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This Code of Ethics expresses the policy and procedures of Worley Erhart-Graves Financial Advisors, Inc. (WEFA), and is enforced to ensure that no one is taking advantage of their position, or even giving the appearance of placing their own interests above that of the accounts, clients, and shareholders we are serving. In this regard, Section 204A of the Investment Advisers Act of 1940 (“Act”) requires investment advisers to establish, maintain, and enforce policies designed to prevent the misuse of nonpublic information by the investment adviser and its associated persons. Moreover, Section 206 of the Act, among other things, prohibits investment advisers from engaging in any device, scheme, or artifice to defraud any existing or prospective client.

In compliance with Sections 204A and 206 of the Act, this Code of Ethics contains provisions reasonably necessary to eliminate the possibility of conduct constituting the misuse of nonpublic information and/or fraud against any existing or prospective client. As more specifically detailed below, this Code prohibits all associated persons from trading in any securities listed on the Restricted Trading List without prior written approval. The following definitions apply as used herein:

The term “account” shall mean any advisory client of WEFA or its affiliated companies or subsidiaries.

The term “Security” means any note, stock, treasury stock, bond, debenture, evidence of indebtedness, certificate of interest, option or participation in any profit-sharing agreement, collateral-trust certificate, pre-organization certificate or subscription, transferable share, investment contract, voting-trust certificate, certificate of deposit for a security, fractional undivided interest in oil, gas, or other mineral rights, or, in general, any interest or instrument commonly known as a “security”, or any certificate of interest or participation in, temporary or interim certificate for, receipt for, guarantee of, or warrant or right to subscribe to or purchase, any of the foregoing; provided, however, that “security” shall not mean securities issued by the government of the United States, bankers’ acceptances, bank certificates of deposit, commercial paper, shares of registered open-end investment companies, variable annuity contracts and variable life insurance policies.

“Beneficial ownership” shall be interpreted in the same manner, as it would be in determining whether a person is subject to the provisions of Section 16 of the Securities Exchange Act of 1934 and the rules and regulations thereunder. “Beneficial ownership of a security” includes securities held by:

• Your spouse, minor children or relatives who share the same house with you;

• an estate for your benefit;

• a trust, of which (i) you are a trustee or you or members of your immediate family have a vested interest in the income or corpus of the trust, or (ii) you own a vested beneficial interest, or (iii) you are the settlor and you have the power to revoke the trust without the consent of all the beneficiaries;

• a partnership in which you are a partner;

• a corporation (other than with respect to treasury shares of the corporation) of which you are an officer, director or 10% stockholder;

• any other person if, by reason of contract, understanding, relationship, agreement or other arrangement, you obtain there from benefits substantially equivalent to those of ownership; or

• your spouse or minor children or any other person, if, even though you do not obtain there from the above mentioned benefits of ownership, you can vest or revest title in yourself at once or at some future time.

A beneficial owner of a security also includes any person who, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, has or shares voting power and/or investment power with respect to such security. Voting power includes the power to vote, or to direct the voting of such security, and investment power includes the power to dispose, or to direct the disposition of such security. A person is the beneficial owner of a security if he or she has the right to acquire beneficial ownership of such security at any time within sixty days.

“Associated person,” means any officer, director, advisor or employee of Worley Erhart-Graves Financial Advisors, Inc. or its affiliates.

All associated persons must have prior written approval from Chief Compliance Officer (CCO) to invest in any initial public offering or any limited offered, as well as, acquiring beneficial ownership in any security.

Responsibility

It is expected that all supervisory personnel, access persons, solicitors, and employees conduct business with the highest level of ethical standards keeping in mind at all time WEFA’s fiduciary duties to its clients. The Chief Compliance Officer (CCO) will be responsible for having each employee sign a written acknowledgement that they have read this entire Compliance Manual and any amendments thereto. A copy of such receipt will be kept in the supervised/access persons employment file. Furthermore, the CCO will be responsible for maintaining and enforcing WEFA’s policies and recording any violation and any actions taken as a result of any violation, and reporting any violation to senior management of the WEFA.

Duty to Clients

WEFA has a duty to exercise its authority and responsibility for the benefit of its clients, to place the interests of its clients first, and to refrain from having outside interests that conflict with the interests of its clients. WEFA is committed to avoid any circumstances that might adversely affect, or appear to affect, its duty of complete loyalty to its clients

Privacy of Client Financial Information

WEFA will not disclose any nonpublic personal information about a client to any nonaffiliated third party unless the client expressly gives permission to WEFA to do so. The client in writing or verbally in person or on the phone must grant such permission, or denial of permission, to WEFA. A copy of the permission/denial document will be kept in the client file.

Prohibited Acts

WEFA or any of its supervised persons, access persons or employees will not;

• employ any device, scheme or artifice to defraud;

• make any untrue statement of a material fact;

• omit to state a material fact necessary in order to make a statement, in light of the circumstances under which it is made, not misleading;

• engage in any fraudulent or deceitful act, practice or course of business; or,

• engage in any manipulative practices.

Conflicts of Interest

WEFA has a duty to disclose potential and actual conflicts of interest to their clients. All supervised persons, access persons and solicitors have a duty to report potential and actual conflicts of interest to the CCO. Gifts (other than de minimis gifts, which are usually defined as having a value under $100.00) should not be accepted from persons or entities doing business with WEFA

Use of Disclaimers

WEFA shall not attempt to limit liability for willful misconduct or gross negligence through the use of disclaimers.

Suitability

WEFA shall only recommend those investments that it has a reasonable basis for believing are suitable for a client, based upon the client's particular situation and circumstances. In addition, clients should be instructed to immediately notify WEFA of any significant changes in their situation or circumstances so that WEFA can respond appropriately.

Duty to Supervise

Under the Advisers Act Section 203(e)(5), the CCO is responsible for ensuring adequate supervision over the activities of all persons who act on WEFA’s behalf. Specific duties include, but are not limited to:

• establishing procedures that could be reasonably expected to prevent and detect violations of the law by its advisory personnel;

• analyzing its operations and creating a system of controls to ensure compliance with applicable securities laws;

• ensuring that all advisory personnel fully understand WEFA’s policies and procedures; and,

• establishing an annual review system designed to provide reasonable assurance that WEFA’s company's policies and procedures are effective and are being followed.

Access Persons

WEFA’s policies and procedures governing personal security transactions are covered in Section XIII of this manual. Access employees as of March 15, 2024 are:

JULI ERHART-GRAVES, CFP®
PRESIDENT, CERTIFIED FINANCIAL PLANNER™

PAMELA SMITSON, CPA, CGMA
CERTIFIED PUBLIC ACCOUNTANT

MARGARET GOOLEY, CFP®, CDFA®
CERTIFIED FINANCIAL PLANNER™
CERTIFIED DIVORCE FINANCIAL ANALYST®

KYLE MCCUNE, CFP®, CERTIFIED FINANCIAL PLANNER™

TABITHA WILLIAMS
DIRECTOR OF INVESTMENT OPERATIONS
COMPLIANCE OFFICER

SHANE FAGAN, CIMA®, PORTFOLIO MANAGER

ANGIE MILLER
PARAPLANNER

KYLENE MCMURRAY
ASSISTANT PARAPLANNER

PAIGE ADKINS
INVESTMENT SUPPORT SPECIALIST

MADISON WAGNER
INVESTMENT SUPPORT SPECIALIST

RANA KORY, INVESTMENT SERVICES ASSOCIATE

CHRISTINA KANE
MARKETING COORDINATOR

KENNETH HALL
ADMINISTRATIVE ASSISTANT

Worley Erhart-Graves Financial Advisors, Inc., (WEFA) an independent financial planning firm, is committed to safeguarding the confidential information of its clients. We hold all personal information provided to our firm in the strictest confidence. These records include all personal information we collect from clients regarding any of the services provided by WEFA. We have never disclosed information to non-affiliated third parties, except as authorized by you or required by law, and do not anticipate doing so in the future. If we were to anticipate such a change in firm policy, we would be prohibited under the law from doing so without advising you first. As you know, we use financial information that you provide to us to help you meet your personal financial goals while guarding against any real or perceived infringements of your rights of privacy. Our policy with respect to personal information about you is listed below.

We limit employee access to information to only those who have a business or professional reason for knowing, and only to non-affiliated parties as permitted by law.

We maintain a secure office and computer environment to ensure that your information is not placed at unreasonable risk.

For unaffiliated third parties that require access to your personal information, such as auditors, we require strict confidentiality in our agreements with them and expect them to keep this information private. Federal and state regulators also may review firm records as permitted under the law.

We do not provide your personal identifiable information to mailing list vendors or solicitors for any purpose.

Personal identifiable information about you will be maintained during the time you are a client, and for the time thereafter that such records are required to be maintained by federal and state regulators securities laws, and consistent with the CFP Board Code of Ethics and Professional Responsibility. After this required period of record retention, all such information will be destroyed by a secure method.

Client Information Privacy Principles: Like most industries today, the financial services industry is rapidly being shaped by technology, which is literally changing the way we do business. To be successful in this environment, we must continue to ensure that our clients feel secure we will manage their financial affairs with expertise and confidentially.WEFA collects personal, private information from its clients to determine the client’s specific investment goals and objectives, which will assist in determining how to adequately service the client account based on the services provided by WEFA, as disclosed in WEFA's Form ADV Part 2A.

The safeguarding of client information is an issue we take seriously, and we want to assure all our clients that whenever information is collected and used, it is done so with discretion. To affirm our continuing commitment to the proper use of client information, we have set forth the following Privacy Principles, which are designed to guide us in serving the privacy needs of our clients.

Recognition of a Client’s Expectation of Privacy: At WEFA we believe the confidentiality and protection of client information is one of our fundamental responsibilities. And while information is critical to providing quality service, we recognize that one of our most important assets is our clients’ trust. Thus, the safekeeping of client information is a priority for WEFA.

Use, Collection, and Retention of Client Information: WEFA limits the use, collection, and retention of client information to what we believe is necessary or useful to conduct our business, provide quality service, and offer products, services, and other opportunities that may be of interest to our clients. Information collected may include, but is not limited to: name, address, telephone number, tax identification number, date of birth, employment status, annual income and net worth.

Maintenance of Accurate Information: WEFA recognizes it must maintain accurate client records. The above-referenced information is collected at the inception of your relationship with WEFA. Therefore, WEFA will contact you periodically to review your overall account holdings, and to ensure that personal/confidential information contained in your file is accurate. WEFA also requests that you review any information provided to you related to your advisory account, and notify WEFA promptly on the discovery of erroneous information. WEFA will respond to a comment/request to correct inaccurate information immediately.

Limiting Employee Access to Information: At WEFA, employee access to personal identifiable client information is limited to those employees that have a business reason to know such information. Employees are educated on the importance of maintaining the confidentiality of client information and on these Privacy Principles. Because of the importance of these issues, all WEFA employees are responsible for maintaining the confidentiality of client information and employees who violate these Privacy Principles will be subject to disciplinary measures.

Protection of Information via Established Security Procedures: WEFA recognizes that a fundamental element of maintaining effective client privacy procedures is to provide reasonable protection against the unauthorized access to client information. Therefore, WEFA has established appropriate security standards and procedures to guard against any unauthorized access to client information.

Restrictions on the Disclosure of Client Information: When it comes to sharing client information with unaffiliated companies, WEFA places strict limits on who receives specific information about client accounts and other personally identifiable data. WEFA may share information with such companies if they provide a product or service that may benefit our clients. In such case, we share the minimum amount of information necessary for that company to offer its product or service. We may also share information with unaffiliated companies that assist us in providing our products and services to our clients; in the normal course of our business (for example, with consumer reporting agencies and government agencies); when legally required or permitted regarding fraud investigations and litigation; in connection with acquisitions and sales; and at the request or with the permission of a client.

Maintaining Client Privacy in Business Relationships with Third Parties: If we provide personally identifiable client information to a third party with which we have a business relationship, we will insist that the third party keep such information confidential, consistent with the conduct of our business relationship.

Disclosure of Privacy Principles to Clients: WEFA recognizes and respects the privacy expectations of our clients. We want our clients to understand our commitment to privacy in our use of client information. As a result of our commitment, we have developed these Privacy Principles, which are made readily available to our clients. Clients who have questions about these Privacy Principles or have a question about the privacy of their client information should call Tabitha Williams at 317-872-5090.

These Privacy Principles apply to individuals, and we reserve the right to change these Privacy Principles, and any of the policies or procedures described above, at any time. Under such circumstances, we will provide you with an updated set of our policies, and will provide adequate time for you to opt out of any information sharing arrangement. These Privacy Principles are for general guidance and do not constitute a contract or create legal rights and do not modify or amend any agreements we have with our clients.

Updated 02/27/2023

Worley Erhart-Graves Financial Advisors, Inc. is a Registered Investment Adviser. Registration with the SEC or any state securities authority does not constitute an endorsement of the firm by securities regulators, nor does it indicate the advisor has attained a certain level of skill or training.

This website is a publication of Worley Erhart-Graves Financial Advisors. Information on this website does not involve the rendering of personalized investment advice nor is it an offer to buy or sell, or a solicitation of any offer to buy or sell the securities mentioned. A professional advisor should be consulted before implementing any of the strategies presented.

All investment strategies have the potential for profit or loss. Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment will either be suitable or profitable for a client's portfolio.

Worley Erhart-Graves Financial Advisors is not engaged in the practice of law or accounting. Tax services are offered to our clients through our affiliated company, Smitson Erhart-Graves Tax Advisors.

Hyperlinks on this website are provided as a convenience, and we disclaim any responsibility for information, services or products found on websites linked hereto.

Information presented is believed to be factual and up-to-date, but we do not guarantee its accuracy and it should not be regarded as a complete analysis of the subjects discussed. All expressions of opinion reflect the judgment of the authors as of the date of publication and are subject to change.

Third-party rankings and recognition from publications are no guarantee of future investment success. Working with a highly-rated advisor does not ensure that a client or prospective client will experience a higher level of performance or results. These ratings should not be construed as an endorsement of the advisor by any client nor are they representative of any one client’s evaluation. Generally, ratings, rankings and recognition are based on information prepared and submitted by the advisor. Furthermore, information about ratings and awards are available upon request.

Revised 02/24/2022

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