Code of Ethics

Monere Investments

Investment Advisor Code of Ethics

Monere Wealth Management, Inc. (Monere) is a registered investment advisor. Monere Wealth Management, Inc. and Monere Investments, Inc. (a registered broker –dealer) are wholly owned subsidiaries of Monere Holdings, Inc. (a parent company). The Monere Investment Advisor Code of Ethics (“IA Code of Ethics”) is supplemental to the general compliance materials applicable to all Monere personnel. If the Client has any questions about the contents of this brochure, please contact the Monere Compliance Department at (312) 585-3850 or your designated Wealth Advisor.

Investment Advisor Code of Ethics

This Code of Ethics applies to the activities of Monere Wealth Management, Inc. the Investment Advisory firm, a registered Investment Advisor under the Investment Advisors Act of 1940.

Honesty and integrity are hallmarks of Monere Wealth Management, Inc. (“Monere”) which seeks the highest standards of ethics and conduct in all of its business relationships.

U.S. Securities and Exchange Commission’s (“SEC”) rules and regulations require that Monere establish standards and procedures for the detection and prevention of certain conflicts of interest, including activities by which persons having knowledge of the investments and investment intentions of Monere might take advantage of that knowledge for their own benefit. Implementation and monitoring of these standards inevitably places some restrictions on the freedom of the investment activities of those people.

Monere is adopting this Code of Ethics to ensure no one is taking advantage of their position, or even giving the appearance of placing their own interests above that of their accounts or clients.

This Code of Ethics’ objectives are:

Providing standards of honest and ethical conduct,
Promoting compliance with applicable State laws, rules and regulations and
Facilitating prompt internal reporting of violations of this Code of Ethics, and
Deterring wrongdoing.

This Code of Ethics applies to all Supervised Persons of Monere, who act as an investment advisor as defined by the SEC rules in providing investment advice to advisory clients, unless otherwise noted below. “Supervised Persons” means any officer, director or employee of Monere, who is subject to the supervision and control of the investment advisor.

Although he or she is not expected to know details of each law governing Monere’s business, they are expected to be familiar with and comply with the company-wide policies and procedures as they apply to their business unit, and when in doubt, to seek advice from supervisors, managers or other appropriate personnel as outlined in the Policy Manual.

Supervised persons are reminded that they must maintain in confidence and prevent the misuse of material non-public information.

All Supervised Persons must be familiar with and abide by all Monere’s employee trading policies. Access Person means any supervised person of this Investment Advisor who (1) has access to nonpublic information regarding any advisory clients’ purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund or (2) is involved in making securities recommendations to advisory clients, or who has access to such recommendations that are non public.

Supervised Persons generally are not deemed by Monere to be Access Persons. The Chief Compliance Officer is required to compile and maintain a list of Monere’s Access Persons, and will promptly notify any Monere Supervised Person who is or becomes an Access Person for these purposes:

Once identified, each Access Person is required to provide the following reports to the Investment Advisor’s Compliance Department:

Holdings Reports: A report of the Access Person’s current securities and holdings that contain the title and type of security, number of shares, the principal amount of each reportable security; the name of any broker, dealer or bank which the access person maintains an account in which any securities are held for the Access Person’s direct or indirect benefit; and the date the Access Person submits the report.
Submission requirements: The holdings report must be submitted to the Chief Compliance Officer no later than 10 days after the person becomes and Access Person, and the information must be current. Thereafter, at least once each 12 months a similar submission is required.
Broker trade confirmations and/or account quarterly statements for each account over which the Access Person has direct or indirect influence or control must be submitted to the Chief Compliance Officer no later than 30 days after the end of each calendar quarter.

Pre-clearance of trades is required for all Access Persons, with an Affirmation that they will not front run or otherwise jeopardize the trading pattern within client’s accounts.

Compliance with this Code of Ethics is a condition of employment with Monere Wealth management, Inc. Taking into consideration all relevant circumstances, the management of Monere will determine what action is appropriate for any breach of the provisions of the Code by a supervised or access person.

Possible actions include, but are not limited to, a letter of censure, fine, suspension, or termination of employment.

Supervised persons are required to report any violations of the Code promptly to the Branch Manager or Designated Supervisor and to the Chief Compliance Officer.

Further, employees are required to self-report their own violations. Monere encourages such reporting and will take steps to prevent any retaliation against reporting employees.

Reports filed pursuant to the Code will be maintained in strict confidence but will be reviewed by the appropriate Senior Management or designated Supervisor, the Compliance and/or Legal Department and may be subject to regulatory review to verify compliance with the Code. Additional information may be required to clarify the nature of particular transactions.

Monere shall maintain the records listed below for a period of five (5) years at Monere’s principal office in an easily accessible place:

A list of all access persons currently and within the last five years;
transaction and holdings reports submitted by access persons;
signed acknowledgements;
copies of any amendments to the Code of Ethics;
records of violations of the code and any action taken;

Employees are required to sign and return the Code of Ethics acknowledgement to Compliance Department attesting receipt of copies of the code and attesting that they have read and understand it.

For more information, please contact the Client’s advisor or:

Monere Wealth Management, Inc.

Compliance Department

20 N. Martingale Road, Suite 450

Schaumburg, IL 60173

E-mail: info@monereinvestments.com