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Code of Ethics

The Investment Advisers Act of 1940 imposes a fiduciary duty on investment advisers. As a fiduciary, Pebble Management Group, LLC (PMG) has a duty of utmost good faith to act solely in the best interests of each of our clients. Our clients entrust us with their funds, which in turn places a high standard on our conduct and integrity. Our fiduciary duty compels all direct employees and representatives licensed with PMG (employees) to act with the utmost integrity in all of our dealings. This fiduciary duty is the core principle underlying this Code of Ethics and represents the expected basis of all of our dealings with our clients. 

Standards of Conduct 

This Code of Ethics consists of the following core principles:

  • The interests of clients will be placed ahead of the firm's or any employee's own investment interests.
  • Employees are expected to conduct their personal securities transactions in accordance with the Personal Trading Policy and will strive to avoid any actual or perceived conflict of interest with the client.  Employees with questions regarding the appearance of a conflict with a client should consult with the CCO before taking action that may result in an actual conflict.
  • Employees will not take inappropriate advantage of their position with the firm.
  • Employees are expected to act in the best interest of each of our clients.
  • Employees are expected to comply with federal securities laws. Strict adherence to the policy and procedure manual will assist the employee in complying with this important requirement.

Protection of Material Nonpublic Information
As more fully discussed within our Privacy Policy, employees are expected to exercise diligence and care in maintaining and protecting our client's nonpublic, confidential information.

Employees are also expected to not divulge information regarding PMG's securities recommendations or client securities holdings to any individual outside of the firm, except:

  • As necessary to complete transactions or account changes (for example, communications with brokers and custodians);
  • As necessary to maintain or service a client or his/her account (for example, communications with a client's accountant);
  • With various service providers providing administrative functions for PMG (such as our technology service provider), only after we have entered into a contractual agreement that prohibits the service provider from disclosing or using confidential information except as necessary to carry out its assigned responsibilities and only for that purpose; or
  • As permitted by law.

Personal Conduct
As noted above, employees are expected to conduct themselves with the utmost integrity and to avoid any actual or perceived conflict with our clients. In this spirit, the following are required of employees:

Acceptance of Gifts

Employees are prohibited from receiving any gift, gratuity, hospitality or other offering of more than de minimis value from any person or entity doing business with PMG. This gift policy generally excludes items or events where the employee has reason to believe there is a legitimate business purpose. The term "de minimis" is defined as $100 or less. Additionally, the receipt of an occasional dinner, a ticket to a sporting event or to the theater, or comparable entertainment also shall be considered to be of de minimis value if the person or entity providing the entertainment is present. No employee may give or accept cash or cash equivalent gifts to or from a client, prospective client, or any entity that does business with or on behalf of the adviser.

Service as Director for an Outside Company

Any employee wishing to serve as director for an outside company (public or private) must first seek the approval of the CCO. The CCO, in reviewing the request, will determine whether such service is consistent with the interests of the firm and our clients.

Outside Business Interests

Any employee wishing to engage in business activities outside of PMG's business must seek approval from the CCO and, if requested, provide periodic reports to the CCO summarizing those outside business activities.


Pebble Management Group, LLC is a Registered Investment Adviser. Information presented in this publication is not intended to be specific investment advice. Investors should consult a qualified financial adviser before making investments specific to their needs and situation. The information in this website constitutes neither an offer to sell nor a solicitation to invest. Such offer or solicitation will be made only in those jurisdictions where permitted by law.

To the extent that this material concerns tax or legal matters, it is not intended or written to be used, and cannot be used, by a taxpayer for the purpose of avoiding penalties that may be imposed by law. Each taxpayer should seek independent advice from a tax and/or legal professional based on his or her individual circumstances.

These materials are provided for general information and educational purposes based upon publicly available information from sources believed to be reliable—we cannot assure the accuracy or completeness of these materials. The information in these materials may change at any time and without notice.

This communication is strictly intended for individuals residing in the state(s) of LA. No offers may be made or accepted from any resident outside the specific states referenced.

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