Tems of Use

  1. Introduction.  All references to “the Company” related to both the company as an entity and to its employees.
  2. Responsibility to Act in Accordance with Biblical Principles.  The Company has been founded on Christian principles as outlined in the Bible and shall continue to be managed in this way. This is the highest possible standard and the Company strives to keep it in all dealings with clients and service providers.
  3. Responsibility to Comply With All Applicable Securities Laws. All employees shall comply with applicable federal securities laws. Violations federal securities laws or this Code of Ethics shall constitute grounds for dismissal.
  4. Duty to Provide All Supervised Persons with the Code of Ethics and any Amendments. The CCO shall provide all supervised persons with a copy of the Code of Ethics and any amendments upon commencing employment and annually thereafter.
  5. Duty to Keep Written Acknowledgment of Receipt of the Code and any Amendments. Supervised persons must sign a copy of the Code of Ethics and any amendments each year indicating that they have received a copy, have read and understood it, and agree to comply with its provisions and return. The signed copy shall be given to the CCO and retained in the Company’s records.
  6. Client Receipt of Code of Ethics. The Code of Ethics shall be given to all new clients and to all client or prospective clients upon request. The Code shall be referenced in the ADV Part II.
  7. Responsibility.   It is the responsibility of all employees to ensure that the Company conducts its business with the highest level of ethical standards and in keeping with its fiduciary duties to its clients.
  8. Duty to Clients.    The Company has a duty to exercise its authority and responsibility for the benefit of its clients, to place the interests of its clients first, and to refrain from having outside interests that conflict with the interests of its clients. The Company must avoid any circumstances that might adversely affect or appear to affect its duty of complete loyalty to its clients.
  9. Confidentiality of Client Financial Information.  Employees must comply with the Company Privacy Policy, which stipulates that all information about clients and former clients is strictly confidential. The Company will not disclose any nonpublic personal information about a Client to any nonaffiliated third party unless the Client expressly gives permission to the Company to do so.  The Client in writing must grant such permission, or denial of permission, to the Company.  A copy of the permission/denial document will be filed in the Client file.
  10. Prohibited Acts
    1. Employing any device, scheme or artifice to defraud;
    2. Making any untrue statement of a material fact;
    3. Omitting to state a material fact necessary in order to make a statement, in light of the circumstances under which it is made, not misleading;
    4. Engaging in any fraudulent or deceitful act, practice or course of business; or,
    5. Engaging in any manipulative practices.
  11. Conflicts of Interest.   The Company has a duty to disclose potential and actual conflicts of interest to clients. A conflict of interest occurs when the personal interests of employees interfere or could potentially interfere with their responsibilities to the firm and its clients.
  12. Gifts. Gifts having a value over $100.00 or gifts of cash or cash equivalents will not be accepted from persons or entities doing business with the Company nor given to them. No gift of extravagant entertainment may be given or received by an employee. The sole source of revenue for the company shall be fees collected from clients.
  13. Political and Charitable Contributions. No employee shall consider the Company’s current or anticipated business relationships as a factor in soliciting political or charitable contributions.
  14. Use of Disclaimers.   The Company shall not attempt to limit liability for willful misconduct or gross negligence through the use of disclaimers.
  15. Marketing and 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.
  16. Suitability.    The Company shall only recommend those investments that it has a reasonable basis for believing are suitable for a client, based upon the client’s particular situation and          circumstances. In addition, clients will be instructed to immediately notify the Company of any significant changes in their situation or circumstances so that the Company can respond appropriately.
  17. Duty to Supervise.   Advisers Act Section 203(e)(5)  The Chief Compliance Officer is responsible for ensuring adequate supervision over the activities of all persons who act on the Company’s behalf.   Specific duties include, but are not limited to:
    1. Establishing procedures that could be reasonably expected to prevent and detect violations of the law by its advisory personnel;
    2. Analyzing its operations and creating a system of controls to ensure compliance with applicable securities laws;
    3. Ensuring that all advisory personnel fully understand the Company’s policies and procedures; and,
    4. Establishing an annual review system designed to provide reasonable assurance that the Company’s policies and procedures are effective and are being followed.
  18. Personal Securities Transactions.

    1. The Company shall not place orders before clients, sell to clients any investment in which the Company has a financial interest, or profit at the expense of clients (excluding fees).
    2. A record shall be kept of all securities transactions by principals and all supervised persons and must include the title and exchange ticker symbol or CUSIP, type of security, number of shares and principal amount, interest rate and maturity, price, nature of transaction, the name of the broker-dealer or bank transacting the security and the date of the report.
    3. All personal securities transactions must be reported no later than 30 days after the end of a calendar quarter to the CCO and reviewed by the CCO.
    4. No principal or supervised person shall maintain or trade in a securities account outside of Cornerstone Investment Services.
    5. No employee may participate in an initial public offering or private placement.
    6. The CCO shall periodically review personal securities transactions.
  19. Personal Securities Holdings Reports.
    1. A record shall be kept of all securities held by employees and must include the title and exchange ticker symbol or CUSIP, type of security, number of shares and principal amount, interest rate and maturity, price, nature of transaction, the name of the broker-dealer or bank transacting the security and the date of the report.
    2. All personal securities transactions must be reported no later than 30 days after the end of a calendar quarter to the CCO and reviewed by the CCO.
    3. The CCO will periodically review personal securities holdings reports.
  20. Insider Trading. No employee shall trade for themselves or on behalf of others on the basis of material non-public information. Non-public information includes information on the personal information of clients, their holdings, information on companies of which the client may have knowledge, and any Company recommendations regarding the finances or holdings and transactions of clients.
  21. Reporting of Violations.Any violation of the Code of Ethics shall be reported promptly to the CCO.