Code of Ethics

Code of Ethics

The Investment Advisers Act of 1940 imposes a fiduciary duty on investment advisers. As a fiduciary, Alexander Financial Planning, Inc., (AFPI) has a duty of utmost good faith to act solely in the best interests of each of our clients. Our clients entrust us with their funds, which in turn places a high standard on our conduct and integrity. Our fiduciary duty compels all employees to act with the utmost integrity in all of our dealings. This fiduciary duty is the core principle underlying the Code of Ethics and represents the expected basis of all our dealings with our clients.

AFPI is committed to the general principals of honesty, integrity, professionalism, and putting the interests of our clients first. We hold the identity of the security holdings and financial circumstances of our clients to be confidential, and maintain our independence in the investment recommendations and decisions on behalf of our clients.

The Core Principles of the Code of Ethics:

1. The interests of clients will be placed ahead of the firm’s or any employee’s own investment interest.

2. Employees are expected to conduct their personal securities transactions in accordance with the Personal Trading Policy and will strive to avoid any actual or perceived conflict of interest with the client. Employees with questions regarding the appearance of a conflict with a client should consult with the CCO before taking actions that may result in an actual conflict.

3. Employees will not take inappropriate advantage of their position with the firm.

4. Employees are expected to act in the best interest of each our clients.

5. Employees are expected to comply with federal security laws.

Protection of Material, Non-public Information

As more fully discussed within our Client Privacy Policy, employees are expected to exercise diligence and care in maintaining and protecting our clients’ nonpublic, confidential information.

Employees are also expected not to divulge information regarding AFPI’s securities recommendations or client holdings to any individual outside the firm, except:

1. As necessary to complete transactions or account changes (for example, communications with brokers and custodians);

2. As necessary to maintain or service a client or his/her account (for example, communications with client’s accountant);

3. With various service providers providing administrative functions for AFPI (such as our technology service provider), only after we have entered into contractual agreement that prohibits the service provider from disclosing or using confidential information except as necessary to carry out its assigned responsibilities and only for that purpose; or

4. As permitted by law.

Chief Compliance Officer

Thresa R. Alexander is the CCO of AFPI and has the authority to enforce the company’s Code of Ethics. As noted above, employees are expected to conduct themselves with the utmost integrity and to avoid any actual or perceived conflict with our clients.

Supervision of Employees

• Employees are prohibited from receiving any gift, gratuity, hospitality or other offering of more than de Minimis value from any person or entity doing business with AFPI. This policy generally excludes items or events where the employee has reason to believe there is legitimate business purpose. De Minimis is defined as any value less than $100.

• Any employee wishing to serve as director for an outside company (public or private) must first seek approval of the CCO. The CCO will determine whether such service is consistent with the interests of the firm and our clients.

• Any employee wishing to engage in business activities outside of AFPI’s business must seek approval from the CCO and, if requested, provide periodic reports to the CCO summarizing those outside business activities.

Annual Employee Acknowledgement

New employees must acknowledge they have read, understand, and agree to comply with this Code of Ethics and Personal Trading Policy. All employees are required to acknowledge as such annually in connection with the firm’s annual policy manual acknowledgement process.

Additional Codes & Oaths followed by Alexander Financial Planning, Inc.

The Company abides by the Code of Ethics and Professional Responsibility stipulated by the Certified Financial Planner Board of Standards and contained in the CFP® Licensee Manual, which is incorporated herein by reference. In addition, the Company has adopted the CFP® Practice Standards stipulated by the Certified Financial Planner Board of Standards.

The company abides by the National Association of Personal Financial Advisors (NAPFA) Fiduciary Oath, which is incorporated herein by reference.