Item 11 – Code of Ethics

FIA and/or its representatives recommend the same investments that are held in their own accounts. However, it is against their policy to take an opposite position on a recommendation to a client. FIA and/or its representatives buy and sell for itself securities that it also recommends to clients. Since most all securities traded are DFA mutual funds, or exchange traded index funds, conflicts of interest do not arise.

FIA has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at FIA must acknowledge the terms of the Code of Ethics annually, or as amended.

FIA’s clients or prospective clients may request a copy of the firm’s Code of Ethics by contacting Kenneth L. Fortney CPA/PFS.

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