As part of an internal compliance program, Armada Advisors is subject to a Code of Ethics and related policies and procedures imposing standards of business conduct, including requirements to put client's interests first and not to take inappropriate advantage of employment-related information. There are prohibitions on employees engineering better trades than clients and on trading in securities while in possession of related material, nonpublic information and reporting of personal securities transactions.

The goal is to minimize potential conflicts of interest between employees and clients, assuring compliance with applicable laws and regulations. Existing and prospective clients may obtain copies of the applicable Code of Ethics by mailing a written request to Armada Advisors.

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Potential Conflicts Of Interest

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There may be instances when employees may own or solicit some of the same securities held by its clients. Armada Advisors realizes that we have a fiduciary responsibility to our clients to act in their best interest. Additionally, we have opted not to act in a broker capacity; therefore, our advisors have no incentive or capability to recommend or to benefit from financial transactions in which they would receive commissions. Insurance transactions, however, are exempt from this. Our primary incentive is prudent financial money management for clients based upon an agreed upon fee schedule. As such, our advisors recommending the program receive compensation as a result of the client’s participation.

Armada Advisors may make charitable contributions or underwrite or sponsor charitable events at the request of others. It may also send corporate gifts or pay for meals and entertainment such as holiday baskets, dinners or tickets to cultural events for clients or prospective clients. Our employees may also be the recipients of such gifts. The giving and receipt of gifts and other benefits are subject to limitations under the Armada Advisors Code of Ethics.

No client assets are held by Armada Advisors. All clients must establish custodial relationships with outside entities like Fidelity or Charles Schwab & Co. These custodians provide computer access and other technology to manage the assets placed there. While on those platforms, we have access to research, literature, pricing, and other market data. In evaluating whether to recommend a custodian, Armada Advisors may take into account the costs, client needs, availability, familiarity, and depth of services offered. A conflict may arise because a majority of clients are with one particular custodian, and Armada Advisors is thus more familiar with its platform and services offered.