AHRENS ADVISORS, L.P.

CODE OF BUSINESS CONDUCT AND ETHICS

I.          INTRODUCTION

Ahrens Advisors, L.P. (the Company) maintains a policy of strict compliance with the highest standards of ethical business conduct and the provisions of applicable laws federal securities laws, including rules and regulations promulgated by the Securities and Exchange Commission (the SEC).  This Code of Business Conduct and Ethics (the Code) applies to each employee of the Company (Employee).  It is designed to ensure compliance with legal requirements and the Companys standards of business conduct.  Employees shall read and understand this Code and uphold the standards in the Code in their day-to-day activities at the Company.

This Code does not address every possible situation that may arise, consequently every Employee is responsible for exercising good judgment, applying ethical principles, and bringing potential violations of the Policy to the attention of the Chief Compliance Officer of the Company (the CCO).  

Each Employee shall sign the acknowledgement form attached to this Code indicating his or her receipt and understanding of, and agreement to comply with this Code.  Such signed acknowledgement should be immediately returned the CCO.  

II.         GENERAL STANDARDS OF CONDUCT

A.         Corporate Conduct

The following general principles guide the Companys corporate conduct:

          The Company will act in accordance with applicable laws and regulations.

          The Company will provide products and services designed to help clients achieve their financial goals.

          The Company will conduct business fairly, in open competition.

          The Company will provide employment opportunities without regard to race, color, sex, pregnancy, religion, age, national origin, ancestry, citizenship, disability, medical condition, marital status, sexual orientation, veteran status, political affiliation, or any other characteristic protected by federal or state law.

          The Company will support the communities in which we operate.

B.         Individual Conduct

The following general principles guide the individual conduct of each Employee:

          The Employee will not take any action that will violate any applicable laws or regulations.

          The Employee will adhere to the highest standards of ethical conduct.

          The Employee will maintain the confidentiality of all information obtained in the course of employment with the Company.

          The Employee will bring any issues reasonably believed to place the Company at risk to the attention of the CCO.

          The Employee will not abuse or misappropriate the Companys assets or use them for personal gain.

          The Employee will not engage in any activities that create a conflict of interest between the Employee and the Company.

          The Employee will deal fairly with clients, colleagues, and others.

          The Employee will comply with this Code.

III.       ETHICAL BUSINESS PRACTICES

A.         Compliance With Laws and Regulations

It is the policy of the Company that any violation of applicable laws and of this Code shall be immediately reported to the CCO.  An Employee must not conduct individual investigations, unless authorized to do so by the CCO.  If an Employee who in good faith raises an issue regarding a possible violation of law, regulation or Company policy or any suspected illegal or unethical behavior they will be protected from retaliation.

B.         Falsification or Alteration of Records

Falsifying or altering records or reports, preparing records or reports that do not accurately or adequately reflect the underlying transactions or activities, or knowingly approving such conduct is prohibited.  Examples of prohibited financial or accounting practices include:

          Making false or inaccurate entries or statements in any Company or client books, records, or reports that intentionally hide or misrepresent the true nature of a transaction or activity.

          Manipulating books, records, or reports for personal gain.

          Failing to maintain books and records that completely, accurately, and timely reflect all business transactions.

          Maintaining any undisclosed or unrecorded Company or client funds or assets.

          Using funds for a purpose other than the described purpose.

          Making a payment or approving a receipt with the understanding that the funds will be, or have been, used for a purpose other than what is described in the record of the transaction.

C.         Political Contributions

No corporate funds, merchandise, or service may be paid or furnished, directly or indirectly, to a political party, committee, organization or to a political candidate or incumbent, except if legally permissible and if approved in advance in writing by the CCO.  This Code does not apply to or restrict the ability of any Employee of the Company to participate voluntarily in political activities on their own personal time or to make personal contributions.  However, the Company is prohibited from reimbursing any Employee for political contributions made from such individual's personal funds.

D.         Payments to Government Officials or Employees

Company funds or gifts may not be furnished, directly or indirectly, to a government official, government employee or politician for the purpose of obtaining or maintaining business on behalf of the Company.  Such conduct is illegal and may violate federal and state criminal laws.  Assistance or entertainment provided to any government office should never, in form or substance, compromise the Companys arms-length business relationship with the government agency or official involved.

E.         Competition and Fair Dealing

The Company seeks to outperform its competition fairly and honestly.  The Company seeks competitive advantages through superior performance, not through unethical or illegal business practices.  Stealing proprietary information, possessing trade secret information obtained without the owners consent, or inducing such disclosures by past or present employees of other companies is prohibited.  Each Employee of the Company should endeavor to respect the rights of and deal fairly with the Companys clients, customers, vendors, suppliers, and competitors.  No Employee of the Company should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other intentional unfair dealing practice.  The Companys Employees should not falsely disparage or make unfair negative comments about its competitors or their products and services.  Negative public statements concerning the conduct or performance of any former Employee of the Company should also be avoided.

Home        Intelligence        Services        Subscriptions        News        About Us

Contact Us       Terms of Use       Resend Documents       Shopping Cart

Copyright © 2008 The Consus Group LLC