The goal of each firm's Investment Advisors' Code of Ethics is to set forth the policies and procedures required pursuant to Rule 204A-1 under the Investment Advisers Act of 1940 (the "Advisers Act"). The IA Code of Ethics is intended to assist the advisory firm's advisers and associates involved in investment advisory activities in meeting the high standards the firm follows in conducting its business. One of the advisory firm's most important assets is its reputation for integrity and professionalism. The responsibility of maintaining that reputation rests with all advisory firm associates.