Code of Ethics

Introduction

Foundry Wealth Group LLC ("Foundry Wealth Group," "we," "our," or "us") is committed to maintaining the highest standards of ethical conduct in all aspects of our business. This Code of Ethics establishes the principles and standards that guide our conduct and reflects our commitment to fiduciary excellence, integrity, and the protection of client interests.

As a registered investment adviser, we are subject to the fiduciary standard, which requires us to act in the best interests of our clients at all times. This Code of Ethics applies to all employees, officers, directors, and supervised persons of Foundry Wealth Group.

Fiduciary Duty

As fiduciaries, we have a legal and ethical obligation to act in the best interests of our clients. This means:

• Duty of Loyalty: We must place our clients' interests above our own and avoid conflicts of interest whenever possible. When conflicts cannot be avoided, we must fully disclose them and obtain client consent.
• Duty of Care: We must exercise reasonable care, skill, and diligence in providing investment advice and managing client assets.
• Duty of Disclosure: We must provide full and fair disclosure of all material facts, including fees, conflicts of interest, and risks associated with investment recommendations.
• Duty to Act in Good Faith: We must act honestly and in good faith in all client relationships.

We will always prioritize our clients' financial well-being and long-term success over any potential benefit to Foundry Wealth Group or its employees.

Conflicts of Interest

We recognize that conflicts of interest can arise in the investment advisory business. We are committed to identifying, disclosing, and managing conflicts of interest in a manner that protects our clients' interests.

Prohibited Activities

The following activities are strictly prohibited:

• Engaging in any transaction that creates a conflict between our interests and those of our clients
• Receiving compensation or other benefits from third parties in connection with client transactions, except as fully disclosed to clients
• Recommending investments in which we have a material financial interest without full disclosure
• Engaging in principal transactions with clients without proper disclosure and consent
• Using client assets for our own benefit or the benefit of other clients without authorization

Disclosure Requirements

When conflicts of interest cannot be avoided, we will:

• Fully disclose the conflict to affected clients in writing
• Obtain informed consent from clients before proceeding
• Document the disclosure and consent in client files
• Take steps to mitigate the impact of the conflict on clients

Personal Trading

Employees and supervised persons are subject to personal trading policies designed to prevent conflicts of interest and ensure that client interests come first.

Key Principles

• Client Priority: Client transactions always take priority over personal trading
• Pre-Clearance: Personal trades in securities recommended to clients must be pre-cleared
• Restricted Securities: Trading in certain securities may be restricted or prohibited
• Reporting: All personal securities transactions must be reported to the Chief Compliance Officer
• Holding Periods: Minimum holding periods may apply to personal trades

Prohibited Practices

• Trading ahead of client orders
• Front-running client transactions
• Using material non-public information
• Short-term trading in securities recommended to clients
• Trading in securities that conflict with client positions without disclosure

Gifts and Entertainment

We maintain strict policies regarding gifts and entertainment to prevent conflicts of interest and maintain our independence and objectivity.

General Policy

• Employees may not solicit or accept gifts, favors, or entertainment that could influence or appear to influence their professional judgment
• Modest business meals and entertainment are generally acceptable if they serve a legitimate business purpose
• All gifts and entertainment exceeding $100 in value must be reported to the Chief Compliance Officer
• Gifts from clients are generally prohibited, except for items of nominal value
• Gifts to clients must be reasonable and not create an appearance of impropriety

Confidentiality

We are committed to protecting the confidentiality of client information. All employees and supervised persons must:

• Maintain the confidentiality of all client information, including financial data, investment objectives, and personal information
• Use client information only for legitimate business purposes
• Not disclose client information to third parties without authorization, except as required by law or regulation
• Protect client information from unauthorized access, use, or disclosure
• Comply with all applicable privacy laws and regulations, including SEC Regulation S-P

Client information may only be shared with:

• Authorized employees and service providers who need the information to serve clients
• Regulatory authorities when required by law
• Third parties with explicit client authorization

Compliance and Reporting

All employees and supervised persons are required to:

• Read and acknowledge receipt of this Code of Ethics
• Report any violations or potential violations of this Code to the Chief Compliance Officer
• Cooperate fully with any investigation of potential violations
• Complete annual training on ethics and compliance
• Certify annually that they have complied with this Code of Ethics

Chief Compliance Officer

The Chief Compliance Officer is responsible for:

• Administering and enforcing this Code of Ethics
• Reviewing personal trading reports and pre-clearance requests
• Investigating potential violations
• Maintaining records of compliance activities
• Providing training and guidance on ethical conduct

Violations and Enforcement

Violations of this Code of Ethics will not be tolerated and may result in:

• Disciplinary action, up to and including termination of employment
• Reporting to regulatory authorities when required
• Legal action if violations involve illegal conduct
• Restitution to affected clients if applicable

We encourage employees to report suspected violations without fear of retaliation. We are committed to investigating all reports thoroughly and taking appropriate action.

Contact Information

If you have questions about this Code of Ethics or wish to report a potential violation, please contact: