Code of Ethics

The Advisory Group of San Francisco, LLC (“AGSF”) has adopted the following Code of Ethics.

This Code of Ethics is to establish the highest principles and standards. These principles are general statements expressing the ethical and professional ideals AGSF is expected to display in its professional activities. As such, the principles are aspirational in character and provide a source of guidance

Principle 1 – Integrity: Provide professional services with integrity

Integrity demands honesty and candor, which must not be subordinated to personal gain and advantage. Professionals are placed in positions of trust by clients, and the ultimate source of that trust is the professional’s personal integrity. Allowance can be made for innocent error and legitimate differences of opinion, but integrity cannot co-exist with deceit or subordination of one’s principles.

Principle 2 – Objectivity: Provide professional services objectively

Objectivity requires intellectual honesty and impartiality. Regardless of the particular service rendered or the capacity in which a professional functions, professionals should protect the integrity of their work, maintain objectivity and avoid subordination of their judgment.

Principle 3 – Competence: Maintain the knowledge and skill necessary to provide professional services competently

Competence means attaining and maintaining an adequate level of knowledge and skill, and application of that knowledge and skill in providing services to clients. Competence also includes the wisdom to recognize the limitations of that knowledge and when consultation with other professionals is appropriate or referral to other professionals necessary. Professionals make a continuing commitment to learning and professional improvement.

Principle 4 – Fairness: Be fair and reasonable in all professional relationships; eliminate conflicts of interest

Fairness requires impartiality, intellectual honesty and disclosure of material conflicts of interest. It involves a subordination of one’s own feelings, prejudices and desires so as to achieve a proper balance of conflicting interests. Fairness is treating others in the same fashion that you would want to be treated.

Principle 5 – Confidentiality: Protect the confidentiality of all client information

Confidentiality means ensuring that information is accessible only to those authorized to have access. A relationship of trust and confidence with the client can only be built upon the understanding that the client’s information will remain confidential.

Principle 6 – Professionalism: Act in a manner that demonstrates exemplary professional conduct

Professionalism requires behaving with dignity and courtesy to clients, fellow professionals, and others in business-related activities.

Principle 7 – Diligence: Provide professional services diligently

Diligence is the provision of services in a reasonably prompt and thorough manner, including the proper planning for, and supervision of, the rendering of professional services.

The Advisory Group of San Francisco, LLC (“AGSF”) is an SEC registered investment adviser principally located in San Francisco, California. AGSF and its representatives are in compliance with the current filing requirements imposed upon SEC registered investment advisers by those states in which AGSF maintains clients. AGSF may only transact business in those states in which it is registered or qualifies for an exemption or exclusion from registration requirements. AGSF`s web site is limited to the dissemination of general information pertaining to its investment advisory services. Accordingly, the publication of AGSF`s web site on the Internet should not be construed by any consumer and/or prospective client as AGSF`s solicitation to effect, or attempt to effect, transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Any subsequent, direct communication by AGSF with a prospective client shall be conducted by a representative that either is registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. For information pertaining to the registration status of AGSF, please contact either the SEC or the state securities law administrators for those states in which AGSF maintains a notice filing. In addition to being registered as a registered investment adviser with the U.S. Securities and Exchange Commission, AGSF maintains a notice filing with the State of California Department of Corporations and AGSF is primarily limited to providing investment advisory services to residents of California, unless additional filings are completed for specific states. The presence of the web site on the internet shall in no direct or indirect way raise a presumption that AGSF is offering to sell advisory services to residents of any state outside of the state of California. A copy of AGSF`s current written disclosure statement discussing AGSF`s business operations, services, and fees is available from AGSF upon written request. AGSF does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to AGSF`s web site or incorporated herein, and takes no responsibility for such information. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.

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