Statement of Ethical Standards
Ethics are paramount to the investment advisory business and especially to our firm. We recognize that ethical choices are the responsibility of each individual and we realize that violation of these ethical standards would cause us to cease existence as a business.
We are fiduciaries for our clients in all our endeavors and we will not allow revenue, profits, etc. to distort our ethical principles.
Our goal is to focus on the long term and in doing so means our success depends more on our reputation than on our skills.
Statement of Values and Ethics
Always operate based on a “Clients First” principle. We will conduct business in accordance with the highest ethical and legal standards. Potential conflicts of interest will be mitigated through full and fair disclosure.
Standards of Care
Clients: To exceed our client’s expectations by providing the highest quality of service. Having a thorough understanding of our clients goals, financial strengths and weaknesses and risk tolerance are an important part of this process. During planning we will put at the forefront the client’s needs and will adhere to the standards of fairness, diligence, integrity, objectivity and professionalism.
Confidentiality is essential to client relationships and will be steadfastly maintained.
Service Providers: To build a long-standing, mutually beneficial relationships based upon merit, quality, trust and price. Providers of proprietary information will be safeguarded.
Government: We recognize that we operate in a regulated environment. Internal and External Compliance regulatory requirements are adhered to and maintained as part of our ongoing business practices. Scrutiny by various agencies provides opportunities to gain insights and improve our operations, however, we reserve the right to disagree and challenge if outside assessments appear to conflict with meeting our clients’ needs.
Society: To be involved in community activities both within and outside the financial services area. Our commitment includes education, leadership and active participation.
FLM has the following Policies and Procedures in place:
- Personal Trading Restrictions
- Insider Trading/Material Non Public Information
- Client Communication & Disclosure Policies
- Custody of Assets
- Trading Practices
- Best Execution
- “Soft” Dollar Arrangements
- Proxy Voting
- USA Patriot Act
- Document Destruction Procedures
- Electronic Document Storage Procedures and Safeguards