Code of Ethics

We adhere to the CERTIFIED FINANCIAL PLANNER™ Board of Standards Ethics agreement.

The principles of its ethics agreement as follows:

Principle 1 – Integrity – Provide professional services with integrity.

Integrity demands honesty and candor which must not be subordinated to personal gain and advantage. Certificants are placed in positions of trust by clients, and the ultimate source of that trust is the certificant’s personal integrity. Allowance can be made for innocent error and legitimate differences of opinion, but integrity cannot co-exist with deceit or subordination of one’s principles.

Principle 2 – Objectivity – Provide professional services objectively.

Objectivity requires intellectual honesty and impartiality. Regardless of the particular service rendered or the capacity in which a certificant functions, certificants should protect the integrity of their work, maintain objectivity and avoid subordination of their judgment.

Principle 3 – Competence – Maintain the knowledge and skill necessary to provide professional services competently.

Competence means attaining and maintaining an adequate level of knowledge and skill, and application of that knowledge and skill in providing services to clients. Competence also includes the wisdom to recognize the limitations of that knowledge and when consultation with other professionals is appropriate or referral to other professionals necessary. Certificants make a continuing commitment to learning and professional improvement.

Principle 4 – Fairness – Be fair and reasonable in all professional relationships. Disclose conflicts of interest.
Fairness requires impartiality, intellectual honesty and disclosure of material conflicts of interest. It involves a subordination of one’s own feelings, prejudices and desires so as to achieve a proper balance of conflicting interests. Fairness is treating others in the same fashion that you would want to be treated.

Principle 5 – Confidentiality – Protect the confidentiality of all client information.
Confidentiality means ensuring that information is accessible only to those authorized to have access. A relationship of trust and confidence with the client can only be built upon the understanding that the client’s information will remain confidential.

Principle 6 – Professionalism – Act in a manner that demonstrates exemplary professional conduct.
Professionalism requires behaving with dignity and courtesy to clients, fellow professionals, and others in business-related activities. Certificants cooperate with fellow certificants to enhance and maintain the profession’s public image and improve the quality of services.

Principle 7 – Diligence – Provide professional services diligently.
Diligence is the provision of services in a reasonably prompt and thorough manner, including the proper planning for, and supervision of, the rendering of professional services.

Participation or Interest in Client Transactions and Personal Trading

Neither advisors, nor employees nor independent contractors of ours – “covered persons” – may make any transactions in a security that is being actively purchased or sold or is being considered for purchase or sale, on behalf of any of our clients, unless in accordance with the SWMS Trading Policy.

Non-Public Information Policy

We maintain and enforce the following written policies:

1. We will not use any material non-public information to effect securities transactions for any person.

2. We will document in writing any material non-public information we learn, which will be filed in the “MATERIAL, NON-PUBLIC, INFORMATION” folder and kept for a minimum of five years from the end of the calendar year in which we obtained the information.

Privacy Policy:

Our Commitment to Your Privacy: Protecting clients’ privacy is of paramount importance to Sirius Wealth Management Strategies, LLC (the “Firm”). It is the Firm’s policy that no private client financial information obtained by the Firm is sold or made available to third parties except that:

· Third parties may be used by the Firm to assist in the management or maintenance of client accounts (such as a custodian, broker or bank).

· Client information may be released to client’s accountancy, legal and other third party representatives at client’s direction;

· Client information may be released in accordance with applicable laws and regulations.
The Firm will not share non-public personal information about its clients with third parties without prior client consent, except for specific purposes described below. This notice explains the Firm’s collection, use and safeguarding of client information.

How The Firm Gathers Information: In connection with providing clients with investment management services, the Firm may obtain information about its clients from the following sources:

· Client agreements and other information that clients provide to the Firm, whether in writing, in person, by telephone, electronically or by any other means. This information may include a client’s name, address, phone number, email address, social security number, employment information, income, investment experience, and credit references;

· Personal tax returns provided by the client;

· Transactions on a client’s behalf. This information may include the client’s account balances, positions, investment interests and history;

· Consumer reporting agencies. This information may include account information and credit history; and

· Public sources.
Sharing Information with Third Parties: The Firm only discloses non-public client information to third parties when it is believed necessary for the Firm’s provision of services to you or as required or permitted by law, such as:

· If you request or authorize the disclosure of the information;

· To provide client account services or account maintenance;

· To respond to a subpoena or court order, judicial process, law enforcement or regulatory authorities;

· To perform services for the Firm or on its behalf to develop or maintain proprietary trading or other software;

· In connection with a proposed or actual sale, merger, or transfer of all or a portion of the Firm’s business or an operating unit;

· To help prevent fraud;

· With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants and auditors of the Firm;

· To comply with federal, state or local laws, rules and other applicable legal requirements; and

· Pursuant to any other exceptions enumerated in the California Information Privacy Act.
The Firm does not make any disclosure of client non-public personal information to other companies who may want to sell their products or services to you. For example, the Firm does not sell client lists and the Firm will not sell client names to catalogue companies.

Opt In – Opt Out Provision: If, at some point in the future, it becomes necessary to disclose any client personal information in a way that is inconsistent with this policy, the Firm is required by applicable law to provide clients with advance notice of the proposed disclosure. At that time, you will have the opportunity to either opt-in or opt-out of such disclosure.

Former Clients: This Privacy Policy continues to apply to all former clients.

To Whom This Policy Applies: This Privacy Policy applies to individuals who obtain or have obtained services from the Firm used primarily for personal, family or household purposes.

Our Security Practices and Information Accuracy: The Firm takes steps to safeguard client information. Access to the personal and account information of clients is restricted to its employees and agents for business purposes only. The Firm maintains physical, electronic and procedural safeguards to guard your personal information. Additionally, the Firm has internal controls to keep client information as accurate and complete as possible. If you believe that any information about you is not accurate, please contact the Firm.

Other Information: The Firm reserves the right to change this Statement of Privacy Policy. The examples contained within this Privacy Policy are illustrations and they are not intended to be exclusive. If you have any questions about this Privacy Policy, please contact Richard C. Chambers, Chief Compliance Officer at 650.276.7967.

Regulatory Disclosures:

Sirius Wealth Management Strategies, LLC (SWMS) may only transact business or render personalized investment advice in those states and international jurisdictions where we are registered, or have filed notice, or are otherwise excluded or exempted from registration requirements. Any communication with prospective clients residing in states or international jurisdictions where SWMS not registered or licensed shall be limited so as not to trigger registration or licensing requirements. We do not render or offer to render personalized investment advice or financial planning advice through this medium. This medium is limited to providing you with general information on our services and provides a way for you to contact us.

Past investment performance does not insure future results. Investing in the stock and bond markets is risky and principal, income, expenses, taxes, inflation, exchange rates, and total return fluctuate so an investment when redeemed may be worth less than its original cost. Nothing contained herein is to be construed as legal, accounting, or tax advice.

Terms and Conditions:

Sirius Wealth Management Strategies, LLC and its members, officers, directors, owners, shareholders, partners, employees, agents, representatives, licensors, advertisers, suppliers and service providers (collectively “SWMS”) provides this website (the “Site”) for informational purposes only. Use of and access to the Site and the information, materials, services, and other content available on or through the Site (“Content”) are subject to these terms of use and all applicable laws.

NO INVESTMENT ADVICE

The Content is for informational purposes only, you should not construe any such information or other material as legal, tax, investment, financial, or other advice. Nothing contained on our Site constitutes a solicitation, recommendation, endorsement, or offer by SWMS or any third party service provider to buy or sell any securities or other financial instruments in this or in in any other jurisdiction in which such solicitation or offer would be unlawful under the securities laws of such jurisdiction.

All Content on this site is information of a general nature and does not address the circumstances of any particular individual or entity. Nothing in the Site constitutes professional and/or financial advice, nor does any information on the Site constitute a comprehensive or complete statement of the matters discussed or the law relating thereto. SWMS is not a fiduciary by virtue of any person’s use of or access to the Site or Content. You alone assume the sole responsibility of evaluating the merits and risks associated with the use of any information or other Content on the Site before making any decisions based on such information or other Content. In exchange for using the Site, you agree not to hold SWMS, its affiliates or any third party service provider liable for any possible claim for damages arising from any decision you make based on information or other Content made available to you through the Site.

INVESTMENT RISKS

There are risks associated with investing in securities. Investing in stocks, bonds, exchange traded funds, mutual funds, and money market funds involves risk of loss. Loss of principal is possible. Some high risk investments may use leverage, which will accentuate gains and losses. Foreign investing involves special risks, including a greater volatility and political, economic and currency risks and differences in accounting methods. A security’s or a firm’s past investment performance is not a guarantee or predictor of future investment performance.

THIRD PARTY LINKED SITES

As a convenience to you, SWMS may provide hyperlinks to websites operated by third parties. When you select these hyperlinks you will be leaving the SWMS site. Because SWMS has no control over such sites or their content, SWMS is not responsible for the availability of such external sites or their content, and SWMS does not adopt, endorse and shall not be responsible or liable for any such sites or content, including advertising, products or other materials, on or available through such sites or resources. Other websites may provide links to the Site or Content with or without our authorization. SWMS does not endorse such sites and shall not be responsible or liable for any links from those sites to the Site or Content, or for any content, advertising, products or other materials available on or through such other sites, or any loss or damages incurred in connection therewith. SWMS may, in its sole discretion, block links to the Site and Content without prior notice.

YOUR USE OF THIRD PARTY WEBSITES AND CONTENT, INCLUDING WITHOUT LIMITATION, YOUR SUBMISSION OF DATA TO THE SITE AND YOUR USE OF ANY INFORMATION, DATA, ADVERTISING, PRODUCTS, OR OTHER MATERIALS ON OR AVAILABLE THROUGH SUCH WEBSITES, IS AT YOUR OWN RISK AND IS SUBJECT TO THEIR TERMS OF USE.

SITE AND CONTENT NOT WARRANTED

THE SITE AND CONTENT, ARE PROVIDED “AS IS” AND WITHOUT WARRANTIES OF ANY KIND. YOU BEAR ALL RISKS ASSOCIATED WITH THE USE OF THE SITE AND CONTENT, INCLUDING WITHOUT LIMITATION, ANY RELIANCE ON THE ACCURACY, COMPLETENESS OR USEFULNESS OF ANY CONTENT AVAILABLE ON THE SITE. SWMS AND ITS AFFILIATES, AND THEIR RESPECTIVE EMPLOYEES, OFFICERS, DIRECTORS, SHAREHOLDERS, PARTNERS, AGENTS, REPRESENTATIVES, LICENSORS, ADVERTISERS, SUPPLIERS AND SERVICE PROVIDERS, DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, WITHOUT LIMITATION, ALL WARRANTIES OF TITLE, NON-INFRINGEMENT, ACCURACY, COMPLETENESS, USEFULNESS, MERCHANTABILITY, AND FITNESS FOR A PARTICULAR USE, AND WARRANTIES THAT MAY ARISE FROM COURSE OF DEALING/PERFORMANCE OR USAGE OF TRADE.

LIMITATION OF LIABILITY

YOUR EXCLUSIVE REMEDY FOR DISSATISFACTION WITH THE SITE AND CONTENT IS TO STOP USING THE SITE AND CONTENT. SWMS IS NOT LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL OR PUNITIVE DAMAGES, UNDER ANY THEORY OF LIABILITY, INCLUDING WITHOUT LIMITATION, DAMAGES FOR LOSS OF PROFITS, USE, DATA, OR LOSS OF OTHER INTANGIBLES. IN PARTICULAR, AND WITHOUT LIMITATION, SWMS WILL NOT BE LIABLE FOR DAMAGES OF ANY KIND RESULTING FROM YOUR USE OF OR INABILITY TO USE THE SITE OR CONTENT.

While we try to maintain the integrity and security of the Site and the servers from which the Site is operated, we do not guarantee that the Site or Content is or remains secure, complete or correct, or that access to the Site or Content will be uninterrupted or error free. The Site and Content may include inaccuracies, errors and materials that violate or conflict with these Terms. Additionally, third parties may make unauthorized alterations to the Site or Content. If you become aware of any unauthorized third party alteration to the Site or Content, contact us at richc@siriuswm.com with a description of the material(s) at issue and the URL.

NOTICES, COMMUNICATIONS, AND ELECTRONIC SIGNATURES

You agree to be bound by any affirmation, assent or agreement that you transmit on or through the Site or any other aspect of SWMS’s services that you access by computer or other electronic device, including internet, telephonic and wireless devices, including but not limited to any consent you give to receive communications from us solely through electronic transmission. You agree that, when in the future you click on a “Submit” or “I agree” or other similarly worded “button” or entry field with your mouse, keystroke or other device, your agreement or consent will be legally binding and enforceable and the legal equivalent of your handwritten signature.

LIMITED RIGHT OF USE/OWNERSHIP OF CONTENT

You are permitted to use the Site and Content for your personal, non-commercial use only. The Site and Content are and shall remain the property of SWMS and are protected by copyright, trademark, patent, and/or other intellectual property, proprietary, work product rights and laws. You may use the Site and Content for your personal, non-commercial use, provided that you keep intact all copyright, trademark, patent and other proprietary notices. Except as expressly authorized in advance by SWMS in writing, you agree not to reproduce, modify or create derivative works based on, rent, lease, loan, sell, distribute, publish, publicly perform or display, reverse engineer, de-compile or dissemble, all or any part of the Site or Content.

Trade names, trademarks and service marks of SWMS include, without limitation, Sirius Wealth Management Strategies, LLC and any associated logos. All trademarks and service marks on the Site not owned by SWMS are the property of their respective owners. Nothing contained on the Site should be construed as granting, by implication, estoppel or otherwise, any license or right to use any of SWMS’s trade names, trademarks or service marks without our express prior written consent.

TERMINATION

SWMS, in its sole discretion, may terminate your access to or use of the Site and Content, at any time and for any reason. Your access to or use of the Site and Content may be terminated without notice. SWMS shall not be liable to you or any third party for any termination of your access to the Site or Content, or to any such information or files, and shall not be required to make such information or files available to you after any such termination.

RULES OF CONDUCT

Your use of the Site and Content is conditioned on your compliance with the rules of conduct set forth here. You will not:

• Use the Site or Content for any fraudulent or unlawful purpose.

• Interfere with or disrupt the operation of the Site or Content or the servers or networks used to make the Site and Content available; or violate any requirements, procedures, policies or regulations of such networks.

• Restrict or inhibit any other person from using the Site or Content (including without limitation by hacking or defacing any portion of the Site or Content).

• Use the Site or Content to advertise or offer to sell or buy any goods or services without SWMS’s express prior written consent.

• Reproduce, duplicate, copy, sell, resell or otherwise exploit for any commercial purposes, any portion of, use of, or access to the Site or Content.

• Modify, adapt, reverse engineer, de-compile/disassemble any part of the Site or Content.

• Remove any copyright, trademark or other proprietary rights notice from the Site or materials originating from the Site or Content.

• Frame or mirror any part of the Site or Content without SWMS’s express prior written consent.

• Create a database by systematically downloading and storing Content.

• Use any robot, spider, site search/retrieval application or other manual or automatic device to retrieve, index, “scrape,” “data mine” or in any way gather Content or reproduce or circumvent the navigational structure or presentation of the Site without the express prior written consent of SWMS.

INDEMNIFICATION

By accessing and using the Site and Content, you agree to indemnify, defend and hold harmless SWMS (specifically including its affiliates, and their respective members, officers, directors, owners, shareholders, partners, employees, agents, information providers, licensors and licensees) (collectively, the “Indemnified Parties”) from and against any and all claims, losses, costs and expenses (including attorneys’ fees) arising out of or relating to (a) any breach (or claim, that if true, would be a breach) by you of these Terms and (b) your use of or activities in connection with the Site. We reserve the right, at our own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you. You shall not enter into any settlement agreement which affects the rights of any of the Indemnified Parties or requires the taking of any action by any of them, without our prior written approval.

JURISDICTIONAL CONTEXT

The Site is controlled and operated by SWMS from the United States, and is not intended to subject SWMS to the laws or jurisdiction of any country or territory other than that of the United States. SWMS does not represent or warrant that the Site or any part thereof is appropriate or available for use in any particular jurisdiction other than the United States and only in those US states and territories where SWMS is registered or licensed or exempt from registration or licensing under applicable state or federal law. In choosing to access the Site, you do so on your own initiative and at your own risk, and you are responsible for complying with all local laws, rules and regulations. We may limit the Site’s availability to any person, geographic area or jurisdiction.

MODIFICATIONS

SWMS may amend the terms of use at any time in its discretion, by posting revisions on the Site.

Copyright Notice

All rights reserved. All material contained herein is copyright protected and may not be reproduced in any manner without the express written permission of the copyright owner. Certain text and articles: © 2000-2017 Garrett Planning Network, Inc., Sheryl Garrett, Principal. Certain text, graphics, and articles: © 2000-2017 Financial Planning Association, Inc. Certain text and graphics: © 2000-2017 National Association of Personal Financial Advisors. Other text, articles, and logos: © 2000-2017 Investor’s Capital Management, LLC and Sirius Wealth Management Strategies, LLC.

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