Each employee of M.J. Smith and Associates shall always:

1. Serve in the best financial interests of our clients. All recommendations and decisions on behalf of our clients shall be solely in the best interest of our clients.

2. Disclose fully to our clients services provided and compensation alternatives and sources.

3. Provide our clients all requested information as well as other information needed to make informed investment decisions. Our client’s inquiries shall be answered to the best of our abilities in a prompt and accurate fashion.

4. Maintain the confidentiality of all information entrusted by our clients, to the fullest extent permitted by law.

5. Comply fully with all statutory and regulatory requirements issued by federal and state regulatory bodies and compliance requirements of our affiliated broker/dealer, Raymond James Financial Services, Inc.

6. Act with integrity, dignity, and honesty, and maintain the highest standards of ethics in all forms of professional conduct.

7. MJS shall perform professional services in a manner that is fair and reasonable to clients and shall disclose conflicts of interest in providing such services.

8. Maintain knowledge base through continuing education.

9. Personal securities holdings and transactions of all MJS’ employees shall be monitored regularly to verify that employees’ trading activity is not counter to our clients’ best interests.

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