Code of Ethics

Maintaining the highest ethical standards is a guiding principle of Robinswood Financial

Robinswood Code of Ethics, Part I, Values 

Principle 1 — Integrity

All Robinswood team members shall offer and provide professional services with integrity.

All members of the Robinswood team are placed by clients in positions of trust and confidence. The ultimate source of such public trust is the Robinswood team’s personal integrity. In deciding what is right and just, a Robinswood team member should rely on his or her integrity as the appropriate touchstone. Integrity demands honesty and candor, which must not be subordinated to personal gain and advantage. Within the characteristic of integrity, allowance can be made for innocent error and legitimate difference of opinion; but integrity cannot co-exist with deceit or subordination of one’s principles. Integrity requires a Robinswood team member to observe not only the letter but also the spirit of this Code.

Principle 2 — Objectivity

All Robinswood team members shall be objective in providing professional services to clients.

Objectivity requires intellectual honesty and impartiality. It is an essential quality for any professional. Regardless of the particular service rendered or the capacity in which a Robinswood team member functions, a Robinswood team member should protect the integrity of his or her work, maintain objectivity, and avoid subordination of his or her judgment that would be in violation of this Code.

Principle 3 — Competence

All Robinswood team members shall provide services to clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which the team member is engaged.

One is competent only when he or she has attained and maintained an adequate level of knowledge and skill, and applies that knowledge effectively in providing services to clients. Competence also includes the wisdom to recognize the limitations of that knowledge and when consultation or client referral is appropriate. In addition to assimilating the common body of knowledge required and acquiring the necessary experience, all Robinswood team members shall make a continuing commitment to learning and professional improvement.

Principle 4 — Fairness

All Robinswood team members shall perform professional services in a manner that is fair and reasonable to clients, principals, partners, and employers and shall disclose conflict(s) of interest(s) in providing such services.

Fairness requires impartiality, intellectual honesty and disclosure of conflict(s) of interest(s). It involves a subordination of one’s own feelings, prejudices, and desires so as to achieve a proper balance of conflicting interests. Fairness is treating others in the same fashion that you would want to be treated and is an essential trait of any professional.

Principle 5 — Confidentiality

All Robinswood team members shall not disclose any confidential client information without the specific consent of the client unless in response to proper legal process, to defend against charges of wrongdoing by the Robinswood team member or in connection with a civil dispute between the Robinswood team member and client.

A client, by seeking the services of a Robinswood team member, will be interested in creating a relationship of personal trust and confidence with the Robinswood team member. This type of relationship can only be built upon the understanding that information supplied to the Robinswood team member or other information will be confidential. In order to provide the contemplated services effectively and to protect the client’s privacy, the Robinswood team member shall safeguard the confidentiality of such information.

Principle 6 — Professionalism

Because of the importance of the professional services rendered by Robinswood team members, there are attendant responsibilities to behave with dignity and courtesy to all those who use those services, fellow professionals and those in related professions. A Robinswood team member also has an obligation to cooperate with fellow Robinswood team members to enhance and maintain the profession’s public image and to work jointly with other team members to improve the quality of services. It is only through the combined efforts of all Robinswood team members in cooperation with other professionals, that this vision can be realized.

Principle 7 — Diligence

All Robinswood team members shall act diligently in providing professional services.

Diligence is the provision of services in a reasonably prompt and thorough manner. Diligence also includes proper planning for, and supervision of, the rendering of professional services. 

Principle 8 — Compliance

All Robinswood team members shall comply with all applicable federal securities laws, including the Investment Advisers Act of 1940 and rules adopted thereunder. Team members are expected to understand and adhere to the policies and procedures established by Robinswood, cooperate with compliance reviews, promptly report known or suspected violations of this Code or applicable law, and uphold the firm’s fiduciary duty to place client interests first.

Our strategy has proven to be consistent, steady, and repeatable. Best of all, our strategy requires no ability to forecast the future.

Robinswood Code of Ethics, Part II, Compliance

SEC Rule 204A-1 Compliance Provisions

Principle 9 – Fiduciary Duty

Robinswood and all Supervised Persons owe a fiduciary duty to clients. Every Supervised Person shall place client interests ahead of personal interests at all times and shall:

• Act with honesty, integrity, competence, and fairness.
• Seek to avoid conflicts of interest whenever possible.
• Fully disclose material conflicts of interest when they cannot be avoided.
• Never misuse a position of trust for personal benefit.
• Conduct business consistent with the Advisers Act and all applicable federal securities laws.

Principle 10 – Personal Securities Transactions

Robinswood recognizes that personal investing by employees may create actual or apparent conflicts of interest. Access Persons are required to conduct personal securities transactions in a manner that avoids any conflict with client interests.

Access Persons shall:
• Place client transactions before personal transactions.
• Avoid trading on material nonpublic information.
• Avoid taking inappropriate advantage of investment opportunities presented by virtue of their employment.
• Comply with all reporting and pre-clearance requirements established by the Chief Compliance Officer (“CCO”)

Access Persons

An “Access Person” includes:
• Any supervised person who has access to nonpublic information regarding client purchases or sales of securities;
• Any supervised person involved in making securities recommendations to clients; or
• Any person designated by the CCO because of his or her access to confidential investment information.

Personal Holdings Reports

Each Access Person shall submit:
• An Initial Holdings Report within ten (10) days of becoming an Access Person.
• An Annual Holdings Report at least once every twelve (12) months.
• Such additional reports as requested by the CCO.

Reports shall include all Reportable Securities and brokerage accounts as required under Rule 204A-1.

Quarterly Transaction Reports

Within thirty (30) days after the end of each calendar quarter, every Access Person shall submit a report of all reportable securities transactions during the quarter or certify that no reportable transactions occurred.

Duplicate brokerage statements or electronic feeds may satisfy this requirement if approved by the CCO.

Brokerage Account Reporting

All Access Persons shall disclose all brokerage accounts in which they have any direct or indirect beneficial ownership and shall promptly notify the CCO before opening any new brokerage account.

The CCO may require duplicate confirmations and account statements to be sent directly from the broker-dealer.

Initial Public Offerings and Private Placements

Access Persons must obtain written approval from the CCO before acquiring beneficial ownership in:
• Securities acquired in an Initial Public Offering (IPO); or
• Securities acquired in a Limited Offering or Private Placement.

Approval may be denied whenever the investment presents an actual or potential conflict with client interests.

Prohibited Conduct

No Supervised Person may:
• Employ any device, scheme, or artifice to defraud any client.
• Make any untrue statement of a material fact or omit a material fact necessary to make statements not misleading.
• Engage in any act, practice, or course of business that operates as a fraud or deceit upon any client.
• Engage in manipulative practices with respect to client accounts.
• Front-run, trade ahead of clients, or otherwise misuse knowledge of pending client transactions.
• Misappropriate investment opportunities belonging to clients.

Insider Trading

No employee shall purchase or sell any security while in possession of material nonpublic information or communicate such information to another person in violation of applicable law.

All personnel shall immediately report any suspected possession or misuse of material nonpublic information to the CCO.

Reporting Violations

All Supervised Persons are required to promptly report any known or suspected violation of this Code or applicable federal securities laws to the CCO.

Reports may be made without fear of retaliation. Retaliation against any individual who reports a concern in good faith is prohibited.

Sanctions

Violations of this Code may result in disciplinary action, including:
• Letter of caution or warning;
• Mandatory training;
• Disgorgement of profits;
• Suspension of personal trading privileges;
• Financial penalties where appropriate;
• Suspension or termination of employment; and
• Referral to regulatory authorities when warranted.

Annual Certification

Each Supervised Person shall:
• Acknowledge receipt of this Code upon hire;
• Certify annually that he or she has read, understands, and complied with the Code; and
• Promptly disclose any known violations.

Administration

The Chief Compliance Officer is responsible for administering this Code, reviewing required reports, granting pre-clearance approvals, maintaining required records, investigating violations, and reporting material violations to firm management as appropriate.

The CCO shall maintain records required under Rule 204A-1 and Rule 204-2, including:
• Current and historical versions of the Code;
• Employee acknowledgments;
• Holdings and transaction reports;
• Pre-clearance approvals;
• Records of violations and disciplinary actions; and
• Documentation supporting the administration of this Code.