Code of Ethics

Code of Ethics

As part of holding the CFA and CFP professional designations, we must adhere to a strict set of ethical guidelines and standards of professional conduct. A requirement of a designation or not, we think it makes good sense to communicate where we stand ethically. Below is our firm’s Code of Ethics.

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I will not engage in any conduct involving dishonesty, fraud, deceit, or commit any act that reflects adversely on my integrity, trustworthiness, or professional competence.

If I provide investment advice to clients or prospective clients, I will make a reasonable inquiry into the investment experience, risk and return objectives, and financial constraints of the client or prospective client before to making any investment recommendation or taking investment action and will reassess and update this information at least annually. If I am responsible for managing a portfolio to a specific mandate, strategy, or style, I will only make investment recommendations or take investment actions that are consistent with the stated objectives, and constraints of the portfolio.I will exercise diligence, independence and thoroughness in conducting investment analysis, making investment recommendations, and taking investment actions; and I will have a reasonable and adequate basis, supported by appropriate research and investigation, for making any investment analysis, recommendation, and taking any action.

I will create and maintain appropriate records to support my investment analyses, recommendations, actions, performance, and other investment-related communications with clients and prospective clients.

Upon request I will disclose to clients and prospective clients the basic format and general principles of the investment processes by which investments are analyzed, securities are selected, and portfolios are constructed and will promptly disclose any changes that might materially affect those processes. I will use reasonable judgment in identifying which factors are important to client investment analyses, recommendations, or actions and include those factors in communications with clients and prospective clients.

I will make full and fair disclosure of all matters that could reasonably be expected to impair my independence and objectivity or interfere with my respective duties to Highland Investment Advisors, LLC, clients, or prospective clients. I will ensure that disclosures are prominent, are delivered in plain language, and communicate the relevant information effectively.

I will not knowingly make any statement that misrepresents facts relating to investment analysis, recommendations, actions, or other professional activities.

I will not make or imply any assurances or guarantees regarding any investment except to communicate accurate information regarding the characteristics and terms of the investment instrument and the issuer’s obligations under the instrument.

When I communicate investment performance information, I will make reasonable efforts to ensure that it is fair, accurate, and complete.

I will keep information about current, former, and prospective clients confidential unless: 1) the information concerns illegal activities on the part of the client or prospective client, 2) disclosure is required by law, or 3) the client or prospective client provides written permission allowing disclosure of the information.

I will place the interests of the firm before my own and will not deprive the firm of the advantage of my skills and abilities, divulge confidential information, or otherwise cause harm to the firm.

I will comply with the policies and procedures established by the firm to the extent that there is no conflict with applicable laws, rules, and regulations.

I will endeavor to understand and comply with all applicable laws, rules, and regulations of any government, governmental agency, regulatory organization, licensing agency, or professional association governing professional activities. I will not knowingly participate or assist in, and will dissociate myself from, any violation of such laws, rules, or regulations.

I will make reasonable efforts to detect and prevent violations of applicable laws, rules, and regulations by anyone subject to my supervision or authority.

If I possess material nonpublic information related to the value of an investment I will not act, or cause others to act, on the information, until that information is made public.

I will not offer, solicit, or accept any gift, benefit, compensation or consideration that could be reasonably expected to compromise my own or another’s independence and objectivity. I will not accept gifts, benefits, compensation, or consideration that competes with, or might reasonably be expected to create a conflict of interest with the firm unless I obtain written consent.

I will comply with trading restrictions for securities listed on the various restricted lists of the affiliate, as communicated to me by the firm’s compliance officer.

I will provide the firm’s compliance officer with duplicate trade confirmations and account statements at least quarterly for all personal securities accounts. I will provide copies of all brokerage account statements to the firm’s compliance officer when I first become an access person (initial report). I acknowledge in writing that all personal securities accounts and securities holdings have been reported to the firm’s compliance officer.

I acknowledge that my personal securities transaction reports will be reviewed to assess whether I have followed internal procedures, to include the comparison of personal trading to any restricted lists, and an analysis to determine if clients are receiving terms as favorable as those given myself when trading the same security, and a review to determine if client accounts with the same objectives as my own have similar quality of performance and a similar percentage of profitable trades.

I will not trade securities in my personal account(s), or accounts of family members or affiliates, two business days before trading the same securities for clients (i.e., front-running), and thereby receiving better prices.

I will not invest in IPO’s prior to secondary trading, and must receive pre-clearance to invest in private placements by the firm’s compliance officer.

I will promptly report any observed violations of this Code of Ethics to the firm’s compliance officer.