| 1. | Serve the financial interests of clients. All recommendations to clients and decisions on behalf of clients shall be solely in the interest of the clients. |
| 2. | Disclose fully to client services provided and compensation received. All financial relationships, direct or indirect, between consultants and investment managers, plan officials, beneficiaries, sponsors or others shall be fully disclosed. |
| 3. | Provide to clients all requested information as well as other information they may need to make informed decisions. All client inquiries shall be answered promptly, completely and truthfully. |
| 4. | Maintain the confidence of all information entrusted by the client to the fullest extent permitted by law. |
| 5. | Comply fully with all statutory and regulatory requirements affecting the delivery of consulting service to clients. |
| 6. | Endeavor to establish and maintain excellence in all aspects of investment management consulting (or all aspects of financial services to clients). |
| 7. | Maintain the highest standard of personal conduct. |
