code of ethics & standards of conduct

Updated 2025

Core Planning, LLC (the "Firm") is committed to maintaining the highest standards of integrity, professionalism, and ethical conduct in all aspects of its investment advisory business.

This Code of Ethics and Business Standards of Conduct ("Code") has been adopted in accordance with Rule 204A-1 under the Investment Advisers Act of 1940 ("Advisers Act") to promote honest and ethical conduct and to ensure compliance with all applicable securities laws and fiduciary obligations.

Fiduciary Duty

As a registered investment adviser, the Firm and its personnel owe a fiduciary duty to clients. This duty requires acting in the best interests of clients, providing full and fair disclosure of conflicts of interest, and ensuring that investment advice is made with diligence, competence, and care.

Standards of Conduct

All supervised persons, including Investment Adviser Representatives (IARs), employees, and associated personnel, must adhere to the following principles:

  • Integrity and Honesty: Conduct all business dealings with integrity, fairness, and transparency.

  • Objectivity: Provide investment advice based on thorough analysis, free from personal biases and conflicts of interest.

  • Confidentiality: Maintain the confidentiality of client information, except as required by law or with client consent.

  • Compliance: Follow all applicable laws, rules, and regulations governing the securities industry.

  • Fair Treatment: Treat all clients fairly and equitably, avoiding favoritism or discrimination.

  • Professionalism: Uphold high professional standards in interactions with clients, colleagues, and the public.

Personal Securities Transactions

Supervised persons may invest in securities for their personal accounts but must ensure that such transactions do not conflict with client interests. The following policies apply:

  • Prohibited Transactions: No trading ahead of client trades (front-running) or using material non-public information (insider trading).

  • Pre-clearance: Certain transactions, including initial public offerings (IPOs) and private placements, may require pre-approval by the Firm’s Chief Compliance Officer (CCO).

  • Reporting Requirements: Supervised persons must provide periodic reports of their personal securities holdings and transactions.

Conflicts of Interest

Supervised persons must avoid or disclose conflicts of interest that could interfere with their ability to act in the best interest of clients. This includes:

  • Disclosing any outside business activities or compensation arrangements that may create a conflict.

  • Refraining from accepting gifts or entertainment that could unduly influence business decisions.

  • Prioritizing client trades over personal transactions.

Confidentiality and Protection of Client Information

All client information must be kept confidential and used only for legitimate business purposes. Employees must:

  • Follow Firm policies on data security and protection. [Privacy Policy]

  • Not disclose non-public client information unless required by law or authorized by the client.

  • Properly dispose of sensitive documents to prevent unauthorized access.

Reporting Violations

Any supervised person who becomes aware of a violation of this Code must promptly report it to the CCO. The Firm prohibits retaliation against any individual who reports violations in good faith.

Training and Acknowledgment

All supervised persons must:

  • Review and acknowledge this Code upon hire and annually thereafter.

  • Complete any required ethics and compliance training.

Administration and Enforcement

The CCO is responsible for administering and enforcing this Code. Violations may result in disciplinary action, including termination of employment.

Amendments and Review

The Firm will periodically review and update this Code as necessary to remain compliant with regulatory requirements and best practices.