Protecting Client privacy is very important to ChappelWood Financial Services (CFS). The Advisor views protecting its Clients’ private information as a top priority and, pursuant to the requirements of the federal Gramm-Leach-Bliley Act, the Advisor has instituted policies and procedures to ensure that customer information is kept private and secure.

 

CFS does not disclose any nonpublic personal information about its Clients or former customers to any nonaffiliated third parties, except as permitted by law. In the course of servicing a Client's account, CFS may share some information with its service providers, such as transfer agents, custodians, broker-dealers, accountants, and lawyers.

 

CFS restricts internal access to nonpublic personal information about the Client to those associated persons of the Advisor who needs access to that information in order to provide services to the Client. As emphasized above, it has always been and will always be the Advisor's policy never to sell information about current or former customers or their accounts to anyone. It is also the Advisor's policy not to share information unless required to process a transaction, at the request of a Client, or as required by law.

 

CFS has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its Clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition against rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at CFS must acknowledge the terms of the Code of Ethics annually, or as amended.

 

CFS anticipates that, in appropriate circumstances, consistent with Clients’ investment objectives, it may recommend to Clients or prospective Clients, the purchase or sale of securities in which CFS, its affiliates and/or Clients, directly or indirectly, have a position of interest. CFS’ employees and persons associated with CFS are required to follow CFS’ Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of CFS and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for CFS’ Clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of CFS will not interfere with (i) making decisions in the best interest of CFS’ Clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would not materially interfere with the best interest of CFS’ Clients. In addition, the Code requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as CFS’ clients, there is a possibility that employees might benefit from market activity by a Client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between CFS and its Clients.

 

Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis when consistent with CFS’ obligation of best execution. In such circumstances, the affiliated and client accounts will share commission costs equally and receive securities at a total average price. CFS will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order.

 

Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order.

 

CFS’ Clients or prospective clients may request a copy of the firm's Code of Ethics by contacting CFS.

 

It is CFS’ policy that the firm will not affect any principal or agency cross securities transactions for client accounts. CFS will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an advisor, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated hedge fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment advisor in relation to a transaction in which the investment advisor, or any person controlled by or under common control with the investment advisor, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an advisor is dually registered as a broker-dealer or has an affiliated broker-dealer.