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Code of Ethics

The management of Tropp & Company, Inc. believes that the business of the firm should be conducted in a legal and ethical fashion. In keeping with that belief we present the following code to be followed by all employees.

These principles provide the grounding for our understanding of the term ethical; all employees should use these principles as the basis for business decisions.

• We believe that all of our actions are subject to a higher authority than that of any governmental body; the legal rulings of our government outline the minimum that we must do in the conduct of our business but do not limit us in the pursuit of good business practices.

• We will, at a minimum, follow all legal guidelines in the conduct of our relationships with the stakeholders of our company including, but not limited to, employees, vendors, competitors and clients.

• We respect the dignity of human beings and will strive to pro-actively improve the condition of people with whom we do business.

• While we will compete aggressively for business, we will avoid false criticism of our competitors and will fairly represent our capabilities. If we become aware of another opportunity that improves the condition of our client, we will share that information openly.

• We are in business to make a profit and to support the families of our employees and owners. However, we will strive to maintain a fair margin and to avoid windfall profits at the expense of our clients or vendors.

• We are human beings and we will make mistakes. Our policy will be to quickly admit our errors and work to correct any damage caused by our shortcomings.

• We respect our environment and when given the opportunity will be pro-active in protecting and improving our world.

• We will be willing to re-evaluate our position on all matters, including this Code of Ethics, when we feel we are falling short of our mission.