Entertainment, Gifts & Travel

Our business survives upon successful, productive, relationships with vendors and clients. We recognize that modest, sensible gifts, entertainment or travel can be a normal part of doing business, but we must ensure that decisions relating to clients and vendors remain completely objective and avoid real or perceived conflicts of interest.

When doing business with our company, vendors must understand that our people must follow these guidelines:

·          Summit Advisors employees may only accept modest, sensible gifts which are given as a normal part of doing business.

·          Written advance approval is required by the President, for an employee to accept any gifts, gratuities, travel or entertainment or similar favors that may appear excessive.

·          Forms of gifts, entertainment and travel that are never allowed from vendors, and constitute a clear violation of company policy include:

4  Cash, gift cards, gift certificates, loans, stocks or stock options.

4  Excessive, lavish or frequent gifts or entertainment (some examples include season tickets, club memberships, expensive jewelry, computer equipment or any type of household item).

4  Any gift, entertainment or travel which imposes an obligation to give special consideration to the payer of any such expense.

4  Any item that is illegal, sexually explicit, involves gambling, or would violate our commitment of respect toward all those with whom we deal.

4     Summit Employees, when traveling, may not entertain a client in the evening. We believe the client should not be taken away from his/her family for entertainment purposes, unless the spouse is included.

Conflicts of  Interest

Summit Advisors expects business decisions to be made objectively and in the best interest of the company and our clients. Any situation that creates or appears to create a conflict between personal interests of Summit Advisors employees and the interests of Summit Advisors must be avoided.

A conflict of interest may arise when Summit Advisors is doing business with a supplier that employs, or is partially or fully owned by, a Summit Advisors employee or an employee's family member. Potential conflicts must be disclosed by employees. Summit Advisors also requires its vendors to disclose any actual or potential conflicts of interest that could be relevant to Summit Advisors management.

Supporting this Code of Business Conduct and Ethics will promote continued success between Summit Advisors and our vendors.

Failure to support this Code of Business Conduct and Ethics will negatively impact a vendor’s relationship with Summit and could also put an involved employee at risk.