Morse Asset Management, Inc. is an SEC registered investment advisor, and accordingly we have a fiduciary responsibility to our clients, which means we have an obligation to always put the interests of our clients ahead of our own interests. Thus, when our interests or those of our employees conflict with interests of our clients, our clients’ interests take precedence.

Robert B. Morse, the Chairman and Chief Executive Officer of Morse Asset Management, Inc. and most of its staff have been together in the investment advisory business for at least 10 years and in the industry at for at least 20 years, and fully understand the importance of our fiduciary obligations to our clients and the need for high ethical standards of conduct in all that we do. We have a Code of Ethics, which applies to all employees, and we have always operated in a manner designed to ensure that we have appropriately addressed the potential risks of conflicts involved in our investment management business.

We believe that our success is dependent upon managing our investment advisory business in an ethical manner, consistent with our fiduciary duty to our clients, and all applicable rules and regulations, and in a manner that includes appropriate disclosures of potential conflicts of interests relating to our operations. This philosophy of compliance and fiduciary responsibility to our clients is a basic tenet of Morse Asset Management, Inc.