Introduction

Business ethics involves making judgements about what’s right and what’s wrong. In the business world, many ethical issues aren’t clear cut. That is why we’ve developed a Code of Ethics -- to provide guidelines and expectations about how we should act. This Code of Ethics is an expression of our recognition of responsibilities to our clients, associates, business partners, vendors and the community. It reflects our commitment to help our clients achieve their life goals.

The principles you see below capture the essence of three of the documents we use for guidance – our Employee Manual, SII’s Code of Ethics and the Financial Planning Association’s code. As a successful businessperson said, “Principles are to people like roots are to trees.”

Our Principles

INTEGRITY
We offer and provide professional services with integrity.
We are placed by our clients in positions of trust and confidence. The ultimate source of such trust is our personal integrity. In deciding what is right, we should rely on our integrity as the appropriate touchstone. Tell the truth, use good judgment and comply with securities laws and regulations. If you make a mistake, inform your manager so the appropriate action can be taken to correct the situation and avoid making the same mistake again. It is our responsibility to reinforce these guidelines in others, as our good reputation has taken years to build and can easily be diminished by any negative action. Should you ever feel you are in a situation that would compromise your integrity, please talk to your manager.

In our capacity as investment advisor representatives of SII Investments, we owe a fiduciary duty to our clients. We must put their interests first and avoid activities, interests and relationships that may run contrary to theirs.

OBJECTIVITY
We are objective in providing professional services to clients.
Objectivity requires honesty and impartiality. It is our responsibility to make full and adequate disclosures of all facts necessary to enable clients to make informed decisions. Our advertising and sales materials must be clear as to purpose and honest and fair as to content.

To help maintain objectivity, no employee is allowed to benefit, either financially or otherwise, directly or indirectly, from information learned in confidence through one’s employment with Ellenbecker Investment Group, Inc. In addition, Employees are not allowed to accept personal favors or gifts from any of the company’s clients, vendors, suppliers or service people without the prior consent of management.

COMPETENCE
We provide services to clients competently and maintain the necessary knowledge and skill to continue to do so.
To be competent we must attain and maintain a level of knowledge and skill, then apply it effectively. Competence also includes the wisdom to recognize our limits and know when to seek additional resources to meet our clients’ needs. In addition, we shall make a continuing commitment to learning and professional improvement.

No employee may solicit investments, quote pricing, provide investment information, provide any investment opinion or advice, comment with respect to investments or sell investments unless appropriately licensed and registered for securities and having the prior consent of management.

FAIRNESS
Our services are performed in a manner that is fair and reasonable to clients, business partners, vendors and employees.
Fairness requires impartiality, honesty and disclosure of any conflicts of interest. Fairness is treating others as you would want to be treated.

Ellenbecker Investment Group, Inc. is committed to a policy of equal employment opportunity for every employee. It is the company’s policy to seek and employ the best qualified personnel in all positions, to provide equal opportunity for training and advancement, and to administer these activities in a manner which will not discriminate against or give preference to any person because of race, color, religion, sex, age, national origin, handicap, ancestry, sexual orientation, marital status, or any other discriminatory basis prohibited by federal or state law. The company also is committed to providing a work environment in which employees are treated with courtesy, respect and dignity. The company will not tolerate any form of harassment, verbal or physical, with regard to an employee’s race, sex, national origin or any other protected characteristic. All employees are encouraged and directed to advise management of any concerns or complaints in this regard. All complaints of harassment of any kind will be investigated promptly and, where necessary, immediate and appropriate action, including discharge, will be taken to stop and remedy any such conduct.

CONFIDENTIALITY
Our information is confidential.
Client information is confidential and shall not be disclosed. This will allow us to create a relationship of personal trust and confidence.

All employees of Ellenbecker Investment Group, Inc., financial advisors, managers and staff must adequately protect customer confidentiality at all times. Unauthorized disclosure of confidential information about this company’s policies or procedures or about a client’s affairs is a serious violation of the policies of this company. No aspect of a client’s affairs, either personal or business may be discussed outside of the office. The confidentiality of a client’s documents in the possession of our company must also be protected. It is each staff member’s responsibility to maintain his or her office-space and store client material in a manner that is in alignment with the company’s client confidentiality policy. In fact, whether or not a particular person, firm or corporation is a client of our company should not be disclosed unless authorized in advance. Care should also be taken to ensure that no other client or visitor overhears or obtains access to a client’s affairs or papers. It is each employee’s full responsibility to uphold client confidentiality to the highest standards.

Professionalism
Our conduct in all matters should reflect credit upon the financial services profession.
It is our obligation to work with others to enhance and maintain the profession’s public image and to improve the quality of our industry’s services. Improving the community and the environment is a responsibility we all share.

Diligence
We act diligently in providing services.
Diligence is the provision of services in a reasonably prompt and thorough manner. It is our responsibility to do what we say we’re going to do; to promptly return e-mails and phone calls; to follow up on outstanding issues; and to meet deadlines.

“Most of the people we come in contact with, whether they are clients, vendors or employees are honest. They want to live in a world where they can work hard, make a contribution, be recognized and treated fairly.”
--Tom Isenberg of Western Extralite, winner of the American Business Ethics Award