Investment Advisor Representatives ("IAR") of Green Pastures Wealth Management LLC must accomplish all personal securities transactions in a manner that avoids a conflict of interests with its clients, in accordance with the Advisor's Personal Trading Policy, and report personnel securities transactions at least quarterly to the Advisor.
IAR's must avoid actions or activities that allow (or appear to allow) profit or benefit from your position with Green Pastures Wealth Management LLC to self, family or acquaintance, or that bring into question your independence or judgment.
IAR's must comply with all applicable federal securities laws, including the prohibitions against the misuse of material non-public information, which includes information relating to issuers as well as to Green Pastures Wealth Management LLC securities recommendations and client securities holdings and transactions, in conducting yourself and the operations of Green Pastures Wealth Management LLC.
IAR's must report any violations of this code of ethics promptly to your chief compliance officer and where necessary any broker-dealer as required, and where necessary to appropriate regulatory authority.
This code of ethics does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not absolve Green Pastures Wealth Management LLC personnel from liability for personal trading or other conduct that violates a fiduciary duty to advisory clients.
Specific Requirements Of Access Persons (Investment Advisor Representatives and Employees and any other associate who may have access to client information) of Green Pastures Wealth Management LLC:
A. Prohibition Against Fraud, Deceit And Manipulation
Representatives of Green Pastures Wealth Management LLC may not, in connection with the purchase or sale, directly or indirectly, of a security held or to be acquired by any client account:
1. Employ any device, scheme or artifice to defraud the client account;
2. Make to the client any untrue statement of a material fact or omit to state to the client a material fact necessary in order to make the statements made, in light of the circumstances under which they are made, not misleading:
3. Engage in any act, practice or course of business which would operate as a fraud or deceit upon the client; or
4. Engage in any manipulative practice with respect to securities or a client.
Two of the most common risks associated with personal securities transactions are front-running and trading opposite a client account. For example, front-running would include the purchase of a security any time within seven days ahead of when a client account purchases the same security or the sale of a security any time within seven days ahead of when a client account sells the same security. An example of trading opposite a client account would include the sale of a security any time within seven days after a client account purchases the same security or the purchase of a security any time within seven days after a client account sells the same security.
B. Limits On Accepting Or Receiving Gifts
In order to protect the reputation and integrity of Green Pastures Wealth Management LLC, access persons shall not accept any gift of more than nominal value (totaling less than $100 over a 12 month period) from any existing or prospective client, broker, persons who regulate, advise or render services to Green Pastures Wealth Management LLC nor offer any such gifts.
This provision does not include:
(1) Occasional meals, tickets to a sporting event or the theatre, or normal business entertainment, if the person or entity providing the entertainment is present; and
(2) Any payment or reimbursement for professional training or educational meetings.
C. Political And Charitable Contributions
Access Persons may not make political contributions for the purpose of obtaining or retaining advisory contracts with government entities relating to private pension plans or municipal securities offerings. Green Pastures Wealth Management LLC will take reasonable steps to ensure that any political contributions made by it or its supervised persons are not intended to obtain or retain advisory business.
E. Interpretation Of Provisions
The Executive Officer (Leeland F. Gray, Jr.) of Green Pastures Wealth Management LLC may, from time to time, adopt such interpretations of this code of ethics as it deems appropriate.
F. Acknowledgment Of Receipt And Annual Certification
Each IAR will receive a copy of this Code (Code Of Ethics) and any subsequent amendments to the Code, and must acknowledge receipt of the Code in writing. In addition, each person is required to certify annually that he/she (i) has read and understands the Code, (ii) is aware that he/she is subject to the provisions of this Code, (iii) has complied with the Code at all times during the previous calendar year, and (iv) has, during the previous calendar year, reported all holdings and transactions that he/she is required to report pursuant to the Code.
In recognition of the trust and confidence placed in Green Pastures Wealth Management LLC by its clients, and because the Advisor believes that its operations should benefit its clients, Green Pastures Wealth Management LLC has adopted the following universally applicable principles:
A. Client's interests are paramount;
B. Green Pastures Wealth Management LLC places client interests before its own and constantly acts in the best interest of the Advisor's clients; and
C. The Advisor will always attempt to recognize and act in the best interest of its clients.
The Investment Advisers Act of 1940 imposes a fiduciary duty on Registered Investment Advisors. Green Pastures Wealth Management LLC places each client's interests as the paramount consideration in all decisions, actions and methods of providing services as a portion of fulfilling its fiduciary duty to clients.
This document will outline both our Fiduciary Duty, as well as, our compliance with rule 201A-1 of the Act.
Green Pastures Wealth Management LLC | 145 Eden Hill Road | Easton, CT 06612 | Phone 203.452.8100 | Toll Free 866.479.3258
Copyright 2014 - 2019 Green Pastures Wealth Management LLC. All Rights Reserved.
This communication is issued by Green Pastures Wealth Management LLC ("GPWM"). The material contained on this website is for informational purposes only and GPWM is not soliciting any action based upon such material. It is not guaranteed as to accuracy, nor is it a complete statement of the financial products or markets referred to. Opinions expressed are subject to change without notice. GPWM may maintain long or short positions in some of the financial instruments referred to. Unless stated specifically otherwise, this is not a recommendation, offer, or solicitation to buy or sell a security and any prices or quotations contained herein are indicative only. Material accessible through this website is not to be construed as investment advice, nor does it constitute a representation that the investments described herein are suitable or appropriate for any person. To the extent permitted by law, GPWM shall not be held liable for improper or incorrect use of data or information contained in any electronic publications. Information, data and related graphics contained in electronic publications are not legal documents and are not intended to be used as such. GPWM gives no warranty, expressed or implied, as to the accuracy, reliability, utility or completeness of any information contained in any electronic document. Past performance is no guarantee of future results. GPWM offers no accounting, tax, or legal advice. GPWM is a Connecticut Registered Investment Advisor which may only transact business where it is properly registered, or qualifies for an exemption or exclusion from registration requirements. GPWM accepts clients nationally per applicable state registration regulations and the "de minimis" exception.
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