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Code of Ethics

This Code of Ethics is a combination of the professional Code of Ethics as established by the Financial Planning Association (FPA) (Principles 1 through 7) and is supplemented as noted by several portions of the Code of Ethics of the National Association of Personal Financial Advisors (NAPFA) (Principles 3 and 8) and hereby incorporates the CFA Institute’s Asset Manager Code of Professional Conduct. This Code of Ethics is an expression of the financial planning and investment management professions’ recognition of the firm’s responsibilities to clients, the public, colleagues, and to employers. These principles apply to all Principals, employees, and independent contractors of Limoges Investment Management PC (collectively referred to below as “Advisors”) and provide guidance to them in the performance of their professional services.

Principle 1 - Integrity

Principle 1 - Integrity

Professional services shall be offered and provided with integrity. The Advisor may be placed by clients in positions of trust and confidence. The ultimate source of such public trust is the Advisor’s personal integrity. In deciding what is right and just, an Advisor should rely upon his or her integrity as the appropriate touchstone. Integrity demands honesty and candor, which must not be subordinated to personal gain and advantage. Within the characteristic of integrity, allowance can be made for innocent error and legitimate difference of opinion; but integrity cannot co-exist with deceit or subordination of one's principles. Integrity requires an Advisor to observe not only the letter but also the spirit of this Code.

Principle 2 - Objectivity

Principle 2 - Objectivity

Advisors shall be objective in providing professional services to clients. Objectivity requires intellectual honesty and impartiality. It is an essential quality for any Advisor. Regardless of the particular service rendered or the capacity in which an Advisor functions, the Advisor should protect the integrity of his or her work, maintain objectivity, and avoid subordination of his or her judgment that would be in violation of this Code.

Principle 3 - Competence

Principle 3 - Competence

An Advisor shall provide services to clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which the Advisor is engaged. One is competent only when he or she has attained and maintained an adequate level of knowledge and skill, and applies that knowledge effectively in providing services to clients. Competence also includes the wisdom to recognize the limitations of that knowledge and when consultation or client referral is appropriate. In addition to assimilating the common body of knowledge required and acquiring the necessary experience, an Advisor shall make a continuing commitment to learning and professional improvement. An Advisor shall not provide advice in areas where he/she is not capable (last sentence from NAPFA guidelines).

Principle 4 - Fairness

Principle 4 - Fairness

An Advisor shall perform professional services in a manner that is fair and reasonable to clients, principals, partners, and employers and shall disclose any conflict of interest in providing such services. Fairness requires impartiality, intellectual honesty, and a subordination of one's own feelings, prejudices, and desires so as to achieve a proper balance of conflicting interests. Fairness is treating others in the same fashion that you would want to be treated and is an essential trait of any professional. As part of our Fairness Principle all principals and employees are required to notify the firm's Chief Compliance Officer (CCO) if he/she intends to engage in any securities transaction (other than that for an open-ended mutual fund) so that the CCO can ensure that transaction does not occur within three (3) days of any trade in the same security which may be contemplated to occur in a client account.

Principle 5 - Confidentiality

Principle 5 - Confidentiality

An Advisor shall not disclose any confidential client information without the specific consent of the client unless in response to proper legal process, to defend against charges of wrongdoing by the Advisor or in connection with a civil dispute between the Advisor and client. A client, by seeking the services of an Advisor, may be interested in creating a relationship of personal trust and confidence with the Advisor. This type of relationship can only be built upon the understanding that information supplied to the Advisor or other information will be confidential. In order to provide the contemplated services effectively and to protect the client's privacy, the Advisor shall safeguard the confidentiality of such information.

Principle 6 - Professionalism

Principle 6 - Professionalism

An Advisor’s conduct in all matters shall reflect credit upon the profession. Because of the importance of the professional services rendered by Advisors, there are attendant responsibilities to behave with dignity and courtesy to all those who use those services, fellow professionals, and those in related professions. An Advisor also has an obligation to cooperate with fellow Advisors to enhance and maintain the profession's public image and to work jointly with other Advisors to improve the quality of services. It is only through the combined efforts of all Advisors in cooperation with other professionals, that this vision can be realized.

Principle 7 - Diligence

Principle 7 - Diligence

An Advisor shall act diligently in providing professional services. Diligence is the provision of services in a reasonably prompt and thorough manner. Diligence also includes proper planning for and supervision of the rendering of professional services.

Principle 8 – Regulatory Compliance

Principle 8 – Regulatory Compliance

An Advisor shall strive to maintain conformity with legal regulations. Services provided by the Advisor are regulated by the Securities And Exchange Commission (SEC). Compliance is required by the regulating authorities and is in keeping with the protection of client interests.

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  • Limoges Investment Management PC
  • 10000 NE 7th Ave, Suite 205
  • Vancouver, WA 98685

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