Applicability
A. The provisions of Worth Financial Group’s Code of Ethics shall apply to Employees and Advisory Representatives of Worth Financial Group Inc. Unless otherwise indicated, the term “Employee” as used herein means: all officers, directors and home office employees of Worth Financial Group Inc. The term “Advisory Representative” as used herein means: all Investment Advisory Representatives registered with Worth Financial Group.
Compliance with Governing Laws, Regulations and Procedures
A. Each Employee or Advisory Representative shall have and maintain knowledge of and shall comply with all applicable federal and state laws and all rules and regulations of any governmental agency or self-regulatory organization governing his/her actions as an Employee and/or Advisory Representative.
B. Each Employee or Advisory Representative shall comply with all laws and regulations, and Worth Financial Group Inc.’s prohibition against insider trading. Trading on or communicating material non-public information, or “inside information”, of any sort, whether obtained in the course of research activities, through a client relationship or otherwise, is strictly prohibited.
C. Each Employee or Advisory Representative shall comply with the procedures and guidelines established by Worth Financial Group Inc. to ensure compliance with applicable federal and state laws and regulations of governmental agencies and self- regulatory organizations. No employee shall knowingly participate in, assist, or condone any act in violation of any statute or regulation governing Worth Financial Group Inc. or any act that would violate any provision of the Code.
D. Each Employee or Advisory Representative shall have and maintain knowledge of and shall comply with the provisions of the Code of Ethics.
E. Each Employee having supervisory responsibility shall exercise reasonable supervision over employees subject to his/her control, with a view to preventing any violation by such persons of applicable statutes or regulations, Worth Financial Group Inc. procedures, or the provisions of the Code. Any Employee or Advisory Representative obtaining evidence that an act in violation of applicable statutes, regulations or provisions of the Code adopted hereunder has occurred shall immediately report such evidence to the Chief Compliance Officer of Worth Financial Group Inc. or the Compliance Department. Failure to report such evidence may result in disciplinary action up to and including termination.
Ethical Standards
A. Employees and Advisory Representatives shall conduct themselves in a manner consistent with the highest ethical and fiduciary standards. They shall avoid any action, whether for personal profit or otherwise, that results in a conflict of interest with Worth Financial Group Inc. or its client accounts, or which may be otherwise detrimental to the interests of clients of Worth Financial Group Inc.
B. Employees and Advisory Representatives shall act in a manner consistent with their fiduciary obligation to clients of Worth Financial Group Inc., and shall not deprive any client account of an investment opportunity in order to personally benefit from that opportunity.
C. Employees and Advisory Representatives shall not engage in an outside business activity for compensation, without the knowledge and approval of the Compliance Department.
D. Advisory Representatives, in making investment recommendations or taking any investment actions, shall exercise diligence and thoroughness, and shall have a reasonable basis for any such recommendation or action.
E. Advisory Representatives shall not attempt to improperly influence for such person’s personal benefit any investment strategy to be followed or investment action to be taken by Worth Financial Group Inc. for its client accounts.
F. Employees and Advisory Representatives shall not improperly use, for such person’s personal benefit, any knowledge, whether obtained through such person’s relationship with Worth Financial Group Inc. or otherwise, of any investment recommendation made or to be made, or of any investment action taken or to be taken by Worth Financial Group Inc.
G. Employees and Advisory Representatives shall not disclose any non-public information relating to a client account’s portfolio or transactions or to the investment recommendations of Worth Financial Group Inc. Conflicts of interest may result from a situation in which an individual has a personal interest in a matter that is or may be in competition with his or her duties to other persons or entities or where an individual has or may have competing obligations or responsibilities to two or more persons or entities. In the case of the relationship between a client account and any Employees or Advisory Representatives, such conflict may result from the purchase or sale of securities for a client account and for the personal account of the individual involved or their related persons. Representative may not disclose any non-public information relating to the business or operations of Worth Financial Group Inc. unless properly authorized to do so.
H. Employees and Advisory Representatives shall not accept, directly or indirectly, from a broker/dealer or other vendor who transacts business with Worth Financial Group or its client accounts, any gifts, gratuities or entertainment of more than de-minimis value or significance that their acceptance might reasonably be expected to interfere with or influence the exercise of independent and objective judgment in carrying out such person’s duties or otherwise give the appearance of a possible impropriety. For this purpose, Employees and Advisory Representatives will be subject to existing policies and procedures contained in the Written Supervisory Procedures of Worth Financial Group.
Insider Trading
A. Employees and Advisory Representatives while in possession of material, non-public information shall not;
Buy or sell securities for his or her personal accounts or for accounts in which they have a beneficial interest or over which they have the power directly or indirectly to make investment decisions while in possession of material, non-public information.
Solicit clients’ orders to purchase or sell the securities.
Issue research reports, recommendations or comments which could be construed as recommendations.
Disclose material non-public information or any conclusions based thereon to any person other than the Chief Compliance Officer of Worth Financial Group Inc.
B. Material, non-public information is generally defined as information that a reasonable investor would likely consider to be important to making an investment decision, and any information that is reasonable certain to have a substantial effect on the price of a company’s securities that has not been effectively communicated to the market and the market has had time to absorb the information. Examples of material, non-public information include, but are not limited to, changes in dividends or dividend policy, earnings estimates or changes in previously released earnings estimates, developments concerning significant merger or acquisition proposals, developments in major litigation or significant changes in management.
C. In addition, Employees and Advisory Representatives shall be required to certify annually that they understand and will comply with the insider trading provisions contained in the Code of Ethics and Written Supervisory Procedures of Worth Financial Group through the annual Compliance Questionnaire.
Penalties for Violations of the Code
A. Employees and Advisory Representatives found to have violated the provisions of Worth Financial Group Inc.’s Code may be subject to sanctions up to and including a letter of reprimand, additional continuing education requirements, fines, suspension or termination.
B. Employees and Advisory Representatives may also be required to disgorge any profits realized or losses avoided for transactions in securities that are inconsistent with the provisions of the Code.
C. Employees and Advisory Representatives found to have violated any of the insider trading provisions of the Code may be subject to additional penalties under federal regulatory authorities including revocation of licenses and registrations, substantial monetary fines and/or imprisonment.
Record Keeping Requirements
A. The Compliance Department is responsible for maintaining the following records for a period of five years;
All Acknowledgement Statements
Review of Advisory Representative’s personal brokerage account statements
All lists of Employees and Advisory Representatives who are either Supervised Persons and/or Access Persons covered by the Code.
A copy of the Code of Ethics as well as any amendments
A written record of each violation of the Code as well as a record of any action taken as a result of the violation
