Code of Ethics

BHAM has established a Code of Ethics that will apply to all of its associated persons. BHAM is considered a fiduciary according to the Investment Advisers Act of 1940. As a fiduciary, it is an BHAM’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. BHAM has a fiduciary duty to all clients. This fiduciary duty is considered the core underlying principle for the advisor’s Code of Ethics which also covers its Insider Trading and Personal Securities Transactions Policies and Procedures.  BHAM requires all of its supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and when changes occur, all supervised persons will sign an acknowledgment that they have read, understand and agree to comply with the advisor’s Code of Ethics. BHAM has the responsibility to make sure that the interests of all clients are placed ahead of BHAM’s or its supervised person’s own investment interest. Full disclosure of all material facts and potential conflicts of interest will be provided to clients prior to any services being conducted. BHAM and its supervised persons must conduct business in an honest, ethical and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients.

Customer Privacy Policy

In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA
requires certain financial institutions, such as investment advisor firms, to protect the privacy of
customer information. In situations where a financial institution does disclose customer information to non-affiliated third parties, other than permitted or required by law, customers must be given the opportunity to opt out or prevent such disclosure. BHAM does not share or disclose customer information to non-affiliated third parties except as permitted or required by law.

BHAM is committed to safeguarding the confidential information of its clients. BHAM holds all
personal information provided by clients in the strictest confidence and it is the objective of
BHAM to protect the privacy of all clients. Except as permitted or required by law, BHAM does
not share confidential information about clients with non-affiliated parties. In the event that there
were to be a change in this policy, BHAM will provide clients with written notice and clients will
be provided an opportunity to direct BHAM as to whether such disclosure is permissible.

To conduct regular business, BHAM may collect personal information from sources such as:

  • Information reported by the client on applications or other forms the client provides to BHAM
  • Information about the client’s transactions implemented by others
  • Information developed as part of financial consultations and analyses

To provide related services for client accounts, it is necessary for the BHAM to provide access to
customer information within the firm and to non-affiliated companies with whom BHAM has
entered into agreements. To provide the utmost service, BHAM may disclose the information
below regarding customers and former customers, as necessary, to companies to perform certain
services on the BHAM’s behalf.

  • Information BHAM receives from the client on applications (name, social security number, address, assets, etc.)
  • Information about the client’s transactions with others (account information, payment history, parties to transactions, etc.)
  • Information about a client’s financial products and services transaction with the BHAM

Since BHAM shares non-public information solely to service its client, BHAM does not disclose
any non-public personal information about the BHAM’s customers or former customers to anyone,
except as permitted by law. However, BHAM may also provide customer information outside of
the firm as required by law, such as to government entities, consumer reporting agencies or other
third parties in response to subpoenas.

Current SEC Filings

In order to obtain these documents please contact us and select which forms you would like to receive.

  • ADV Part 2
  • ADV Schedule F

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