Operational Guidelines

This Code of Ethics and Integrity (CoEI) applies to all transactions, without regard to the product or service category, the type of intermediary, or the means by which the purchase of a product or service is transacted. If any principle or practice is inconsistent with a provision of an applicable law or regulation, the applicable law or regulation will take precedence.

1. Interests of Client

We shall place the interests of our clients ahead of all other interests.

2. Needs of Client

Before giving advice or making recommendations, we shall make a diligent effort to listen and to learn the client's needs, objectives and circumstances, and to then offer products or services to fulfill them. We shall not recommend the replacement of client's policy or program unless we strongly believe that such a replacement is in the best interest of the client. We shall respect client's values, beliefs, requirements, limitations and boundaries.

3. Legitimacy of Client and Transaction

We shall collect only and enough information about the client and the proposed transaction to reasonably determine the identity of the client and that the transaction is lawful. We shall not act on behalf of a client when there are reasonable grounds to believe that the transaction is of an unlawful nature. We shall not knowingly submit information that is inaccurate or misleading.

4. Professionalism

We shall possess an appropriate level of knowledge relating to our particular business and meet high standards of professional ethics, including acting with honesty, integrity, fairness, due diligence and skill. Continuing education shall be pursued as a means of keeping skill and knowledge levels current . We shall ensure that client records are properly maintained and follow sound business practices.

5. Disclosure of Business Information

We shall not misrepresent our qualifications or experience, and shall inform the client of the business licenses and registrations held, as well as the business name(s) of firm(s) under which we are licensed to operate. We shall ensure that all references to our business activities, services and products are clear, descriptive and not misleading.

6. Disclosure of Service/Product Information

When recommending a transaction to a client, we shall disclose all relevant facts, considerations, costs and risks necessary for an informed decision. This disclosure shall be in writing, and a written receipt obtained from the client.

In addition to clearly describing the product or service for the client and the ways in which the solutions/recommendations, plans will fulfill the needs of the client, we shall disclose important assumptions underlying any illustrations or examples that have been provided to the client, as well as the fact that actual results may differ in various degrees from those shown. We shall not use examples or illustrations which we know, or ought to know, are based on unusual results or a period that generated much better than normally anticipated performance.

7. Confidentiality

We shall maintain the confidentiality of the client and the business relationship. We shall not disclose any information about the client and to any individual or company without express written permission or request from the client.

8. Conflicts of Interest

We shall disclose to a prospective clients all conflicts of interest associated with any recommendations and transactions and the client shall then be given the opportunity to halt the transaction, to seek additional advice elsewhere or complete the transaction.

9. Behavior

We shall act in good faith at all times, and meet high standards of professional ethics, including acting with honesty, integrity, fairness, due diligence and skill.

We shall not engage in behavior that is likely to be detrimental to the public professional image of ourselves, our clients or our competitors.

We shall deal directly with all formal and informal complaints or disputes, or refer them to the appropriate person or process, in a timely and forthright manner.

We shall provide services to clients only in the areas of our expertise and qualification. If it becomes apparent that the client has a situations beyond our expertise, we shall request that the client seek services from qualified professionals. We reserve the right to terminate the business relationship until the client has done so, if the challenge impedes the forward movement of the business process.

10. Independence

We shall declare and maintain our business independence from any in-network service provider.