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CIBC Cleary Gull has adopted a Code of Ethics to assist employees in carrying out its duties as a fiduciary to its clients. The Code of Ethics is based upon the principle that CIBC Cleary Gull and its employees owe a fiduciary duty to clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid: (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the firm, and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. The Code of Ethics is designed to maintain CIBC Cleary Gull’s high ethical standards. Existing or prospective clients may contact CIBC Cleary Gull for a full copy of the Code of Ethics.


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