Code of Ethics
Our Code of Ethics
American Trust Investment Services Advisory, Inc places the highest priority on maintaining its reputation for integrity and professionalism. American Trust Investment Services Advisory, Inc has adopted its Code of Ethics ("Code") to ensure that the high ethical standards long maintained by American Trust Investment Services Advisory, Inc continue to be applied. A copy of the Code will be provided to the clients upon request. The purpose of the Code is to preclude activities which may lead to or give the appearance of conflicts of interest, insider trading and other forms of prohibited or unethical business conduct. American Trust Investment Services Advisory, Inc and its financial advisers are subject to the following specific fiduciary obligations when dealing with clients:
· Act in their customers' best interest;
· Adopt procedures reasonably designed to detect potential conflicts;
· Eliminate those conflicts of interest whenever possible; Provide
· Adopt written supervisory procedures reasonably designed to ensure that any remaining conflicts, such as differential compensation, do not encourage financial advisers to provide any service or recommend any
product that is not in the customer's best interest;
· Obtain retail customer consent to any conflict of interest related to recommendations or services provided;
· Provide retail customers with disclosure in plain English concerning recommendations and services provided, the products offered and all related fees and expenses.
Participation or Interest in Client Transaction:
American Trust Investment, Inc does have employees that are registered broker-dealer representatives and will seek authorizations from the clients for the discretion to trade with the broker-dealer deemed most appropriate.
In some cases, clients of American Trust Investment Services Advisory, Inc may liquidate positions for financial reasons or non-American Trust Investment Services Advisory, Inc clients may require the liquidation of bond positions that would be appropriate for American Trust Investment Services Advisory, Inc clients. In those cases, American Trust Investment Services Advisory, Inc may facilitate a cross trade after soliciting competitive bids and offers and determining best execution. In these cases a Principal or Representative of American Trust Investment Services Advisory, Inc may receive a transaction fee from non-American Trust Investment Services Advisory, Inc clients.
American Trust Investment Services Advisory, Inc has an internal policy restricting the managing advisors from receiving short term benefits from short term price movements of securities caused by the activity of the separately managed accounts. Below is an abstract of American Trust Investment Services Advisory, Inc's Internal Management policy regarding Short Swing Rule: The managing advisors will not purchase a security in order to benefit from the price impact* of the multiple individually managed accounts purchasing or selling one security. Any short swing profits will be contributed to the separately managed accounts in proportion to the assets in the account.
*Price impact is defined as a movement of a stock of more that $0.25 caused by the demand/supply impact of the multiple accounts buying or selling a security.
Advisory Representatives must disclose personal securities accounts and report at least quarterly any reportable transactions in their personal accounts.
Employees must send monthly statements and all transaction reports to the Chief Compliance Officer of American Trust Investment Services Advisory, Inc's RIA) all business, financial or personal relationships that may result in access to material, non-public information.
FINRA BrokerCheck: http://brokercheck.finra.org/
FINRA Securities Helpline for Seniors: 844-57-HELPS (844-574-3577)