Client Services

Tull Financial Group, Inc. Code of Ethics

Introduction

Tull Financial Group, Inc. (henceforth, “TFG”) has set forth the following Code of Ethics (hereinafter referred to as the “Code”), as required by SEC Advisers Act Rule 204A-1. The purpose of the Code is to establish acceptable standards of business conduct, and to translate these standards within the fiduciary duties related to TFG’s daily business activities.

As a working foundation to the concepts driving TFG’s Code, we first accept and adhere to the Code of Ethics expressed by the Financial Planning Association (FPA), of which TFG’s Investment Adviser Representatives are members. The FPA’s Code of Ethics describes these 7 basic principles:

Principle 1: Integrity

An FPA member shall offer and provide professional services with integrity.

Principle 2: Objectivity

An FPA member shall be objective in providing professional services to clients.

Principle 3: Competence

An FPA member shall provide services to clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which the designee is engaged.

Principle 4: Fairness

An FPA member shall perform professional services in a manner that is fair and reasonable to clients, principals, partners, and employees and shall disclose conflict(s) of interest(s) in providing such services.

Principle 5: Confidentiality

An FPA member shall not disclose any confidential client information without the specific consent of the client unless in response to proper legal process, to defend against charges of wrongdoing by the FPA member or in connection with a civil dispute between the FPA member and client.

Principle 6: Professionalism

An FPA member’s conduct in all matters shall reflect credit upon the profession.

Principle 7: Diligence

An FPA member shall act diligently in providing professional services.

While these principles apply to FPA members, TFG requires that all its employees adhere to these standards as they relate to their positions within the firm. For a complete description of the FPA Code of Ethics, please refer to the following web link:

http://www.fpanet.org/member/about/principles/ethics.cfm

 TFG Fiduciary Responsibilities

A fiduciary relationship exists whenever one person trusts in or relies upon another. The U.S. Supreme Court described an investment adviser’s fiduciary duty as including, “…an affirmative duty of utmost good faith, and full and fair disclosure of all material facts.” (SEC v. Capital Gains Research Bureau, 375 U.S. 180, 1963.) These descriptions do apply to financial planners as well as investment advisers. The fiduciary duty is the fundamental and primary duty without which Tull Financial Group cannot adequately serve its clients. TFG must place the interests of the client above the firm’s interests (such as compensation) and must disclose any potential conflicts of interest when recommending investments. Advice rendered must be genuinely impartial.

TFG exercises the following four duties in enforcing appropriate fiduciary care with regard to its clientele:

1. The Duty to Disclose

Disclosure of Conflicts of Interest: TFG makes an active practice of rendering financial planning, investment advice and recommendations best suited to the client’s situation and expressed goals and objectives. It is TFG’s resolve to exercise and enforce full and fair disclosure of all material facts in situations where advice rendered may present a possible conflict of interest between the client and TFG. In these instances, TFG will fully inform the client of this concern, and present all facts relevant to the scenario. No actions will be taken by TFG in implementing the advice given until the parties have fully discussed the conflict, reached an agreement, and TFG has documented the matter fully.

Disclosure of Investment Risks: TFG exercises routine Due Care in its investigation of investments utilized in client recommendations. The companies which serve as custodians for TFG’s client investments (such as Schwab, Fidelity, and American Skandia) routinely provide annual Prospectuses directly to our clients regarding their investments. When deemed appropriate, TFG will take extra measures to fully inform clients about any new risk and/or suitability concerns discovered regarding investments presently owned by clients, or suitability concerns on investments inquired about by clients. In situations where a client insists on acquiring a significant position in a specific holding which TFG deems unsuitable, we will guide their interests outside of the investments actively managed by TFG and clarify our position on the investment related to their financial planning needs. Such a situation would be fully documented.

2. The Duty to Diagnose

It is the responsibility of TFG to adequately diagnose the client’s present portfolio, current financial circumstances, stated goals and objectives, and tolerance for risk in order to present accurate financial planning advice and recommend suitable investments appropriate for the client. It is also TFG’s responsibility to consider these facts in light of the current economic environment as advice is given. TFG diagnoses clients using any combination of the following, as appropriate to the planning services provided: (1) Request for current statements documenting all investments; (2) Completion of Monthly Expenses detail; (3) Copy of most recent Tax Return; (4) Pay stub copies; (5) Completion of Investment Policy and Risk Profile; and (6) any other pertinent materials deemed appropriate to complete the services requested by the client. TFG considers the Duty to Diagnose as an ongoing responsibility pertaining to all steps of the financial planning process, and the firm is resolved to address any suitability concerns affecting any client promptly upon discovery.

3. The Duty to Consult

The Financial Planning Profession encompasses numerous areas of specialization, and TFG acknowledges its limitations in providing full, comprehensive financial planning and investment advice. With this awareness, TFG sets forth the following policy: In situations where TFG’s professionals have any doubts concerning an issue that goes beyond their level of personal competence, an expert in that area will be consulted or, if more appropriate, the client will simply be informed of TFG’s limitations and not be billed for that service. TFG prohibits its professionals from practicing business in areas where they are not properly licensed.

4. The Duty to Keep Current

Because the Financial Planning Profession frequently encounters legislative changes germane to its functions, TFG professionals must adhere to the continuing education requirements set forth by the governing bodies of those licenses held within the firm. The professionals employed by TFG have been informed that they have a duty to keep reasonably abreast of current practice and information in the professional fields of which they hold themselves out to the public.

Persons Subject to the Code

All employees considered “access persons” are responsible for adhering to the requirements set forth in this Code. An “ access person” is defined as any person employed by TFG who has convenient access to any information related to client personal information, accounts, trades, investments, and other data directly involved with the financial planning and investment management process . Using this definition, all employees of TFG are considered access persons.

Standards of Ethical Conduct Governing the Firm and Those Subject to the Code

All access persons are expected to conduct themselves according to the standards set forth within the FPA Code (discussed above) as well as TFG’s Code, as expressed herein and all subsequent Codes as amended and maintained by TFG. Access persons must adhere to fundamental principles of openness, integrity, honesty, trust, and full compliance with the federal securities laws applicable to this firm and its operations.

Privacy Policy: Means of Protecting Material Nonpublic Information

TFG’s Privacy Policy applies to any individual to whom TFG renders financial services or has done so in the past (in other words, all clients of TFG). It covers any nonpublic personal information obtained from clients, as well as from other firms in connection with providing such services.

All nonpublic personal information is treated as strictly confidential and is not disclosed except to employees for the purpose of carrying out their responsibilities and to affiliated and nonaffiliated firms necessary to effect and administer custodial, brokerage, financial planning, legal, accounting, insurance or similar services requested and authorized by the client. Federal and state regulators also may review client records as permitted under law. TFG requires that our affiliates protect and restrict the use of client information to the same extent as TFG.

TFG’s Written Compliance Procedures (WCP) Manual discusses at-length the procedures involved with guarding client privacy as it relates to (1) Paper Files, (2) Electronic Files and Databases, and (3) Direct Client Communications (including e-mail, phone, and regular mail). Policy is also in-force for discretion within the office (keeping materials out of plain view) as well as outside of the office (not discussing sensitive business matters in public places).

In accordance with SEC Compliance requirements, TFG presents an informational Privacy Policy Summary to all clients on an annual basis, included with the Quarterly Report mailing for the 3 rd Quarter (September 30 th Quarter-end). The Privacy Policy is available to all new or existing clients upon request.

Methods for Overseeing Personal Securities Trading

The SEC has set forth requirements involving the adviser’s (TFG) oversight of certain personal investment activities as it relates to the firm’s access persons and those with whom they reside. The purpose of such oversight is to identify and examine any suspicious trading patterns which would violate regulations regarding ethics and fair practices.

Procedures are employed by TFG to regularly review personal account activities held by its employees, as described in the firm’s Written Compliance Procedures (WCP) Manual.

IPOs and Private Placement Approval Process for Access Persons

TFG does not engage in Initial Public Offerings, or Private Placements. Should any access person of TFG wish to participate in either of these instruments made available through another firm, they are required to first inform the CEO of their intentions. The CEO, upon review, must grant a pre-approval before that access person is clear to participate.

Review and Enforcement of All Compliance Requirements

TFG employees review the contents of its WCP Manual and Code annually, and as changes occur. TFG employs a 7-step process, illustrated in its WCP Manual, to address any compliance concerns discovered among its employees. Whistle-blowing protections are documented to protect employees. Previous Manuals and Codes used by TFG within the past 5 years are stored for SEC reference.