The purpose of the Code of Ethics is to establish, maintain, and enforce a standard of conduct which applies to all supervised persons and complies with all federal securities laws that govern the conduct of advisory personnel with regard to personal trading, protection of material nonpublic information, and sets the tone for the ethical culture of the George M. Hiller Companies, LLC.
I. Core Values
The core values of the George M. Hiller Companies, LLC center upon the principles of integrity, trustworthiness, honesty, fairness, and respect. It is the mission of the George M. Hiller Companies, LLC to provide the highest quality professional and objective financial counsel in the areas of investment management, estate planning, and personal financial planning designed to help clients improve their financial condition and achieve long-term financial goals.
II. Standard of Conduct
All employees of the George M. Hiller Companies, LLC are required to meet their fiduciary obligation by acting only in the best interest of clients. Employees have an affirmative duty of prudent care, loyalty, and acting in good faith. They are not permitted to defraud or mislead a client in any manner, to engage in any manipulative practice, or to deliberately omit material facts.
All fulltime employees are regarded as access persons and are required, as such, to abide by the requirements of the Code of Ethics. The Chief Compliance Officer will determine whether a part-time employee should be considered an access person based on the duties and responsibilities of their position.
As a condition of employment, employees are required to comply with all federal securities laws as they apply to the services offered by the George M. Hiller Companies, LLC.
Employees of the George M. Hiller Companies, LLC who have earned a designation or are members of an organization, whereas the use of such designation or membership in the organization is contingent upon adherence to a Code of Ethics, must also comply with the standards set forth by those organizations and their respective Codes of Ethics.
III. Protection of Material Nonpublic Information
Employees are prohibited from trading, either personally or on behalf of others while in possession of material, nonpublic information and are prohibited from communicating such information to others. An employee in possession of material nonpublic information must notify the Chief Compliance Officer immediately upon receipt of such information.
Information regarding securities recommended for client accounts, whether on a discretionary or non-discretionary basis, is considered material nonpublic information. All employees shall treat such information as strictly confidential.
IV. Personal Securities Reports
All access persons are required to report personal securities holdings within 10 days of becoming an access person and annually thereafter. This information must be current as of a date not more than 45 days prior to the date of submission. Holdings reports must included all reportable securities in addition to all open-end mutual funds. Annual holdings reports are required as of December 31st of each year and must be submitted no later than 30 days following the end of the period.
All access persons must report, on a quarterly basis, their personal trading activities for all reportable securities to the Chief Compliance Officer within 30 days after the close of the quarter. Employees are also required to report trading activity for any person sharing their household and any account over which the employee has trading authority.
All access persons are required to provide duplicate or copies of statements for all accounts with reportable securities.
Annual holdings reports are required for all accounts of which the access person has any direct or indirect influence or control, includes all accounts held in the name of any immediate family member living in the same household, and any account over which the employee has trading authority.
Reportable securities are all securities except the following:
Direct obligations of the U.S. Government
Money market funds
High quality short-term debt instruments and cash equivalents
Open-end mutual funds, provided that the George M. Hiller Companies, LLC does not act as Investment Adviser to the fund.
Variable product sub-accounts, provided that the underlying investment product is an unaffiliated mutual fund.
V. Personal Trading Procedures
All employees are required to conduct personal trading in a manner consistent with the requirements of the Code of Ethics to avoid any potential conflict of interest or any abuse of the employee’s position of trust in the George M. Hiller Companies, LLC.
Employees are required to obtain written approval from the Chief Compliance Officer prior to acquiring any securities through an initial public offering or private placement.
Employees are discouraged from day trading because it runs counter to the investment philosophy of the firm and it is a distraction from servicing client accounts.
The purchase or sale of a security by any employee is forbidden if the transaction is executed with the intention of buying or selling on a price change that may be caused by transactions made on behalf of any account for which the George M. Hiller Companies, LLC acts as Investment Adviser.
Employees trading securities in their personal accounts shall maintain order tickets showing the transaction details, specifically including the time such order was entered.
The George M. Hiller Companies, LLC does not allow front-running of client trades.
VI. Reporting Violations of the Code of Ethics
The George M. Hiller Companies, LLC requires all employees to report Code of Ethics violations to the Chief Compliance Officer. The firm will not permit retaliation of any kind by, or on behalf of, the Firm or any employee against any individual for making good faith reports of violations to this Code of Ethics or any securities laws.
VII. Adherence to the Code of Ethics
The Chief Compliance Officer will oversee adherence to the Code of Ethics. Under some circumstances, the Chief Compliance Officer may override certain provisions of the Code of Ethics; however, documentation should be maintained to support that decision.