Code of Ethics

At SS&H Financial Advisors, Inc. we take great pride in our commitment to serving our clients’ needs and the integrity with which we conduct our business. The financial services industry has come under significant scrutiny as of recent times, especially in the area of the inherent responsibility of the financial professional to behave in the best interests of his/her clients. We have developed a Code of Ethics as a means of memorializing our vision of appropriate and professional conduct in carrying out the business of providing investment advisory services.

Each of our "access persons" has attested to their understanding of the Code and acceptance of its terms. When a client signs our advisory contract, we view that action as an expression of trust in our ability to manage assets effectively and within the highest standards of professional conduct. It is our policy and duty to respect the trust that our clients place in us and to always keep their best interests ahead of our own. We believe that upholding this fiduciary duty is the cornerstone upon which fruitful relationships are forged and hence, successful businesses are built.

As a registered investment adviser, we operate under the regulatory jurisdiction of the SEC and the state of Michigan, which subjects the firm to a variety of industry rules and regulations. We recognize that these laws, rules, and regulations exist to protect the interests of the investing public and therefore insist that our employees maintain strict compliance thereto.

Violations of the Code are taken seriously. Below is a copy of our Code of Ethics.

SS&H FINANCIAL ADVISORS, INC.

50 W. Big Beaver Road, Suite 225, Troy, Michigan 48084

(248) 538-9755

Code of Ethics

Introduction

At SS&H Financial Advisors, Inc., we take great pride in our commitment to serving our clients’ needs and the integrity with which we conduct our business. The financial services industry has come under significant scrutiny as of recent times, especially in the area of the inherent responsibility of the financial professional to behave in the best interests of his/her clients. We have developed this Code of Ethics (“Code”) as a means of memorializing our vision of appropriate and professional conduct in carrying out the business of providing investment advisory services.

Each of our “access persons” has been furnished with a copy of our Code and have signed their name to a written acknowledgement attesting to their understanding of the Code and acceptance of its terms. An “access person” is defined by the U.S. Securities and Exchange Commission (“SEC”) as any supervised person of the firm who has access to nonpublic information regarding any clients’ purchase or sale of securities, or nonpublic information regarding the portfolio holdings of any reportable fund, or who is involved in making securities recommendations to clients, or who has access to such recommendations that are nonpublic.

Obligations of the Firm to its Clients

When a client signs our advisory contract, we view that action as an expression of trust in our ability to manage assets effectively and within the highest standards of professional conduct. It is our policy and duty to respect the trust that our clients place in us and to always keep their best interests ahead of our own. We believe that upholding this fiduciary duty is the cornerstone upon which fruitful relationships are forged and hence, successful businesses are built.

Our representatives will seek to manage a client’s assets in accordance with the client’s stated investment objectives, financial profile, risk tolerance, investment experience, and any other specific preferences. Open and frequent communication between our representatives and our clients is a key factor in delivering financial services. To the fullest extent possible, our representatives should make sure that clients are made aware of the state of their account(s) during all market conditions. Our job does not end with portfolio management. It is our duty to constantly monitor our clients’ needs and objectives and to make every effort to ensure that their investments are appropriate given their particular situations.

Protection of Material Nonpublic Information

The beginning phase of our relationship with our clients starts with building a foundation of trust. Our clients choose to do business with us because they trust that we will deliver the services we offer in a manner that puts their interests above all others. In choosing to do business with us, our clients entrust us with the protection of information about them that should never be used in a manner other than for their own benefit. Thus, it is our policy that all personal nonpublic information given to us by, or in relation to, our clients is kept strictly confidential and that it never is used in any manner other than for the purposes of carrying out our duties to our clients. Personal nonpublic information could include, but would not be limited to a client’s current income situation, current securities holdings, trading strategies, medical or health information, tax-related matters, etc.

The mishandling of a client’s personal nonpublic information could create several undesirable results for the firm(s) and their representatives. These negative consequences might include civil actions, criminal actions, arbitrations, issuance of restrictive orders against the firm(s) or representatives by regulatory bodies, fines, etc. Any of these actions could have a devastating impact on the firm(s) and representatives. Given these consequences, we will not tolerate the use of a client’s personal nonpublic information in a manner that is inconsistent with the best interests of that client. Behavior by representatives that involves the misuse of a client’s personal nonpublic information could result in severe disciplinary action (including termination for cause) against the culpable party(s).

Conflicts of Interest

A major component of carrying out our fiduciary duties to our clients is the awareness and disclosure of conflicts of interest. A conflict of interest occurs when the best interests of the firm(s) and/or their representative(s) are contrary to the interests of our clients. Such a conflict can arise when a representative of the firm(s) pursues interests that prevent that individual from performing their duties to his/her client(s) objectively and effectively. Conflicts of interest also arise when a representative or member of the representative’s family receives certain benefits as a result of the individual’s position with the firm.

An access person must not use his/her personal relationships to influence the trading activities of client accounts in a manner that will be beneficial to the access person, his/her family members, and/or acquaintances; nor shall an access person engage in activity that is detrimental to the firm or our clients. Any conflict of interest that arises in a specific situation must be disclosed by the individual and resolved before taking any action on behalf of the client(s) involved.

Compliance with Federal Securities Laws

As registered investment advisers, we operate under the regulatory jurisdiction of the SEC and the state of Michigan, which subjects the firm to a variety of industry rules and regulations. We recognize that these laws, rules, and regulations exist to protect the interests of the investing public and therefore insists that its employees maintain strict compliance thereto. Our Compliance officials have an “open door” policy and all employees should seek guidance whenever the applicability of a law, rule, regulation, or firm policy comes into question in any situation.

Personal Securities Transactions and Holdings

Our policy allows employees to maintain personal securities accounts provided any such personal investing by the employee or any immediate family or household member is consistent with our fiduciary duty to our clients. The employee must report all transactions to the firm(s) Chief Compliance Officer within 10 days of the quarter end.

It is our expressed policy that no person employed by the firm may purchase or sell any security on the day a transaction(s) is being or has been implemented for an advisory account, and therefore, preventing such employees from benefiting from transactions placed on behalf of advisory accounts. A member or employee of the firm(s) shall not buy or sell securities for their personal portfolio(s) where their decision is substantially derived in whole or in part, by reason of his or her employment at the firm on a day the security has been transacted in any client account. No person at the firm shall prefer his or her own interest to that of an advisory client.

The Chief Compliance Officer will review all access persons transactions at least quarterly.

Exceptions from reporting requirements:

Any report with respect to securities held in accounts over which the access person had no direct or indirect influence or control;
A transaction report with regard to transactions effected pursuant to an automatic investment plan;
Transactions and holdings in direct obligations of the U.S. Government;
Money market instruments — bankers’ acceptances, bank CDs, commercial paper, repurchase agreements, and other “high quality, short-term debt instruments” (maturity at issuance of less than 366 days, and which is rated in one of the highest two categories by a Nationally Recognized Statistical Rating Organization, or which is unrated but is of comparable quality);
Shares of money market funds;
Transactions and holdings in shares of other types of mutual funds, unless the firm or a control affiliate acts as the investment adviser or principal underwriter for the fund; and
Transactions in units of a unit investment.

IPO and Private Placement Policy

All of our access persons must obtain approval from the Chief Compliance Officer prior to directly or indirectly acquiring beneficial ownership in any security in an initial public offering or a private placement.

Reporting Violations

Violations of the Code are taken seriously. Each employee of the firm has an obligation to report such violations to the Chief Compliance Officer in an expeditious manner after becoming aware that a violation has occurred. Reports of violations will be kept strictly confidential in order to avoid retaliation from those involved. We also allow anonymous submissions of violation reports so as to keep concerned employees at ease. Any breach of the confidentiality of a report of a violation of the Code will constitute a further violation of the Code and will be dealt with as such.

Gifting

Investment personnel may only accept gifts of de minimis value. Also, no employee of our firm may give gifts in excess of $100 to any person at another firm or securities or financial institution without the prior approval from our Chief Compliance Officer. Any questions about gifts, gratuities or other payments to or from employees are to be reviewed by the Chief Compliance Officer.

Record-keeping

With regard to our Code, we maintain the following books and records for a period of five years following the end of the fiscal year during which the last entry was made on such record, the first two years in an easily accessible location:

A copy of the current Code as well as copies of Codes that were in effect at any time within the past five years;
Records of violations of the Code, including records of the actions taken subsequent to such violations;
Signed acknowledgements from each person who is currently, or was at some point during the past five years, a supervised person that confirms their receipt, understanding, and acceptance of the Code. This acknowledgement will represent an obligation to adhere to the standards and provisions set forth in the Code;
A record of the names of all persons who were access persons at any time within the past five years;
A record of each transaction report made by an access person, including if requested applicable brokerage statements and confirmations collected in lieu of such a report;
A record of any decision and the reasons supporting the decision, to approve the acquisition of securities by access persons through an initial public offering or limited offering.

Representative Acknowledgement

By my signature below, I attest that I have read and understand the firm’s Code of Ethics and agree to act in a manner that is consistent with this Code and in the best interests of our clients.

Representative Name/Rep.#

Representative Signature Date