The Allegheny Code of Ethics and Code of Conduct are sets of principles and guidelines that define the professional conduct we expect of our advisors, representatives, and employees. These values represent who we are. They describe our intended state of being. They are so integral to our being that we would not abandon them even if we were penalized for holding them. We realize our duty and responsibility to place the investor first. These Codes work in tandem with the National Association of Securities Dealer (NASD) Rules of Conduct and all other applicable Standards of Professional Conduct.

Allegheny Code of Ethics

INTEGRITY
We conduct ourselves in a manner that reflects honorably upon Allegheny.

COMPETENCE
We provide all financial services with superlative knowledge and skill. This requires not only lifelong learning, but also the continual assessment of our ability to appropriately and effectively address the needs of those we serve.

FAIRNESS
We are fair and reasonable in all of our dealings with clients, principals, partners, employees, associates, and each other, and disclose all conflicts, or potential conflicts of interest.

DILIGENCE
We provide our services in a prompt and thorough manner, with outstanding planning and supervision.

OBJECTIVITY
We provide our financial services in an objective and unbiased manner.

CONFIDENTIALITY
We do not disclose any confidential information without the specific consent of our client, unless we are compelled to do so pursuant to proper legal process, or in judicial or regulatory proceedings.

PROFESSIONALISM
We epitomize the best and highest ethical standards of the financial services profession.

STEWARDSHIP
We recognize our responsibility to act with vision, ever mindful of the effects of our actions today and tomorrow on the future.

Code of Conduct

Allegheny and its agents shall observe high standards of commercial honor and just and equitable principles of trade in the conduct of their business. Acts and practices, including but not limited to the following, are considered contrary to such standards and may constitute grounds for denial, suspension, or revocation of registration, termination of employment, or such other action authorized by statute and Allegheny policies.

As a registered representative of Allegheny I will not:

• induce trading in a customer's account that is excessive in size or frequency in view of the financial resources and character of the account.
• recommend to a customer the purchase, sale, or exchange of any security or other investment without reasonable grounds to believe that such transaction or recommendation is suitable for the customer. I will make this recommendation based upon reasonable inquiry concerning the customer's investment objectives, financial situation and needs, and any other relevant information known by the broker-dealer.
• execute a transaction on behalf of a customer without authorization to do so.
• exercise any discretionary power in effecting a transaction for a customer's account without first obtaining written discretionary authority from the customer, unless the discretionary power relates solely to the time and/or price for the execution of orders.
• execute any transaction in a margin account without securing from the customer a properly executed written margin agreement promptly after the initial transaction in the account.
• enter into a transaction with or for a customer at a price not reasonably related to the current market price of the security, and will not receive an unreasonable commission, fee, or profit.
• effect any transaction in or induce the purchase or sale of any security or other investment by means of any manipulative, deceptive or fraudulent device, practice, plan, program, design or contrivance, which may include, but not be limited to:
  • Effecting any transaction in a security that involves change in the beneficial ownership thereof.
  • Entering an order or orders for the purchase or sale of any security with the knowledge that an order or orders of substantially the same size, at substantially the same time, and substantially the same price, for the sale of any such security, has been or will be entered by or for the same or different parties for the purpose of creating a false or misleading appearance of active trading in the security, or a false or misleading appearance with respect to the market for the security. I understand that nothing in this subsection shall prohibit me from entering bona fide agency cross transactions for my customers.
  • Effecting, along or with one or more other persons, a series of transactions in any security creating actual or apparent active trading in such security or raising or depressing the price of such security, for the purpose of inducing the purchase or sale of such security by others.
• guarantee a customer against loss in any security or other investment account.
• publish or circulate, or cause to be published or circulated, any notice, circular, advertisement, newspaper article, investment service, or communication of any kind which purports to report any transaction as a purchase or sale of any security unless I believe that the transaction was a bona fide purchase or sale of the security.
• use any advertising or sales presentation in such a fashion as to be deceptive or misleading. I will not distribute any non-factual data, material, or presentation based on conjecture, unfounded or unrealistic claims or assertions.
• lend or borrow money or securities to or from a customer, and will not act as a custodian for money, securities, or an executed stock power for a customer.
• affect securities transactions not recorded on the regular books or records of Allegheny, unless Allegheny Compliance authorizes the transactions in writing prior to the execution of the transaction.
• establish or maintain an account containing fictitious information in order to execute transactions which would otherwise be prohibited.
• share directly or indirectly in profits or losses in the account of any customer without Allegheny's written authorization.
• divide or split my commissions, profits, or other compensation from the purchase or sale of securities with any person not also registered with Allegheny.
• purchase a new issue of securities (hot issue) that trades at a premium in the immediate after market for my account or the account of my immediate family, contrary to the Free Riding and Withholding Interpretational Memorandum of NASD.

As a registered representative of Allegheny I will:

• fully and completely disclose any and all outside business activities and private securities transactions to Allegheny, and will not participate in such activities until I receive written permission from Allegheny to do so.
• furnish customers purchasing securities with a prospectus for the offering. I will furnish this information no later than the date of confirmation of the transaction.

Securities Reporting Requirements for Access Persons

APPLICATION OF THE CODE OF CONDUCT TO ACCESS PERSONS OF ALLEGHENY
The provisions of this section apply to every security transaction, in which an Access Person of Allegheny has, or by reason of such transaction acquires, any direct or indirect beneficial interest, in any account over which he has any direct or indirect control. Generally, an Access Person is regarded as having a beneficial interest in those securities held in his or her name, the name of his or her spouse, and the names of his or her minor children who reside with him/her. An Access Person may be regarded as having a beneficial interest in the securities held in the name of another person (individual, partnership, corporation, trust, custodian, or another entity) if by reason of any contract, understanding, or relationship he obtains or may obtain benefits substantially equivalent to those of ownership. An Access Person does not derive a beneficial interest by virtue of serving as a trustee or executor unless the person, or a member of his/her immediate family, has a vested interest in the income or corpus of the trust or estate. However, if a family member is a fee-paying client, the account will be managed in the same manner as that of all other Allegheny clients with similar investment objectives.

If an Access Person believes that he should be exempt from the reporting requirements with respect to any account in which he has direct or indirect beneficial ownership, but over which he has no direct or indirect control in the management process, he should so advise the CO in writing, giving the name of the account, the person(s) or firm(s) responsible for its management, and the reason for believing that he should be exempt from reporting requirements under this Code.

USE OF PRONOUNS
Words used in this document in the masculine shall be read and construed in the feminine or neuter where required by the context in which they are used. Words in the singular shall include the plural and vice versa where the context so requires.

ON BECOMING AN ACCESS PERSON
Any employee of Allegheny who during the course of his employment becomes an Access Person must provide the CO with an Initial Securities Holdings Report no later than 10 days after the employee becomes an Access Person. This report must include the following information:

• A list of securities, including the title, number of shares, and/or principal amount (if fixed income securities) of each covered security in which the Access Person had any direct or indirect beneficial interest or ownership as of the date the employee became an Access Person;
• The name of any broker, dealer or bank with whom the Access Person maintained an account, or in any other account in which securities were held for the direct or indirect benefit or ownership of the Access Person;
• The date the report is submitted to the CO by the Access Person.

QUARTERLY TRANSACTION REPORTS - RULE 204-2(A)(12) OF THE ADVISERS ACT
Every Advisory Representative and/or Access Person must submit a Personal Securities Trading Report to the CO not later than 10 days after the end of each calendar quarter listing all securities transactions executed during that quarter in the Access Person's brokerage account(s) or in any account(s) in which the Access Person may have any direct or indirect beneficial interest or ownership. The quarterly Personal Securities Trading Report must contain the following information:

The date of each transaction, the name of the covered security purchased and/or sold, the interest rate and maturity date (if applicable), the number of shares and/or the principal amount of the security involved;

The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition);

The price at which the covered security was effected;

The name of the broker, dealer or bank through whom the transaction was effected; and

The date the report is submitted to the CO by the Advisory Representative and/or Access Person. (Note: The report must be submitted to the CO within 10 calendar days following the end of the quarter.)

ANNUAL SECURITIES HOLDINGS REPORT
Every Access Person must submit an Annual Personal Securities Holdings Report to the CO listing all covered securities held by the Access Person as of December 31 of each year. The report must be submitted not later than 10 calendar days following year-end and must be current as of a date no more than 30 days before the report is submitted. The Annual Personal Securities Holding Report must contain the following information:

The title, number of shares and principal amount (if fixed income securities) of each covered security in which the Access Person had any direct or indirect beneficial ownership interest or ownership;

The name of any broker, dealer or bank with whom the Access Person maintains an account in which any covered securities are held for the direct or indirect benefit of the Access Person; and

The date the annual report is submitted by the Access Person to the CO.

In addition to the reporting provisions of sub-sections 5.3 and 5.4, above, Access Persons will be required annually read and sign Allegheny's Code of Conduct regarding employee securities transactions.

REPORTS OF ASSOCIATES' SECURITIES TRADES IN ACCOUNTS WITH BROKER/DEALERS
All Associates of Allegheny having account(s) with any broker/dealer must ensure that the account(s) are established so that duplicate copies of trade confirmations and monthly account statements are submitted directly to Allegheny by the broker/dealer.

In lieu of manually listing each securities transaction on the Personal Securities Trading Report, an Associate may affix (staple) copies of trade confirmations received during that quarter to his/her report.

NEGATIVE REPORTS
Although the Rule 204-2(a)(12) and Rule 17j-1 do not require negative reports, it is the policy of Allegheny that Personal Securities Trading Reports be submitted quarterly by all associated persons whether or not securities transactions have occurred in their accounts during the period. Those associates having no securities transactions to report must indicate this fact in his/her quarterly report. The report must then be dated, signed and submitted to the CO for review.