Code of Conduct

The Board of Trustees (the “Board”) of the Investment Program Association (the “Association”) adopted this Code of Conduct (“Code”) to promote a culture of fairness, honesty and transparency within the Association.

This Code encourages the highest professional standards for the direct investment industry and its participants. The provisions in this Code are general statements expressing the ethical and professional ideals members are expected to display in their professional activities.

Each member or associate member of the Association, by being an “Association Participant”, agrees to observe the spirit and intent of this Code, and to conduct business in accordance with this Code. This Code may be amended from time to time subject to ratification by the Board.

I. First Principle

Each Association Participant agrees to a standard of business conduct with other Association Participants, regulators, and other industry participants, that demonstrate professionalism, honesty and integrity. It is expected that Members will participate in the Association’s programs for the benefit of the investing public and to achieve the objectives of the Association.

II. Second Principle

While Association Participants are encouraged to use best practices developed by the Association, they are expected to exercise independent judgment in the conduct of their business, including in determining whether to support comments produced by the Association for submission to regulatory agencies, the use of education and resources available from the Association, and in connection with their disclosure and recommendations to investors based on knowledge gained from participation in the Association. Transparency in the conduct of the Association’s membership is paramount and expected.

III. Third Principle

Each Association Participant agrees to uphold an affirmative duty of care, honesty and good faith to act in the best interests of the Association when participating in Association activities. Each Association Participant should respect the views of other industry or member participants regardless of the diversity of opinions. Association Participants should preserve and respect any confidential or proprietary information gained by participation in the Association unless compelled to make such disclosures by legal or regulatory requirement.

IV. Fourth Principle

Association Participants shall strive to be knowledgeable of the direct investment industry so that they are able to competently participate in the Association. This includes making reasonable efforts to be informed of laws, regulations and legislation that affect the industry. Association Participants shall make every reasonable effort to comply with all applicable laws, regulations and rules relating to the construction and distribution of direct investment products.

V. Fifth Principle

Each Association Participant should act in a manner that demonstrates the standards of practice set forth herein and should conduct themselves in a manner that reflects the highest professional standards applicable to that Association Participant.