Code of Ethics

The following Code of Ethics shall apply to Vetta Investments, its partners, officers and employees (collectively “Adviser”).

• Adviser will strive to be as unbiased as possible in providing investment advice to clients.
• Adviser shall practice on a fee-only basis and shall not accept any referral fees or compensation that is contingent upon the purchase or sale of a financial product.
• Adviser shall treat all client data in the strictest confidence and will be diligent in safeguarding sensitive information.
• Adviser shall uphold its fiduciary responsibility at all times and always place the best interest of its clients first.
• Adviser will strive to comply with all applicable laws and regulations.
• Adviser shall fully describe its compensation to clients and shall make clients aware of the approximate total cost of investments.
• Adviser will always strive to avoid conflicts of interest. When avoidance is not possible, Adviser will disclose possible conflicts of interest to client.
• Adviser shall conduct itself in a professional manner at all times and shall always strive to treat clients with dignity, respect and courtesy.