Hamrick Investment Counsel considers ethics to be an integral part of professional investment management.

We comply with all applicable laws, rules and regulations governing our activities. In addition, we are sworn to conduct our activities in accordance with the Code of Ethics and Standards of Professional Conduct of the CFA Institute, which requires (among other things) that we deal fairly with all our clients, that we preserve their confidentiality, and that we not misuse inside information.

In addition to managing client portfolios, employees of Hamrick Investment Counsel may oversee personal and family investments. In accordance with the CFAI Code & Standards and our internal written compliance procedures, we are required to give precedence to client transactions over our personal transactions and to disclose all material conflicts of interest.

Hamrick Investment Counsel maintains records of employees’ securities holdings and investment transactions in their personal portfolios, which are regularly reviewed by our Chief Compliance Officer.

Copies of the CFAI Code & Standards as well as our internal compliance procedures are available on request. We encourage clients to discuss any questions they may have regarding our personal transactions, holdings, cross-ownership of securities, or any other potential conflicts of interest.