IIS representative and employees shall operate their securities business under the following guidelines. IIS and all who represent it shall view this code of ethics as a guide in all of their professional actions, and in all aspects of their business. People associated with Interpacific Investors Services shall operate their business with the highest degree of integrity. The securities business is one of trust and confidence on the part of all concerned. A client must be able to trust the representative they deal with, the broker/dealer they deal with, and the product vendors they deal with. Likewise, a representative must be trusted by the client, the firm, and the product vendors. All persons associated with Interpacific must recognize the importance of this integrity, and realize the responsibility they have to their clients, their fellow representatives, and the firm to preserve this level of trust and confidence. People associated with Interpacific Investors Services shall deal with a client objectively. All person's shall view it as their responsibility to ensure that the client's interests are always placed first. Our client's best interest's are ultimately our own best interests. Recommending a product to the client for any other reason than it is in their best interests is unacceptable. People associated with Interpacific Investors Services shall recognize their responsibility to deal in areas where they have competence. It shall be the responsibility of all associated with Interpacific Investors to attain and maintain an adequate level of knowledge and skill, as well as the ability to recognize the need to seek advice in areas where they do not have the required level of knowledge and skill. All associated with Interpacific shall recognize that a client's financial success is predicated on many things, and they are often interrelated. People associated with Interpacific Investors Services shall deal with all contacts, be they clients, prospects, fellow representatives, peers, product vendors, and all other who they have a professional relationship in a fair manner. Fairness requires a subordination of one's own feelings and prejudices to the pursuit of impartiality and proper resolution and disclosure of conflicts of interest. IIS and all who are associated with it shall endeavor to "over-disclose" rather than "under-disclose". The ultimate test of this fairness doctrine is to treat others in the fashion you would wish to be treated, and is an essential trait of a professional. All people associated with Interpacific Investors Services shall endeavor to conduct themselves in all manners in such a way as to enhance the Professionalism and Reputation of Interpacific Investors Services and those people associated with it. Associated persons have the responsibility to behave with dignity and courtesy. The reputation of each individual reflects on each and every other individual associated with our firm. Associated people shall protect the confidential nature of the information given to them by their clients, unless otherwise required by consent or legal process. Associated people shall understand their responsibility to act in a prompt and diligent manner. Professionalism requires a unified message to clients, prospects, and our peers in the industry. Professionalism is not negative competition, either against a fellow IIS representative or a competitor. Professionalism allows for disagreement among professionals, but requires disagreement to be constructive, ultimately to benefit the client in the long run. All associated persons with Interpacific Investors Services shall endeavor to live to both the letter and the spirit of this code of ethics. I have read, understand and shall abide by this Code of Ethics. Violations of this code of ethics could result in disciplinary action, up to and including dismissal. Signed: ____________________________________ ____/____/____ Associated Person