Code and Standards

Last updated: December 31, 2025

"Our Code of Ethics and Standards of Professional Conduct are instrumental aspects of our core values. Maintaining the highest ethical and professional standards, regardless of job function, cultural differences, or local conditions, is an essential element of success. We expect that Partners, Associates, and Committee Members also uphold these Code and Standards. Any violation of which may result in disciplinary sanctions such as the revocation of employment or other form of affiliation."

Fitzpatrick Securities LLC dba Fitzpatrick™

CODE OF ETHICS

Partners, Associates, and Committee Members ("they", "themselves", "their" or “Affiliates”) should:

Act with integrity, competence, diligence, respect and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the investment profession, and other capital markets participants within the public and private sectors.

Place the integrity of the investment profession and the interests of clients above their own personal interests.

Use reasonable care and exercise independent professional judgment when conducting investment analysis, making recommendations, taking investment actions, and engaging in other professional activities - our investment process.

Practice (and encourage others to practice) in a professional and ethical manner that reflects well on themselves and the investment profession.

Promote the integrity and viability of the global capital markets for the ultimate benefit of society.

Maintain and improve their own competence and strive to maintain and help improve the competence of other investment professionals, as well.

STANDARDS OF PROFESSIONAL CONDUCT

PROFESSIONALISM

Knowledge of the Law
Affiliates should understand and comply with all applicable laws, rules, and regulations of any governmental, regulatory organization, licensing agency, or professional association governing their professional activities including the Fitzpatrick™ Code of Ethics and Standards of Professional Conduct.

In the event of conflict, Affiliates must comply with the more strict law, rule, or regulation. Affiliates must not knowingly participate or assist in and must dissociate from any violation of such laws, rules, or regulations.

Independence and Objectivity
Affiliates should use reasonable care and judgment to achieve and maintain independence and objectivity in their professional activities.

Affiliates must not offer, solicit, or accept any gift, benefit, compensation, or consideration that reasonably could be expected to compromise their own or another’s independence and objectivity.

Misrepresentation
Affiliates must not knowingly make any misrepresentations relating to investment analysis, recommendations, actions, or other professional activities.

Misconduct
Affiliates must not engage in any professional conduct involving dishonesty, fraud, or deceit or commit any act that reflects adversely on their professional reputation, integrity, or competence.

INTEGRITY OF CAPITAL MARKETS

Material Nonpublic Information
Affiliates who possess material nonpublic information that could affect the value of an investment must not act or cause others to act on the information.

Market Manipulation
Affiliates must not engage in practices that distort prices or artificially inflate valuations with the intent to mislead market participants.

DUTIES TO CLIENTS

Loyalty, Prudence, and Care
Affiliates have a duty of loyalty to their clients and must act with reasonable care and exercise prudent judgment. Partners, Associates, and Committee Members must act for the benefit of their clients and place their clients’ interests before their employer’s or their own interests.

Fair Dealing
Affiliates must deal fairly and objectively with all clients particularly when providing investment analysis, making investment recommendations, taking investment action, or engaging in other professional activities.

Suitability
Affiliates are in an advisory relationship with a client, they must:

Make a reasonable inquiry into a client’s or prospective client’s investment experience, risk and return objectives, and financial constraints prior to making any investment recommendation, or taking investment action and must reassess and update this information regularly.

Determine that an investment is suitable to the client’s financial situation and consistent with the client’s written objectives, mandates, and constraints before making an investment recommendation or taking investment action.

Judge the suitability of investments in the context of the client’s total portfolio.

When Affiliates are responsible for managing a portfolio to a specific mandate, strategy, or style, they must make only investment recommendations or take only investment actions that are consistent with the stated objectives and constraints of the portfolio.

Performance Presentation
When communicating investment performance information, Affiliates must make reasonable efforts to ensure that it is fair, accurate, and complete.

Preservation of Confidentiality
Affiliates must keep information about current, former, and prospective clients confidential unless:

The information concerns illegal activities on the part of the client or prospective client; or

Disclosure is required by law; or

The client or prospective client permits disclosure of the information.

DUTIES TO EMPLOYERS

Loyalty
In matters related to their employment, Affiliates must act for the benefit of their employer and not deprive their employer of the advantage of their skills and abilities, divulge Confidential Information, or otherwise cause harm to their employer.

Additional Compensation Arrangements
Affiliates must not accept gifts, benefits, compensation, or consideration that competes with or might reasonably be expected to create a conflict of interest with their employer’s interest unless they obtain written consent from all parties involved.

Responsibilities of Supervisors
Affiliates must make reasonable efforts to ensure that anyone subject to their supervision or authority complies with applicable laws, rules, regulations, and the Code and Standards.

INVESTMENT ANALYSIS, RECOMMENDATIONS, AND ACTIONS

Diligence and Reasonable Basis
Affiliates must:

Exercise diligence, independence, and thoroughness in analyzing investments, making investment recommendations, and carrying out investment actions.

Have a reasonable and adequate basis, supported by appropriate research and investigation, for any investment analysis, recommendation, or action.

Communication with Clients and Prospective Clients
Affiliates must:

Disclose to clients and prospective clients the basic format and general principles of the investment processes they use to analyze investments, select securities, and construct portfolios and must promptly disclose any changes that might materially affect those processes.

Disclose to clients and prospective clients significant limitations and risks associated with the investment process.

Use reasonable judgment in identifying which factors are important to their investment analyses, recommendations, or actions and include those factors in communications with clients and prospective clients.

Distinguish between fact and opinion in the presentation of investment analysis and recommendations.

Record Retention

Affiliates must develop and maintain appropriate records to support their investment analyses, recommendations, actions, and other investment-related communications with clients and prospective clients.

CONFLICTS OF INTEREST

Disclosure of Conflicts

Affiliates must make full and fair disclosure of all matters that could reasonably be expected to impair their independence and objectivity or interfere with respective duties to their clients, prospective clients, and employer. Partners, Associates, and Committee Members must ensure that such disclosures are prominent, are delivered in plain language, and communicate the relevant information effectively.

Priority of Transactions

Investment transactions for clients and employers must have priority over investment transactions in which an Affiliate is the beneficial owner.

Referral Fees

Affiliates must disclose to their employer, clients, and prospective clients, as appropriate, any compensation, consideration, or benefit received from or paid to others for the recommendation of products or services.

RESPONSIBILITIES AS A PARTNER, ASSOCIATE, OR COMMITTEE MEMBER

Conduct as Partners, Associates, and Committee Members
Affiliates must not engage in any conduct that compromises the reputation or integrity of Fitzpatrick or the integrity, validity, or security of the legal status or relations of Fitzpatrick.

Referencing the Firm
When referencing Fitzpatrick, Affiliates must not misrepresent Fitzpatrick or disclose Confidential Information.

Acknowledge and Accept

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If you have questions, please contact:

team(at)fitzpatrick-securities(dot)com | +1 (888) FITZSEC

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