The Investment Advisers Act of 1940 imposes a fiduciary duty on investment advisers.  As a fiduciary, KAM recognizes its responsibilities to provide financial services to clients with the highest standards of professional conduct and integrity.  KAM’s requires all its employees and affiliates to act with the utmost integrity in all dealings with clients.  KAM provides the Code of Ethics presented below to all clients and prospective clients.

Code of Ethics

• No owner, employee, or affiliate of KAM shall buy or sell securities for personal portfolio(s) if the decision to buy or sell is derived in whole or in part by reason of KAM employment or affiliation, unless the information used is also available to the investing public upon reasonable inquiry.
  
  
• No owners, employees, or affiliates of KAM shall prefer their own interest to that of advisory clients.
  
  
• Clients of KAM have the unrestricted right to decline to implement any recommendation or advice given by KAM.
  
  
• KAM requires all owners, employees, or affiliates of KAM to act in accordance with all applicable federal and state regulations governing registered investment advisors.
  
  
• KAM expects its owners, employees, or affiliates to conduct personal securities transactions in accordance with the firm’s Code of Ethics and requires that they avoid any actual or perceived conflict of interest with clients. Employees or affiliates who have any doubt about even the appearance of a conflict of interest shall consult with the Chief Compliance Officer of KAM before taking any action that may result in a perceived or actual conflict of interest.
  
  
• Any KAM employee or affiliate who violates KAM’s Code of Ethics may be subject to termination of employment with KAM.

Standards of conduct for KAM employees require that KAM employees will not

• Defraud a client in any manner
  
  
• Mislead a client, either by misstatement of material facts or by avoiding statement of material facts,
  
  
• Engage in any act, practice, or conduct that operates or would operate to defraud or deceive a client
  
  
• Engage in any act, practice, or conduct intended to manipulate clients, or
  
  
• Engage in any act, practice, or conduct intended to manipulate the availability or price of a security.

As a fiduciary, KAM acknowledges its affirmative duty of care, loyalty, honesty, and good faith to act always and only in the best interest of its clients.  KAM achieves this duty by avoiding conflicts of interest and by disclosing fully all material facts concerning any potential conflict of interest that may arise with any client.