Employees and Advisors of the Company will commit to act in the best interests of clients, and deal with them honestly, fairly and professionally. An Advisor shall at all times demonstrate the following Code of Conduct and ethical standards:

1.1 Competence

• To be committed to achieve your full individual potential by participating regularly in opportunities for both professional development and personal growth.

• To continually strive to maintain and improve knowledge, skills, and competence, and to provide advice to clients only on matters in which they are proficient.

1.2 Professionalism

• To provide services and products in a manner consistent with the obligations of professional conduct, and in a manner that reflects positively on the Advisor, the Company, the carriers and the industry.

• To understand, comply and abide by the letter and spirit of applicable Federal and Provincial laws, regulations and established policies of governmental agencies, regulator, licensing agency, and the Company. An Advisor will not knowingly condone, participate in, or assist any violation of any laws, rules, regulations, or policies, and an Advisor will not engage in any conduct involving dishonesty, fraud, deceit, misrepresentation, unfair or deceptive acts or practices, or commit any act prohibited by law, regulation, or the Company.

• To cooperate and be responsive to requests from the Company, and regulators in any investigations relating to business practices, conduct or disciplinary hearings.

1.3 Objectivity

• To assess options in a prudent manner in keeping with how an objective third party would evaluate what is in the best interest of clients.

• To make every effort to provide impartial and complete information to clients regarding their financial needs.

1.4 Integrity

• To act in the best interests of clients with the highest level of integrity and always place a client’s interests above your own.

• To consistently make unbiased recommendations with no pressure for the client to purchase unsuitable products.

1.5 Fairness

• To disclose all sources of compensation along with any potential conflicts of interest to clients for recommendations made, services performed, or referrals provided.

• To treat all individuals with fairness, dignity, and respect without discrimination.

1.6 Confidentiality

• To hold the content of client meetings in complete confidence, and to ensure that all personal client information is managed in keeping with current privacy legislation.

• To be particularly careful to guard private information when various meetings involve clients who know and associate with each other.

• To understand and adhere to the Company’s privacy policies at all times in order to protect sensitive client information in a fully responsible manner.