When doing business, Prime' staff members consider the following:

Exercise due care to ensure it is fair, accurate, and complete.

Uphold integrity of the capital market and act for the benefit of the customers. Staff members who possess material non public information that could affect the value of an investment do not act or cause others to act based on the information they possess. Staff members do not engage in practice that distort prices or artificially inflate trading volume with the intent to mislead market participants. Act with integrity, competence, diligence, respect and in an ethical manner with the public, colleagues in the profession, existing and prospective customers. Staff members have a duty of loyalty to their customers and must act with reasonable care and exercise prudent judgment. Staff members must act for the benefit of customers and place their customers’ interest before their own interest. Prime’ staff members deal fairly and objectively with all customers when providing investment analysis, making investment recommendations, taking investment actions, or engaging in other professional activities. When Prime’ staff are in an advisory relationship with a client, they do the following: a  Make reasonable inquiry into existing or prospective customer’s investment experience, risk and return objectives and financial constraints prior to making any investment recommendation or taking investment action and must reassess and update this information regularly. Determine that an investment is suitable to the customer’s financial situation and consistent with the customer’s objectives, mandates, and constraints before taking any investment decision. Judge the suitability of investments in the context of the customer’s total portfolio. when communicating investment performance information, staff members make reasonable efforts to ensure that it is fair, accurate and complete. Prime’ staff members keep information about current, former and prospective customers confidential unless:            The information concerns illegal activities.  Disclosure is required by Law.The customer permits disclosers. Prime’ staff members do not accept or offer gifts, benefits, compensations or considerations that compete with or might reasonably be expected to create a conflict of interest with Prime. Prime’ staff members make reasonable efforts to detect and prevent violations of applicable laws and regulations. Prime' Staff members are prohibited from making any political contribution.