Code of Ethics

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

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.

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