Management and employees of MVP have committed to a Code of Ethics (“Code”) that adheres to the current standards set forth by the CFA Institute. MVP’s Code defines acceptable behavior for management and employees of MVP and addresses conflicts that may arise. The Code reflects MVP’s overriding guiding principle that it is the Company’s responsibility to act in the best interest of their clients. As such, investment transactions for clients must have priority over investment transactions in MVP employee accounts. In addition, MVP does not allow any employee to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our clients. As MVP’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information, no advisory representative or other employee, officer or director of MVP may recommend any transaction in a security or its derivative to advisory clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. MVP’s Code is based on the guiding principle that the interests of the client are our top priority. MVP’s officers, directors, advisors, and other employees have a fiduciary duty to our clients and must diligently perform that duty to maintain the complete trust and confidence of our clients. When a conflict arises, it is our obligation to put the client’s interests over the interests of either employees or the Company. The Code applies to “supervised” persons. “Supervised” persons are employees who have access to non-public information regarding any client purchase or sale of securities, or non-public information regarding the portfolio holdings, who are involved in making securities recommendations to clients, or who have access to such recommendations that are non-public.The firm will provide a copy of its Code of Ethics to any client or prospective client upon request.
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