Code of Ethics

At RAULIN INC., we place a high premium on acting within the letter and spirit of the laws and regulations that govern our business. By operating with integrity in everything we do, we earn and keep our clients’ trust.

Introduction and Fundamental Responsibilities

As a Registered Investment Adviser, RAULIN INC. and its employees recognize and accept the obligation not only to comply with the mandates and requirements of all applicable laws and regulations, but also to act in an ethically responsible manner in all aspects of our business practice and personal affairs.   Most importantly, RAULIN INC. and its employees are cognizant of and committed to the performance of the fiduciary duties owed to each and every client.

All employees act for the benefit of the client and must place client interests before their own.  RAULIN INC. and its employees have a duty of loyalty to our clients and must act with reasonable care and exercise prudent judgment when acting on behalf of a client.  Employees shall not engage in any conduct involving dishonesty, knowingly make misrepresentations or commit any act that reflects adversely on their honesty, trustworthiness or professional competence.

A critical component of our fiduciary duty is to avoid conflicts of interest, as well as the appearance of conflicts of interest.  Accordingly, all employees must avoid activities, interest or relationships that might interfere or appear to interfere with making decisions in the best interests of clients.

Personal Securities Trading

Rule 204A-1 of the Investment Advisers Act of 1940 requires certain persons, deemed “access persons,” to periodically report their personal securities transactions and holdings.  An access person is a supervised person who has access to nonpublic information regarding clients’ purchases or sales, is involved in making securities recommendations to clients or has access to such recommendations that are nonpublic.  This Rule is designed to prevent the misuse of material nonpublic information regarding the adviser’s securities recommendations, as well as client securities holdings and transactions. 

Neither Raulin Inc. nor its employees analyze, recommend or trade securities for client transactions.  RAULIN INC. personnel do not have access to nonpublic information regarding clients’ purchase or sale of securities nor do they have access to such recommendations that are nonpublic.  As such, RAULIN INC. is able to avoid the potential conflicts of interest relating to personal securities transactions that Rule 204A-1 was designed to prevent.

Based on the foregoing, RAULIN INC. personnel are not required to report their personal securities trading.  However, all employees should be mindful that they are prohibited by federal securities laws, and subsequently by this Code of Ethics, from taking advantage of or communicating material nonpublic information, commonly referred to as “insider trading,” in any capacity.

Violations of the Code

Raulin Inc. views violations of this Code to be a serious breach of firm rules.  Any employee who has become aware of a violation, or a potential violation, should promptly report such violation to the Chief Compliance Officer.  Failure to comply with the Code of Ethics may result in disciplinary action, including termination of employment.

Internal Dissemination of the Code

Each employee shall be provided a copy of the RAULIN INC. Code of Ethics and any amendments to the Code.  Each employee must, in turn, provide the Chief Compliance Officer with written acknowledgment that they have received a copy of the Code, including any amendments.  Each employee shall so certify that he or she has read, understands and shall comply with the Code.  Employees with any questions regarding the Code, or any question regarding the application of the Code to a particular situation, should contact the Chief Compliance Officer.

Recordkeeping

The Chief Compliance Officer shall keep copies of the Code, records of violations of the Code and copies of employees’ written acknowledgement of receipt of the Code.  Such records shall be retained for a minimum of five years from the end of the fiscal year during which the last entry was made on such record, in an easily accessible place, the first two years at Raulin Inc.