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The Investment Advisers Act of 1940 imposes a fiduciary duty on investment advisers. As a fiduciary, Clayton Financial Services, Inc. (CFSI) has a duty of utmost good faith to act solely in the best interests of each of our clients. Our clients entrust us with their funds, which in turn places a high standard on our conduct and integrity. Integrity demands honesty and candor, which must not be subordinated to personal gain and advantage. CFSI respects the trust and confidence clients place in us and we recognize our responsibility to be competent, objective, fair, diligent and professional in our relationship with our clients. Our fiduciary duty compels all employees to act with the utmost integrity in all of our dealings with the public, fellow professionals and colleagues. This fiduciary duty is the core principle underlying this Code of Ethics and represents the expected basis of all of our dealings with our clients.
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