Compliance Officer

Training and education regarding the Code of Ethics will occur periodically, but at least annually, by the CCO. All Employees are required to attend any training sessions or read any relevant materials.

VII. Compliance with the Code of Ethics

Compliance Officer Review

The Compliance Officer is responsible for investigating any suspected violation of the Code and shall report each investigation’s results to the Chief Executive Officer of MEANS immediately. Together with the Compliance Officer, the CEO is responsible for reviewing the results of any investigation of any reported or suspected violation of the Code.

Annual Reports

The Compliance Officer should review the Code at least once a year, in light of legal and business developments and experience in implementing the Code, and should report to the Chief Executive Officer of MEANS:

  • Any changes in the procedures made during the past year.
  • Identifying any violation requiring significant remedial action during the past year.
  • Identifying any recommended changes in existing restrictions or procedures based on its experience under the Code, evolving industry practices, or developments in applicable laws or regulations.


If the Compliance Officer and the CEO of Means determine that an employee has violated the Code following a report of the Compliance Officer, the Compliance Officer and the President of Means may impose sanctions and take other actions as they deem appropriate, including a letter of caution or warning, suspension of personal trading rights, suspension of employment (with or without compensation), fine, civil referral to the SEC, criminal referral, and termination of the employment of the violator for a cause.

Sole Authority

The Compliance Officer and the Means CEO have sole authority to determine the remedy for any Code violation.

Exceptions to the Code

Although exceptions to the Code may rarely, if ever, be granted, the Compliance Officer may grant exceptions to the Code’s requirements on a case by case basis if the Compliance Officer finds that the proposed conduct involves a negligible opportunity for abuse. All such exceptions must be in writing and must be reported as soon as practical to the Means CEO.

Compliance Certification

Each current employee and each newly-hired employee shall certify that they have received, read, and understand the Code of Ethics by executing the Certification of Compliance with the Code of Ethics form.

Also, annually, all employees may be required to re-certify that they have read and understood the Code, complied with the Code requirements, and reported all Securities, accounts, and transactions required to be disclosed or reported under the requirements of this Code.

Inquiries Regarding the Code of Ethics

The Compliance Officer should answer any questions about the Code of Ethics or any other compliance-related matters.