Swift Financial Partners

Code of Ethics

Protecting Company Assets and Resources

Swift Financial Partners assets are to be used for your job and should be protected.

Company assets are meant for business, and not personal use. We all have a responsibility to protect and safeguard company assets from loss, theft, misuse and waste. These assets include, but are not limited to:

• The Swift Financial Partners name, our various brand names, our logos, and other brands
• Computers and ancillary equipment
• Software and software licenses
• Office supplies
• Fax machines and other office equipment
• Books, electronic media, CDs and DVDs and other media
• Business plans
• Technology
• Customer, supplier and distributor lists and information
• Physical property
• Patents, copyrights, trademarks, and all other forms of intellectual property

You should use company assets and funds for legitimate and authorized business purposes. The company does understand the need for limited and occasional use of company e-mail, the Internet and phones for personal purposes, subject to the guidelines. Company property should never be used for personal gain, and you should not allow company property to be used for illegal activities. If you become aware of theft, misuse or waste of our assets or funds or have any questions about your proper use of them, you should feel free to speak with your manager or your Human Resources department. Misappropriation of company assets is a breach of your duty to the company and may be an act of fraud against the company. Taking company property from our facilities without permission is regarded as theft and could result in dismissal. In addition, carelessness or waste of company assets may also be a breach of your duty to the company and could result in dismissal. Company assets include all memos, notes, lists, records and other documents (and copies of each of these) that you make or compile relating to the company’s business. All of these are to be delivered to the company promptly after your employment ceases, or at any time that the Company requests.

Use of E-mail, the Internet, Intranets, Telephones and Other Forms of Communication

Use our various forms of communication properly and appropriately. We provide e-mail, Internet and intranet access, telephones and other forms of communication to help our employees do their jobs. It is everyone’s responsibility to help maintain the confidentiality, integrity and availability of our communications infrastructure. When using these forms of communication, please remember:

• These systems are for business purposes. The Company does, however,
• Understand the need for limited and occasional use of Company e-mail, the internet, intranets and phones for personal purposes under certain circumstances. However, if you spend excessive time using e-mail, the Internet, intranets or your phone for non-work matters, you may have your access restricted or prohibited, and/or faces other disciplinary actions up to and including termination of employment.
• Use good judgment when using email. If the Company becomes involved in litigation or an investigation, your e-mails may have to be turned over to third parties. E-mail can be obtained even after you have deleted it from your in-box. Thus, avoid careless, exaggerated or inaccurate e-mail statements that could be misunderstood or used against you or the Company in a legal proceeding.
• Consider how your e-mail would be viewed if disclosed in the media or used as testimony. Before you hit “send,” think and reread.
• Don’t access, send or download any information that could be offensive, insulting, derogatory or harassing to another person, such as sexually-explicit messages, jokes or ethnic or racial slurs.
• Viewing internet sites that relate to pornography, gambling or gaming, or similar material is strictly prohibited.
• Don’t violate the copyright laws or compromise our network security by either installing other types of file sharing, applications that allow you to download music, video clips and/or image files. Use of videos, music, or other streaming media on your computer is prohibited.
• Instant messaging (IM) from your work computer is only permitted if approved by your IT department or manager.
• Manage and keep confidential (do not share) your computer user ID’s and passwords.
• Don’t send internal communications or confidential materials outside of the company unless you are authorized to do so.
• The use of personal software on your work computer or modification of Swift Financial Partners provided software is not permitted unless approved by your IT department.
• Don’t send internal communications or confidential materials outside of the company unless you are authorized to do so.

Conflicts of Interest and Corporate Opportunities

Avoid actual and potential conflicts of interest in performing your duties as a Swift Financial Partners employee and do not advance personal interests at the expense of Swift Financial Partners. As an employee, we expect that you will act in the best interests of Swift Financial Partners and avoid conflicts of interest. A conflict of interest may arise whenever a personal interest interferes – or even appears to interfere with – the interests of Swift Financial Partners. While we respect your right to manage your personal affairs and investments and we do not wish to intrude on your personal life, Swift Financial Partners employees should place the Company’s interest in any business transaction ahead of any personal interest or gain when the opportunity to do so arises. To avoid conflicts of interest, you should identify potential conflicts when they arise and notify your manager if you are unsure whether a relationship or transaction poses a conflict. Your manager will be able to pre-clear or resolve certain conflicts, or will be able to contact someone else at the Company who can. The following are examples of conflicts of interest that could arise, and are prohibited unless they have been pre-cleared or resolved in advance:

• You or someone with a close relationship with you owns more than 1% of a competitor’s, customer’s or supplier’s stock,
• You or someone with a close relationship with you receives improper personal benefits (such as cash, gifts, entertainment, services or discounts) as a result of your position at Swift Financial Partners,
• You work at an outside job, or serve as an officer, director or consultant to another company that interferes with your ability to do your job at Swift Financial Partners
• You participate in a business transaction or opportunity to your personal advantage based on information or relationships developed or discovered in your job at Swift Financial Partners, or You have a spouse, partner or family member that is in a direct reporting relationship with you, or you have the ability to supervise, review or influence the job evaluation, hiring, pay or benefits of any spouse, partner or family member who also works at Swift Financial Partners. In addition, loans to, or guarantees of obligations of Swift Financial Partners executive officers, directors and their family members are prohibited.

Keep in mind that not all conflicts are prohibited and the list above does not address every example. Some conflicts are permissible if they are disclosed and approved. Because it is impossible to describe every potential conflict, we rely on your commitment to exercise sound judgment and to seek advice when appropriate.

Confidential Information

Protect the confidentiality of nonpublic information about Swift Financial Partners.

As part of your job, you may learn or have access to nonpublic information or other confidential information relating to Swift Financial Partners businesses, operations, research or technology. You should not share confidential information with anyone unless there is a “need-to-know” and you are authorized to do so. Confidential information includes some of our most valuable assets, such as:

• New technology,
• Trade secrets,
• Pricing policies,
• Business plans and outlooks,
• Brand formulations, nonpublic financial results,
• New product developments or plans,
• Customer lists,
• Customer or supplier contracts,
• Tests, questions, and item banks,
• Software or computer programs,
• Merger, acquisition or divestiture plans, and
• Personnel acquisition plans or major management changes.

If you have confidential information, you should store or safeguard it where unauthorized people cannot see or access it. You should not discuss confidential information in elevators, restaurants, airplanes or other places where your conversation may be overheard. Also use care when speaking in front of family members who may not know that you are discussing confidential information, and may later inadvertently disclose it to others. You should also be careful not to leave confidential information in unattended conference rooms, or discard confidential information in public places where others can retrieve it. You obligation to safeguard the Company’s nonpublic information or other confidential information applies to you even after you leave the Company for as long as the information remains confidential and is not generally available to the public. You should only disclose confidential information after appropriate steps have been taken, such as signing a confidentiality agreement to prevent misuse of the information. Protect the confidentiality of nonpublic information about customers, suppliers, and others. We also respect confidential information regarding other companies – especially our customers. If you learn of confidential information about another company in the course of your job, you should protect it the same way that you would confidential information about Swift Financial Partners. In some instances confidential information regarding our competitors may come into your possession. You should consult with Swift Financial Partners’ legal department regarding any confidential information (or information that appears to be confidential) of a customer, supplier or competitor.

Accuracy of Records and Information Reporting

Our financial and accounting records are used to produce reports for our Company’s management, shareholders, governmental authorities and others. Therefore, we must all protect the Company’s financial strength and reputation for integrity by ensuring complete and accurate financial and accounting records that are not misleading. Implementing an appropriate control system helps to make sure this happens.

• All of your books, records and accounts –including time sheets, sales records, invoices, bills and expense reports – must be complete, accurate and reliable,
• Unrecorded, undisclosed or “off-the-books” funds or assets should not be kept for any purpose,
• Never falsify any document or distort the facts relating to a particular transaction,
• Transitions should be recorded in a timely manner and supported by appropriate
• documentation,
• Employees should not incur or pay the costs of anything using Company funds if the incurrence or payment is not authorized by your manager or supervisor or reimbursable and financial records that reflect the Company’s activities and transactions should be maintained in accordance with generally accepted accounting principles (GAAP) and in compliance with applicable laws and regulations.

Document and Record Retention and Dispositions

Comply with the document and record retention and disposition policy applicable to you.

Swift Financial Partners information and records are valuable corporate assets and must be managed with due care. Additionally, we must comply with legal and regulatory requirements that relate to document and record retention and disposition. As a result, we have an established policy for properly caring for, storing, retrieving and disposing of company records. Swift Financial Partners employees must manage records and information in a manner that ensures:

• Consistently organized filing, storage, and retrieval of recorded information,
• Record maintenance in whatever media satisfies legal, fiscal, regulatory, and operational requirements,
• Protection of Company records (including backups), needed documentation in the event of litigation, and Proper and timely disposal of records no longer of value.

Do not destroy documents or e-mails if you learn of litigation or investigations

If you are informed about pending or threatened litigation or a governmental investigation, you may not destroy any records (including e-mails) until you have been authorized to do so by a member of the Swift Financial Partners legal department. It may be a criminal offense to destroy documents or e-mails that are subject to a subpoena or other legal process. Any employee, who fails to comply with this policy, as well as applicable regulations and laws, is subject to termination and may also face criminal or civil prosecution, with possible fines and prison terms.

Media, Public and Governmental Inquiries

Don’t speak on behalf of Swift Financial Partners unless you are authorized to do so. We have professionals at our Company who are trained and qualified to release information to the public. When members of the media, financial analysts or government authorities contact the Company to request information, the response can have far-reaching implications, including effects on the Company’s ability to compete. When we provide information on the Company’s products, operational strategies or financial results, we must ensure both that the information is accurate and that the Company is ready to “go public” with that information. If you receive a request for information from outside the Company, you must forward it to the appropriate department if you are not authorized to speak on behalf of the company.

Discrimination and Harassment

Work place discrimination and harassment will not be tolerated. Employees need to know that they work in a safe and respectful environment where high value is put on equity, fairness and dignity. Swift Financial Partners has zero tolerance for harassment. Harassment generally means offensive verbal or physical conduct that singles out a person to the detriment or objection of that person. Harassment covers a wide range of conduct, from direct requests of a sexual nature, to insults, offensive jokes or slurs, and which results in hostile work environment. No employee or non-employee may harass another employee, candidate, customer, vendor, supplier, visitor or any other person on Company premises or while doing Company business regardless of location. Harassment on the basis of race, color, religion, national origin, gender, age, disability, sexual orientation, marital status, citizenship status, veteran status and any other group protected by law and sexual harassment is prohibited by the Company. In addition, conduct that does not violate the law but that is inappropriate is also prohibited. Reports of harassment will be promptly and thoroughly investigated in as confidential a manner as possible. We will take immediate and appropriate action if harassment is determined to have occurred.

Drugs and Alcohol

Don’t use illegal drugs, misuse alcohol or abuse prescription drugs while conducting Company business. Alcohol and drugs can impair your ability to work effectively and can endanger you and those around you. Swift Financial Partners prohibits the possession, use, sale or distribution of illegal drugs, including non-prescription controlled substances, while conducting Company business on or off Company premises. Employees should also not report for duty with levels of alcohol in their system that could impair job performance. These types of activity are grounds for disciplinary action, up to an including termination. As involvement with certain drugs is illegal, you may also be subject to arrest and prosecution by law enforcement agencies. Where allowable by law,

Protect all intellectual property owned by Swift Financial Partners and respect the rights of other companies.

Our brand identity and intellectual property are among our most valuable assets and are essential to maintaining our competitive advantages. These include the Swift Financial Partners name, logo, inventions, processes, innovations, content and software. It is extremely important that we protect these assets, and honor those of third parties. We are responsible for using basic intellectual property protections (such as copyrights, trademarks, service marks and patents) consistently and appropriately.

You should be aware that:

• Any intellectual property that employees create in the performance of their job responsibilities or that is related to Company business or activities belong to the Company and should always be adequately protected.
• Also, where permitted by applicable law, intellectual property created by contractors or agents under a contract with us are also the property of the Company as a work-for-hire. You are expected to promptly disclose any inventions, discoveries and improvement conceived or made during your employment with the Company or that are related to Company businesses or activities,
• You are required to execute applications, assignments or other instruments upon the Company’s request for applications for, and the attainment of, patents or to otherwise protect the interests of Swift Financial Partners.
• You should report any unauthorized use of the Company’ copyrights, patents, trademarks, service marks or other intellectual property to your manager or the Swift Financial Partners legal department.
• You should get written permission to use a third party’s copyrights, patents, trademarks, service marks or other intellectual property. If you want or need to use intellectual property that belongs to someone else, we must obtain a license to use the property or purchase the outright ownership of the property, You should not make copies of, nor publish any copyright-protected material until we have obtained written permission form the holder and determined that copying or publishing is legally permitted.

Contractual Authorization

Don’t sign a contract or agreement on behalf of Swift Financial Partners unless you are authorized. The Company’s contractual agreements govern its business relationships. Because the laws governing contracts are numerous and complicated, policies and procedures are in place to ensure that any contract entered into by and on behalf of the Company has the appropriate level of review and approval. As a result, employees of the Company who enter into contracts or agreements on the Company’s behalf must have proper authorization, including legal review where required by policy, prior to the execution of any contract.

Gifts, Meals, Services and Entertainment

Use your best judgment in giving and receiving gifts. We allow employees to offer or receive business gifts, favors and entertainment within specific guidelines. Gifts given or received should never include cash. You cannot solicit, encourage or actually receive any bribe or other payment, contribution, gifts or favor that could influence your or another’s decision. A bribe or improper payment is designed to influence another’s behavior and is always prohibited. Swift Financial Partners should never provide payments to customers, vendors or others that could be characterized as a bribe.  A bribe could take the form of direct cash payments or other forms of payments such as:

• Kickbacks,
• Unexplained rebates, or invoices for some disguised expense.
• Acceptable business gifts, meals, services or entertainment comply with this Code under the following guidelines if they: are relatively infrequent and not excessive in value for someone of your position, comply with applicable laws and are consistent with customary business practices would not embarrass the company, the person receiving the gift or the person giving he gift, if publicly disclosed.

Fair Competition and Antitrust

Compete and deal fairly with our customers, suppliers and competitors and use caution to avoid violating antitrust and competition laws. We believe in fair and open competition, and our success depends in part on our ability to offer competitively priced quality products and services. While we compete vigorously, we comply with applicable antitrust and competition laws wherever we do business. Antitrust or competition law is extremely complex and covers a broad range of conduct that may be declared illegal. Many antitrust or competition laws prohibit making agreements with competitors or customers to limit or restrict competition, or sharing information with competitors or customers that would limit or restrict competition. This information could include discussions or agreements with competitors relating to:

• Prices,
• Products and services
• Business practices
• Territories
• Bids for new business
• Distribution channels
• Customer lists

As a general rule, you should avoid discussing these topics with competitors. If a competitor raises any of these topics, you should interrupt and stop the conversation immediately. If you attend a conference and have informal contact with a competitor, it is always a good idea to limit informal contract to the extent possible and keep a written summary of any discussions that may have taken place. The standards for conspiracy to violate antitrust laws are extremely broad and an unlawful agreement can be found where competitors never met or exchanged words, but did something like share competitive information. Antitrust violations do not have to be proven by written agreements and violations can be inferred from an individual’s or organization’s actions. It’s a good idea to use extreme care when talking with competitors or potential competitors. Because antitrust or competition law is so complex and varies significantly from country to country, you should consult the Swift Financial Partners legal department in advance of any planned actions that might be considered anti-competitive. We also deal with our customers, suppliers and competitors. While comparative marketing and advertising are generally acceptable, employees should not unfairly disparage or criticize competitors’ products or services. While we strive to exceed customer’s expectations, we will only make honest and factual claims about our products, services and businesses that can be substantiated. Employees should also not seek to obtain information about our competitors through unlawful or unethical practices. 

Disciplinary Action for Code Violations

 Swift Financial Partners strives to impose discipline for each Code violation that fits the nature and particular facts of the violation. A failure by an employee to comply with laws or regulations governing company business, this Code or any other company policy or requirement may result in disciplinary action up to, and including, termination, and if warranted, legal proceedings. Please remember that some Swift Financial Partners businesses have their own disciplinary action policies that are distinct and separate from this Code. As stated on page 3, if there is any conflict between this Code and any supplemental policies applicable to your job, you should comply with the most restrictive requirement.

This is Property of Swift Financial Partners LLC