Download Form ADV Part 2

Download Form CRS

Introduction

This is the Code of Ethics (the "Code") of Worley Erhart-Graves Financial Advisors ("WEFA" or the "Company"). The Company's Policies on Insider Trading and Personal Securities Transactions are included in the Code. 

This Code of Ethics is based on the principle that WEFA has a fiduciary duty to place the interests of clients ahead of the Company's interests. WEFA must avoid activities, interests, and relationships that might interfere with making decisions in the best interests of the Company's clients. 

All Associated Persons will act with competence, dignity, integrity, and in an ethical manner, when dealing with clients, the public, prospects, third-party service providers and fellow Associated Persons. 

We expect all Associated Persons to adhere to the highest standards with respect to any potential conflicts of interest with clients. As a fiduciary, WEFA must act in its clients' best interests. Neither WEFA, nor any Associated Person should ever benefit at the expense of any client. Notify the CCO promptly if you become aware of any practice that creates, or gives the appearance of, a material conflict of interest. 

Guidelines for Professional Standards

• At all times, all Associated Persons must comply with applicable federal securities laws and must reflect the professional standards expected of those engaged in the investment advisory business, and they shall act within the spirit and the letter of the federal, state, and local laws and regulations pertaining to investment advisers and the general conduct of business. These standards require all personnel to be judicious, accurate, objective, and reasonable in dealing with both clients and other parties so that his or her personal integrity is unquestionable. 

• All Associated Persons are required to report any violation of the Code, by any person, to the CCO or other appropriate persons of WEFA promptly. Such reports will be held in confidence to the extent practicable. However, the Company remains responsible for satisfying the regulatory reporting and other obligations that may follow the reporting of a potential violation. 

• Associated Persons must place the interests of clients first. All Associated Persons must scrupulously avoid serving his or her own personal interests ahead of the interests of the Company's clients. In addition, Associated Persons must work diligently to ensure that no client is preferred over any other client. 

• Associated Persons must use good judgment in identifying and responding appropriately to actual or apparent conflicts. Conflicts of interest that involve WEFA and/or its Associated Persons on one hand and clients on the other hand will generally be fully disclosed and/or resolved in a way that favors the interests of the clients over the interests of WEFA and its Associated Persons. If an Associated Person believes that a conflict of interest has not been identified or appropriately addressed, that Associated Person should promptly bring the issue to the CCO's attention. 

• All Associated Persons are naturally prohibited from engaging in any practice that defrauds or misleads any client, or from engaging in any manipulative or deceitful practice with respect to clients or securities. 

• No Associated Person may serve on the board of directors of any publicly traded company without prior written permission from the CCO. 

• Associated Persons will not cause or attempt to cause any client to purchase, sell, or hold any security in a manner calculated to create any personal benefit, or on behalf of WEFA. 

• Associated Persons must use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, trading, promoting WEFA's services, and engaging in other professional activities. 

• Associated Persons must conduct all personal securities transactions in full compliance with this Code. Doubtful situations should be resolved in favor of clients and in cooperation with the CCO. Technical compliance with the Code's provisions shall not automatically insulate from scrutiny any securities transactions or actions that could indicate a violation of WEFA's fiduciary duties. 

• Personal transactions in securities by Access Persons must be transacted to avoid even the appearance of a conflict of interest on the part of such personnel with the interests of the Company's clients. Likewise, Associated Persons must avoid actions or activities that allow (or appear to allow) a person to profit or benefit from his or her position with WEFA at the expense of clients, or that otherwise bring into question the person's judgment. 

• Associated Persons are subject to Insider Trading Policies adopted by WEFA to detect and prevent the misuse of material nonpublic information. 

• No Associated Person shall communicate information known to be false to others (including but not limited to clients, prospective clients and other Associated Persons) with the intention of manipulating financial markets for personal gain. 

• Associated Persons are prohibited from accepting compensation for services from outside sources without the specific prior written permission of the CCO. 

• When any Associated Person faces a conflict or potential conflict between his or her personal interest and the interests of clients, he or she is required to immediately report the conflict to the CCO for instructions regarding how to proceed. 

• Associated Persons must treat recommendations and actions of the Company as confidential and private matters. Accordingly, we have adopted a Privacy Policy to prohibit the transmission, distribution, or communication of any information regarding securities transactions in client accounts or other nonpublic information, except to broker-dealers, other bona fide service providers, or regulators in the ordinary course of business. In addition, no information obtained during the course of employment regarding particular securities (including internal reports and recommendations) may be transmitted, distributed, or communicated to anyone who is not affiliated with WEFA, without the prior written approval of the CCO. 

• No Associated Person shall intentionally sell to or purchase from a client any security or other property without prior written authorization from the CCO. 

• No Associated Person shall provide loans or receive loans from clients without the prior written authorization from the CCO. 

Access Persons

WEFA’s policies and procedures governing personal security transactions are covered in a separate document and provided to access employees annually and by request. Access employees as of January 02, 2025 are: 

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

PAMELA SMITSON, CPA, CGMA®
CERTIFIED PUBLIC ACCOUNTANT
CHARTERED GLOBAL MANAGEMENT ACCOUNTANT® 

MARGARET GOOLEY, CFP®, CDFA®
VICE PRESIDENT, 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

In compliance with The Transparency in Coverage Rule, health plans and health insurance issuers must publish machine-readable files. To access the machine-readable files created and published by UnitedHealthcare, please click here.