Our Business Principles are supplemental to our Code of Ethics that is included in our ADV Part II. Our Code of Ethics is available upon request to current and prospective clients.
Our Business Principles are derived from the Code of Ethics developed by The Paladin Registry.
Our Business Principles 
The primary purpose of Our Business Principles is to help provide consumers with the information they need to determine the integrity of financial professionals. In addition, these Business Principles differentiates advisors who provide consumers with written documentation for their ethical practices from advisors who do not.
We know that consumers need objective information when they select financial advisors. We also know the critical importance of ethics and principles in our relationships with clients and the critical role we play in the achievement of their financial goals. By providing a copy of these principles we agree to adhere to the following ethical principles:
• We acknowledge that we are a Registered Investment Advisor or Investment Advisor Representative with a current registration that permits us to provide financial advice for fees.
• We acknowledge that we are a fiduciary when we provide financial advice and services.
• We will serve our clients with integrity, competence, independence, objectivity, and professionalism.
• We will not misrepresent or omit any information, when marketing my services, which would cause consumers to select us for the wrong reasons.
• We will provide full written disclosure for our credentials, ethics, business practices, and services (See my Paladin Registry Profile) upon request.
• We will only provide advice and services when we possess the necessary knowledge to provide expert advice and quality services.
• We will maintain our levels of knowledge and professionalism by participating in the continuing education programs of recognized associations and other third party service providers.
• We will achieve a thorough understanding of our clients’ current situations, concerns, needs, and goals before I provide any financial advice or services.
• We will provide investment advice that is suitable in regard to our clients’ return objectives and tolerances for risk.
• We will establish realistic expectations of the benefits and results that clients can expect from our advice and services.
• We will maintain the confidential nature of all client information and take reasonable steps to prevent access to the information by unauthorized people.
• We will provide open-architected financial strategies that give our clients a broad range of investment choices not limited to any particular company or group of products.
• We will avoid potential conflicts of interest that impact the risk exposure, performance, or expenses of our clients’ assets.
• We will avoid products that represent potential conflicts of interest or excessive expenses or risk to our clients.
• We will strive to be in compliance with all regulatory and statutory requirements that impact the delivery of our planning or investment services.
• We will provide reports and communications that can be easily understood by clients who are not investment experts.
• We will answer all client requests for information or resolution of problems in a timely, complete, and truthful manner.
• We will extend extra time and consideration to clients who have recently become responsible for significant asset amounts or are facing substantial emotional trauma - for example, pending or recent retirees, widows and widowers, divorcees, and the terminally ill.
• We will have an agreement in place with clients in regard to the basis and amount of my compensation before any advice or services are rendered.
• We will provide full disclosure for all sources of compensation that result from my advice and services.
• We will not accept additional amounts of compensation or other benefits from third parties for our advice or services to clients without our clients’ knowledge in advance.
• We will provide a written service agreement that is counter-signed by clients and does not contain provisions that are in conflict with any applicable regulations or fiduciary standards of care.
• We will maintain appropriate records that document our analysis, advice, and client communications.
Certification
I certify the information in Our Business Principles accurately reflects the ethical standards that govern Noyes Capital's relationships with clients.
Name of Financial Professional: Scott Noyes
Date of Agreement: November 26, 2007
