CODE OF ETHICS

We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for persons associated with our firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties of secrecy, honesty, good faith, and fair dealing with you. All persons associated with our firm are expected to adhere strictly to these guidelines. None of our members may buy or sell their own securities ahead of client trades. Persons associated with our firm are also required to report any violations of our Code of Ethics.

Secrecy is the key to our business so we make sure that your names and contact addresses are not discussed at any time, except by and between the Partners. All other members of our firm, just know the account name by 1 or 2 letters, which are usually initials. We maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm.

Through a detailed due-diligence, we make sure that we know our customers, their background and professional activities, but also their personal lives. Our clients should not be related to politics or have been involved in any type of scandal, corruption, or illegal activities. If at any point, we find that this is the case, we will immediately stop the relationship.

5Gens has been fortunate to receive many client referrals over the years. The referrals came from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The firm does not compensate referring parties for these referrals.

5Gens does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them.