Code of Ethics Summary
Uncompromising integrity and adherence to our fiduciary mandate.
At Sierra Crest Advisors, LLC, trust is the cornerstone of our advisory relationship. To safeguard that trust, we have adopted a rigorous, written Code of Ethics in compliance with SEC Rule 204A-1. This Code establishes the highest standard of business conduct, mandating that all employees, officers, and principals place the financial interests of our clients above their own at all times.
Every individual associated with Sierra Crest Advisors must acknowledge and adhere strictly to this Code. The following is a summary of its core principles and operational guardrails.
The Fiduciary Standard of Conduct
We are legally and ethically bound to act as fiduciaries. This means we must provide advice that is in your absolute best interest, disclose all material conflicts of interest, and execute our duties with unwavering loyalty, fairness, and good faith. We strictly prohibit any action that would disadvantage a client or exploit our position for personal gain.
Personal Securities Transactions
To prevent conflicts of interest, our Code strictly regulates the personal investing activities of our employees. Access persons (employees with access to client trading information) must submit regular reports of their personal securities holdings and transactions. Furthermore, client orders are always given priority over employee trades, and strict pre-clearance is required for employees to participate in initial public offerings (IPOs) or private placements.
Protection of Material Non-Public Information (MNPI)
Sierra Crest Advisors strictly prohibits the use of Material Non-Public Information. Our Code of Ethics and operational policies contain strict provisions forbidding any employee from trading, either personally or on behalf of others, on material non-public information, or from communicating such information to others in violation of the law (insider trading).
Gifts and Entertainment
To ensure that our objective judgment is never compromised by external influences, our Code imposes strict limitations on the giving and receiving of gifts and entertainment. Employees are prohibited from accepting inappropriate gifts, favors, or gratuities from clients, vendors, or broker-dealers that could be perceived as improperly influencing our advisory services or vendor selections.
SEC Rule 204A-1 Availability Statement
The information provided above is a high-level summary of our ethical framework. In accordance with SEC Rule 204A-1 of the Investment Advisers Act of 1940, Sierra Crest Advisors, LLC will provide a complete, unabridged copy of our Code of Ethics to any client or prospective client upon request.
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