The foremost priority we have in our role as your financial adviser is that, at all times, we will act as your fiduciary. The term fiduciary is defined as follows by the National Association of Personal Financial Advisors (NAPFA):

“A financial advisor held to a Fiduciary Standard occupies a position of special trust and confidence when working with a client. As a Fiduciary, the financial advisor is required to act with undivided loyalty to the client. This includes disclosure of how the financial advisor is to be compensated and any corresponding conflicts of interest.”

Our fiduciary responsibility to you as your financial adviser is an essential part of the fabric of Chieco Capital Management, LLC. As your financial adviser, this fiduciary responsibility to you and your best interests serve as a guide as we work together to determine the financial path that works best for you and with which you are most comfortable.

Integrity is the essential building block in earning and keeping your trust. We value our principles and we will not violate them under any circumstances. We are acutely aware that an excellent reputation can be harmed quite easily and repairing one’s reputation is a waste of time and resources if one holds himself to the highest standards. We aim to do our work as efficiently as possible while maintaining the highest character standards.

The key to an effective relationship with you is mutual honesty between adviser and client. Your expectations of us should include candor and honesty as we expect the same in return from you. We are dedicated to telling you things you need to hear from us rather than telling you the things you want to hear. We will fairly negotiate our fees with you and promptly inform you of any reason why a commitment cannot be met as originally communicated. It is our sincere intention to respond to any email or phone call from you the same day we receive your communication.

We intentionally designed our business model to greatly reduce the possibility of any real or perceived conflicts of interest with our clients. We are not compensated for recommending any particular product to you nor do we accept referral fees of any kind for the privilege of doing business with you. We are compensated solely by you, our clients. We believe that independence is an essential characteristic of the client-financial adviser relationship. The investment recommendations you receive from us will be based on what we truly believe is in your best interest.

As your financial adviser, it is important for us to continually improve our own education and professional competence to offer you superior expertise and service. One of our important priorities is to constantly search for improved strategies to help you be more likely to reach your financial goals. Any adjusted strategies that are offered to you for you to improve your chances of meeting your financial goals will be supported by a detailed analysis in writing illustrating the merits of our recommendation. We base our financial advice on our past research of capital markets as well as our perpetual process of continuing education and ongoing research.

At Chieco Capital Management, LLC, we maintain and adhere to our own Code of Ethics in addition to committing ourselves to comply with the following standards:

• The National Association of Personal Financial Advisors (NAPFA) Code of Ethics.
  
• The Certified Financial Planner (CFP) Board Code of Ethics and Professional Responsibility.
  
• The Financial Planning Association (FPA) Code of Ethics.
  
• The CFA Institute’s Code of Ethics and Standards of Professional Conduct.
  
• The American Institute of Certified Public Accountants (AICPA) Code of Professional Conduct.