Code of Ethics
Crescendo Wealth Management, LLC("the firm") and its associates have a duty of utmost good faith to act solely in the interests of each client. Our clients entrust us with their funds and personal information, which in turn places a high stand conduct and integrity. Our fiduciary duty compels all associates to act with the utmost integrity in all of our dealings.
Our firm adheres to its Code of Ethics and accepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities.
This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its provisions will not shield associated persons from liability for personal trading or other conduct that violates a fiduciary duty to advisory clients.
Standards of Conduct:
- The interests of clients will be placed ahead of the firm's or any associate's.
- All known or potential conflicts of interest will be disclosed to our clients.
- Associates are expected to conduct their personal securities transactions in accordance with the policy and will strive to avoid any actual or conflict of interest with the client. Questions regarding the appearance of a conflict with a client should be discussed with the Chief Compliance Officer before taking action that may result in an actual conflict.
- Associates will not take inappropriate advantage of their position with the firm.
- Associates are expected to always comply with securities laws, which include anti-fraud provisions.
- Investment advisor representatives will be appropriately registered or exempted in each jurisdiction they conduct advisory business as required by regulation.
- Business titles will be accurate and avoid public misperception as to the associates position, education, and background.
PROTECTION OF NON-PUBLIC INFORMATION
Associates will exercise diligence and due care in maintaining and protecting client non- public personal information and will be familiar with the firm's published privacy policies. Any known or suspected privacy breach must be immediately reported.
The firm may have written arrangements with third-party providers to perform certain client or firm services. While associates may be directly involved in this activity, they are expected to not divulge information regarding securities recommendations or client securities holdings to any individual outside of the firm except:
- To complete transactions or account changes (i.e., communications with custodians).
- As necessary to maintain or service a client account (i.e., communications with a client attorney).
- With a service provider that supports the firm and only following the firm entering into a contractual agreement that prohibits the disclosure or of confidential information and only as necessary to carry out its assigned responsibilities.
- As permitted or required by law.
Associates are to conduct themselves with the utmost integrity and avoid any actual or perceived conflict with our clients. In this spirit, the following are required:
- Insider Trading —Associates must review and acknowledge their understanding and adherence to the firm's Insider Trading Policy.
- Acceptance of Gifts — All associates are prohibited from receiving any gift, gratuity, hospitality or other offering of more than de minimis value from any person or entity doing business with the firm. This gift policy generally excludes items or events where the employee has reason to believe there is a legitimate business purpose and must be pre-approved by the Chief Compliance Officer.
- Political Contributions — The firm does not engage in direct or indirect political contributions. Any political contributions for or by the firm or anyone associated with the firm in a solicitation capacity is strictly prohibited. The firm's policy is not designed to disallow personnel from engaging in their right of free but does place certain contribution level restrictions pursuant investment advisor regulation. The firm will be guided by rule of the Investment Advisers Act with to political contributions limits and political contributions. Therefore, the firm permits associates to make aggregate contributions up to $350 per election to an elected official or candidate the associate is entitled to vote, and up to $150 per election to an elected Official or candidate the associate is not entitled to vote. These de minimis exceptions are available only for contributions by individual associate, not the firm. Under both exceptions, primary and general elections would be considered separate elections. Associates are obligated to promptly inform the firm of any political contribution as they occur.
- Splitting of Fees — Sharing or splitting of advisory fees will only occur with other appropriately registered personnel and only as approved the firm.
- Director for an Outside Company — The firm prohibits its associates from serving as a director for an outside entity products, services or activities may be a conflict of interest.
- Outside Business Interests - Any associate wishing to engage in business activities outside of the firm must seek approval from the Principal prior to the engagement.
Payment of Services —Advisory client payment of services will be made to the firm only.
As an independent financial advisory firm with Certified Financial Planner Professionals(CFP®), we also follow the professional standards set forth by the CFP Board as outlined here:
The CFP Board adopted the Code of Ethics to establish the highest principles and standards. These Principles are general statements expressing the ethical and professional ideals certificants and registrants are expected to display in their professional activities. As such, the Principles are aspirational in character and provide a source of guidance for certificants and registrants. The principles form the basis of the Rules of Conduct, Practice Standards and Disciplinary Rules, and these documents together reflect CFP Board's recognition of certificants' and registrants' responsibilities to the public, clients, colleagues and employers.
Principle 1 – Integrity: Provide professional services with integrity.
Integrity demands honesty and candor which must not be subordinated to personal gain and advantage. Certificants are placed in positions of trust by clients, and the ultimate source of that trust is the certificant’s personal integrity. Allowance can be made for innocent error and legitimate differences of opinion, but integrity cannot co-exist with deceit or subordination of one’s principles.
Principle 2 – Objectivity: Provide professional services objectively.
Objectivity requires intellectual honesty and impartiality. Regardless of the particular service rendered or the capacity in which a certificant functions, certificants should protect the integrity of their work, maintain objectivity and avoid subordination of their judgment.
Principle 3 – Competence: Maintain the knowledge and skill necessary to provide professional services competently.
Competence means attaining and maintaining an adequate level of knowledge and skill, and application of that knowledge and skill in providing services to clients. Competence also includes the wisdom to recognize the limitations of that knowledge and when consultation with other professionals is appropriate or referral to other professionals necessary. Certificants make a continuing commitment to learning and professional improvement.
Principle 4 – Fairness: Be fair and reasonable in all professional relationships. Disclose conflicts of interest.
Fairness requires impartiality, intellectual honesty and disclosure of material conflicts of interest. It involves a subordination of one’s own feelings, prejudices and desires so as to achieve a proper balance of conflicting interests. Fairness is treating others in the same fashion that you would want to be treated.
Principle 5 – Confidentiality: Protect the confidentiality of all client information.
Confidentiality means ensuring that information is accessible only to those authorized to have access. A relationship of trust and confidence with the client can only be built upon the understanding that the client’s information will remain confidential.
Principle 6 – Professionalism: Act in a manner that demonstrates exemplary professional conduct.
Professionalism requires behaving with dignity and courtesy to clients, fellow professionals, and others in business-related activities. Certificants cooperate with fellow certificants to enhance and maintain the profession’s public image and improve the quality of services.
Principle 7 – Diligence: Provide professional services diligently.
Diligence is the provision of services in a reasonably prompt and thorough manner, including the proper planning for, and supervision of, the rendering of professional services.
For further information of the CFP Board and it’s standards please visit their website at: