Code of Ethics and Standards of Professionalism

Investors Internet Inc., and its Officers and staff, shall, at all times make their best efforts to:

• Act with integrity in an ethical manner.
• Not copy or use in substantially the same form as the original, material prepared by another without acknowledging and identifying the source of the material, except for factual material published by recognized reporting services or similar sources.
• Use reasonable care in the exercise of independent professional judgment.
• Respect confidential information provided to us and not disclose any such information without the provider’s prior permission unless it concerns illegal activities.
• Disclose any personal or financial interest which might influence our work.
• Not knowingly participate or assist in any violation of applicable laws, rules or regulations or not act in any way that involves dishonesty, fraud, deceit or misrepresentation.
• Make reasonable and diligent efforts to avoid any material misrepresentation in any research report or investment comments.
• Use reasonable judgment regarding the inclusion or exclusion of relevant factors in research reports.
• Distinguish between facts and opinions in research reports.
• Use reasonable care and judgment to achieve and maintain independence and objectivity in providing investment information and making recommendations.
• Act for the benefit of Investors Internet Inc’s clients and place clients’ interests before our own.
• Represent accurately the services that Investors Internet Inc. is capable of performing, the qualifications of Investors Internet Inc., the qualifications of the individuals performing the services, and the academic and professional credentials of the individuals.
• Not knowingly make any statements that misrepresent the investment performance that Investors Internet Inc. or any other firm has accomplished or can reasonably be expected to achieve.
• Improve their abilities.

The above Code of Ethics and Standards of Professionalism are based on those approved by the Institute of Management Consultants and the CFA Institute.