Piedmont Street Management: Registered Investment Adviser
85 Piedmont Street
San Francisco, CA 94117
(415) 731-2944
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Code of Ethics

January 2, 2006

This Code of Ethics is adopted by Piedmont Street Management Inc, for this firmís financial planning, investment advisory and management, and related businesses and activities. It is intended to comply with SEC requirements and Advisers Act Rule 204A-1.

This firm adopts and will act in accordance with the Financial Planning Association Code of Ethics:

  1. Integrity. This firm will offer and provide professional services with integrity.

  2. Objectivity. This firm will be objective in providing professional services to clients.

  3. Competence. This firm will provide services to clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which this firm is engaged.

  4. Fairness. This firm will perform professional services in a manner that is fair and reasonable to clients, principals, partners, and employers and shall disclose conflicts of interest in providing such services.

  5. Confidentiality. This firm will not disclose any confidential client information without the specific consent of the client unless in response to proper legal process, to defend against charges of wrongdoing by this firm or in connection with a civil dispute between this firm and client.

  6. Professionalism. This firmís conduct in all matters shall reflect credit upon the profession.

  7. Diligence. This firm will act diligently in proving professional services. Diligence is the provision of services in a reasonably prompt and thorough manner. Diligence also includes proper planning for and supervision of the rendering of professional services.

This firm also adopts and will act in accordance with the following, adapted from the Investment Counsel Association of America, Best Practices for Investment Adviser Codes of Ethics:

  1. General Statement of Principles and Philosophy. This firm will operate under the Financial Planning Code of Ethics (above). It will keep a highest fiduciary duty to clients and the obligation of firm personnel to uphold that fundamental duty. It will at all times place the interest of clients first. All firm personnel securities transactions will be conducted in such a manner as to be consistent with the code of ethics and avoid any actual or potential conflict of interest or any abuse of a personís position of trust and responsibility. This firmís investment management personnel should not take inappropriate advantage of their position. This firm holds to the fiduciary principle that information concerning the identity of security holdings and financial circumstances of clients is confidential. This firm holds that independence in the investment decision-making process is paramount.

  2. Persons Covered by the Code. This code applies to the owner/proprietor, who is the only Access Person. There will not be any other employees or persons who provide advice on behalf of the adviser and are subject to the adviserís supervision and control.

  3. Securities Covered by the Code. Covered Securities means any stock, bond, future, investment contract or any other instrument that is considered a ďsecurityĒ under the Investment Advisers Act.

  4. Standards of Business Conduct. This firm recognizes its fiduciary responsibility to clients, and responsibility to comply with applicable federal and California securities laws. Firm persons are not permitted, in connection with the purchase or sale, directly or indirectly, of a security held or to be acquired by a client:

    a. To defraud such client in any manner;
    b. To mislead such client, including by making a statement that omits material facts;
    c. To engage in any act, practice or course of conduct which operates or would operate as a fraud or deceit upon such client;
    d. To engage in any manipulative practice with respect to such client; or
    e. To engage in any manipulative practice with respect to securities, including price manipulation.

  5. Conflicts of Interest. As a fiduciary, this firm has an affirmative duty of care, loyalty, honesty, and good faith to act in the best interests of its clients. This firm will try to avoid conflicts of interest and will fully disclose all material facts concerning any conflict that does arise with respect to any client. The firm will not display inappropriate favoritism of one client over another client that would constitute a breach of fiduciary duty. The firmís Access Person will not use knowledge about pending or currently considered securities transactions for clients to profit personally, directly or indirectly, as a result of such transactions, including by purchasing or selling such securities.

  6. Insider Trading. The firm prohibits any trading, either personally or on behalf of others, while in possession of material, nonpublic information. Firm personnel will not communicate material nonpublic information to others in violation of law.

  7. Personal Securities Transactions. The firm is allowed to participate in initial public offers. Trading by the Access Person will be restricted to large, publicly-traded companies where such trading is unlikely to have more than a negligible impact on prices or liquidity.

  8. Gifts and Entertainment. A conflict of interest occurs when the personal interest of firm personnel interfere or could potentially interfere with their responsibilities to the firm and its clients. Firm personnel should not accept inappropriate gifts, favors, entertainment, special accommodations, or other things of material value that could influence their decision-making or make them feel beholden to a person or firm.

  9. Confidentiality. Information concerning the identity of security holdings and financial circumstances of clients is confidential, subject to permitted or required disclosures.


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