Code of Ethics ......

• Mitre Group has a Code of Ethics that applies to all officers, registered representatives and staff that are associated with our firm.

• Every aspect of our business will be conducted in a fair, lawful and ethical manner.

• Our customers will be offered only those pre-approved products / services, which have been determined to be appropriate for their specific needs and which provide fair value.

• It is our obligation to respect and protect the right to privacy of all our clients.

• Confidential or proprietary information, obtained in the course of employment with the Mitre Group, is not to be used solely for personal gain or to be shared with others for their personal benefit.

• All efforts are to be made to avoid actual or apparent conflicts of interest.

• Strict compliance with all laws and regulations governing the securities industry is paramount.

• Management of the Mitre Group will lead by example, creating an environment encouraging honesty and fair play by all employees in the conduct of his or her duties.

• Each registered employee has been assigned to a Supervising Principal for supervisory and guidance purposes.

• Management has reviewed the qualifications, experience and training of all individuals prior to assigning any supervisory responsibilities.

• Individual employees not living up to this Code of Ethics, as well as all other polices and directives issued by the Mitre Group, in every manner, during the course of any activities undertaken of behalf of the Mitre Group may be subject to immediate termination.

• All employees are required to report any possible violation of Code of Ethics to the compliance department or a member of the Senior Management Team.