We believe transparency begins with a well structured and articulated governance policy that provides for oversight of the management practices, behaviors, authority, accountability and control.

To augment this belief, we have assembled a governance structure for both fiduciary and non-fiduciary positions of our company. This structure provides oversight, review, and monitoring of management practices related to sound business structure and accountability for the ethical business and personal conduct of the officers, their direct reports and all associates.

The ethical operation of our company requires that all employees, managers and officers avoid any and all conflicts of interest, violation of regulatory laws, or any other actions contrary to our company mission and the laws of the United States. Additionally, we are recruiting an advisory board to counsel the company on these matters.

Careful attention will be perpetually given to the selection of both our advisory board and company managing members, all of whom must have significant experience with the responsibilities of senior level officers and advisory board members. This structure sets the foundation for our keen focus and continuous effort at responsible governance and direct accountability.

We believe ownership based governance is likely to reduce the corrupting influence of unaccountable power; furthermore we believe companies that embrace such a strategy should be better equipped to create wealth, compete in global markets, and solve the highly complex problems of the 3rd millennium. The keys to creating wealth and maintaining a free society lie primarily in the same direction. Both require broad based systems of accountability be built into the governance structures of companies themselves.

To assist in our independent audit efforts, and our oversight and investigation of unethical or irresponsible behavior toward employees, clients, customers, or the community, our company’s general counsel, has been directed by the Managing Principal to intake and investigate any allegations received from employees, clients or the public. These areas include, but are not limited to, alleged illegal activity such as: the manipulation of accounting data, earnings reports and audit reporting, fraud, inappropriate behavior toward others, misuse of power and authority, equal employment opportunity, or violation of interstate-intrastate commerce and regulatory laws.

A quarterly report to the Managing Members and Partners as well as the future advisory board is made by our outside general counsel and is augmented by the annual financial audit report to management and the advisory board which is conducted by an independent audit firm.

Any individuals or organizations who believe the proper ethical, social, financial and legal conduct of our company has been compromised are asked to contact:

David E. Steele