Conflict of Interest

The Investment Adviser acts in a fiduciary capacity and endeavors to avoid any actual or potential conflict of interest while rendering investment advisory services.

The Investment Adviser follows a fee-only advisory model and does not receive commissions, referral fees, incentives, distribution income, or any other form of consideration from product issuers, distributors, or other third parties in relation to the advice provided to clients.

In the event any actual or potential conflict of interest arises, including conflict arising from any other business activity, association, holding, or relationship that may affect objectivity, the same shall be appropriately disclosed to the client.

The Investment Adviser shall take reasonable steps to identify, manage, mitigate, and where necessary avoid such conflicts so that the client’s interests remain protected at all times.

The Investment Adviser shall maintain confidentiality of client information and shall not use or disclose such information except as required under applicable law or with the prior consent of the client.