Paradigm Wealth Services, Inc. is committed to the highest ethical standards in furtherance of our mission of Wealth Management, customer service, professional development, and profitability. We recognize and hold our client's trust and relationship in the highest regard and with the utmost respect. Our policies, procedures, and standards provide guidance for application of the ethical values stated below in our daily life and work together as members of this firm.

We at Paradigm Wealth Services, Inc., are committed to:

Integrity. We will conduct ourselves with integrity in our dealings with and on behalf of our clients, friends, families, and centers of influence.

Excellence. We will conscientiously strive for excellence in our work.

Accountability. We will be accountable as individuals and as members of this firm for our ethical conduct and for compliance with applicable laws, policies, and directives.

Respect. We will respect the rights and distinctions of others.

Standards of Ethical Conduct Purpose Pursuit of a shared commitment to the core values of the firm, as well as a commitment to the ethical conduct of all activities, business relationships and self-conduct. Our Standards of Ethical Conduct are a statement of our belief in ethical, legal and professional behavior in all dealings within Paradigm Wealth Services, Inc. Applicability The Standards of Ethical Conduct apply to all members of the Paradigm Wealth Services, Inc., community, including: The President, Officers of The Board, Staff, Clients, volunteers, contractors, agents, and Centers of Influence for the firm.

1. Fair Dealing Members of the Paradigm Wealth Services, Inc., community are expected to conduct themselves ethically, honestly, and with integrity in all dealings. This means principles of fairness, good faith, and respect consistent with laws, regulations, and broker/dealer policies governing our conduct with others, both inside and outside the firm. Each situation needs to be examined in accordance with the Standards of Ethical Conduct and the SEC/SIPC and state regulations. No unlawful practice or a practice at odds with these standards can be justified on the basis of customary practice, expediency, or achieving a higher purpose.

2. Individual Responsibility and Accountability Members of the Paradigm Wealth Services, Inc., community are expected to exercise responsibility appropriate to their position and delegated authorities. They are responsible to each other, the firm, and the stakeholders both for their actions and their decisions not to act. Each individual is expected to conduct the business of the firm in accordance with the Core Values and the Standards of Ethical Conduct, exercising sound judgment and serving the best interests of the client(s) needs and relationship.

3. Respect for Others Paradigm Wealth Services, Inc. is committed to the principle of treating others with respect and dignity. Paradigm Wealth Services, Inc. prohibits discrimination and harassment and provides equal opportunities for all involved parties of the firm, regardless of race, color, national origin, religion, sex, gender identity, pregnancy, physical or mental disability, medical condition, ancestry, marital status, age, sexual orientation, citizenship, or status as a covered veteran. This firm is committed to creating a safe and drug-free work environment.

4. Compliance with Applicable Laws and Regulations Institutions of wealth management are subject to many of the same laws and regulations as other enterprises, as well as those particular to public entities. Paradigm Wealth Services, Inc. is expected to become familiar with the laws and regulations bearing on their areas of responsibility. Many but not all legal requirements are embodied in federal and state rules and regulations. Failure to comply can have serious adverse consequences both for individuals and for the firm, in terms of reputation, finances, and the health and safety of our client(s) community. Thus, business is to be conducted in conformance with legal requirements, including contractual commitments undertaken by and with individuals and center of influence to such commitments.

5. Compliance with Applicable Policies, Procedures, and Other Forms of Guidance Policies and procedures are designed to inform our everyday responsibilities, to set minimum standards and to give our client community notice of expectations. Members of the Paradigm Wealth Services, Inc., community are expected to transact all business in conformance with policies and procedures and accordingly have an obligation to become familiar with those that bear on their areas of responsibility. Each member is expected to seek clarification on a policy or other compliance directive he or she finds to be unclear, outdated or at odds with Paradigm Wealth Services, Inc., objectives. It is not acceptable to ignore or disobey policies or professional standards if one is not in agreement with them, or to avoid compliance by deliberately seeking loopholes.

6. Conflicts of Interest or Commitment Employee members of the Paradigm Wealth Services, Inc., community are expected to devote primary professional allegiance to the firm and to the mission of education, building client relationships and professional service. Outside employment must not interfere with firm duties. Outside professional activities, personal financial interests, or acceptance of benefits from third parties can create actual or perceived conflicts between the Paradigm Wealth Services, Inc., mission and an individual's private interests. Paradigm Wealth Services, Inc., community members who have certain professional or financial interests are expected to disclose them in compliance with applicable conflict of interest/conflict of commitment policies. In all matters, Paradigm Wealth Services, Inc., community members are expected to take appropriate steps, including consultation if issues are unclear, to avoid both conflicts of interest and the appearance of such conflicts.

7. Records: Confidentiality/Privacy and Access Paradigm Wealth Services, Inc., is the custodian of many types of information, including that which is confidential, proprietary, and private. Individuals who have access to such information are expected to be familiar and to comply with applicable laws, financial policies, directives, and agreements pertaining to access, use, protection, and disclosure of such information. Computer security and privacy are also subject to law and Paradigm Wealth Services, Inc., policy. The public right to information access and the individual's right to privacy are both governed by state and federal law, as well as by other rules and regulations.

8. Internal Controls Internal controls are the processes employed to help ensure that Paradigm Wealth Services, Inc., business is carried out in accordance with these Standards, policies and procedures, applicable laws and regulations, and sound business practices. They help to promote efficient operations, accurate financial reporting, protection of assets, and responsible fiscal management. All members of the Paradigm Wealth Services, Inc., community are responsible for internal controls. Any individual entrusted with funds, is responsible for ensuring that adequate internal controls exist over the use and accountability of such funds.

9. Use of Paradigm Wealth Services, Inc., Resources* Paradigm Wealth Services, Inc., resources may only be used for activities on behalf of the firm. They may not be used for private gain or personal purposes except in limited circumstances permitted by the firm owner, where incidental personal use does not conflict with and is reasonable in relation to Paradigm Wealth Services, Inc., duties (e.g., telephones). Members of the Paradigm Wealth Services, Inc., community are expected to treat business property with care and to adhere to laws, policies, and procedures for the acquisition, use, maintenance, record keeping, and disposal of Paradigm Wealth Services, Inc., property. For purposes of applying this policy, Paradigm Wealth Services, Inc., resources are defined to include but not be limited to the following, whether owned by or under the management of Paradigm Wealth Services, Inc.: *Cash, and other assets whether tangible or intangible; real or personal property *Receivables and the rights to use Paradigm Wealth Services Inc., facilities *The firm's name: Paradigm Wealth Services Incorporated *Paradigm Wealth Services Inc., records, including household and client records; and information technology infrastructures.

10. Financial Reporting All Paradigm Wealth Services Inc., accounting and financial records, tax reports, expense reports, time sheets and effort reports, and other documents, including those submitted to government agencies must be accurate, clear, and complete. All published financial reports will make full, fair, accurate, timely, and understandable disclosures as required under generally accepted accounting principles for government entities, bond covenant agreements, and other requirements. Certain individuals with responsibility for the preparation of financial statements and disclosures, or elements thereof, may be required to make attestations in support of the Standards.

11. Reporting Violations and Protection from Retaliation Paradigm Wealth Services, Inc., will report all known or suspected improper governmental activities. Managers and persons in supervisory roles are required to report allegations presented to them and to report suspected violations that come to their attention in the ordinary course of performing their supervisory duties. Reporting parties, including managers and supervisors, will be protected from retaliation for making such a report under the Policy for Protection of Whistle-blowers from Retaliation and Guidelines for Reviewing Retaliation Complaints (Whistle-blower Retalia­tion Policy).

12. Advocacy for Our Clients At Paradigm Wealth Services Inc., our guiding philosophy centers on the customization of each investor's portfolio to pursue their specific financial goals. We work collaboratively with each of our clients and their additional advisors, (i.e., tax, legal, etc.) to arrive at objective conclusions about critical issues they and/or their organizations face. All consideration is given to the numerous social and environmental issues most important to our client(s) in pursuit of their long-term financial objectives. Paradigm Wealth Services, Inc., holds the well-being and future interests our client in the highest regard, continually acting on their behalf and in their best interest.