Code of Ethics
NORTHSTAR STRATEGIC INVESTMENTS, INC.
CODE OF ETHICS
Northstar Strategic Investments, Inc., a Florida Corporation, is an Investment
Advisor Firm registered with the State of Florida.
In accordance with Rule 204A-1 and related rule amendments under the Investment Advisers
Act of 1940, registered advisers are required to adopt codes of ethics to set forth standards
of conduct and require compliance with Federal and State securities laws for all associates
involved in investment advisory activities. Northstar is covered under the Small Entities Rule
in that, at this time, no Supervised Associates are employed and all trading and securities
activities are transacted by the President and CFO, a licensed Advisor.
Northstar’s first focus is to conduct business and build on the trust we have earned from our
clients, Federal and State regulatory institutions, and the general public. All Associates and
personnel must comply with applicable Federal and State securities laws, and above all,
conduct themselves in a manner appropriate for the well being of the client.
Northstar Advisors
and employees shall strive to maintain a high level of knowledge and ability through continuing
education, market and economic research, and shall not provide advice in areas where they are
not capable or qualified.
This Code of Ethics and all written policies and procedures require Northstar Associates and
employees to hold all assets and information in the strictest of privacy and confidence, and in
no way use any information to their own personal benefit. Associates may not take advantage
of their position for the purpose of furthering any private interest or as a means to making any
personal gain.
Northstar associates and employees shall keep all client data private unless
authorization is received from the client to share it. Northstar associates and employees
shall treat all documents with care and take care when disposing of them in compliance with
all applicable securities and related laws and regulations, and to prevent the misuse of any
materials that may be non-public information.
All associates and employs shall maintain the highest standards of business conduct when
providing investment advisory services to clients. Northstar shall keep and maintain lists
of securities that the advisory firm is analyzing or recommending for client transactions.
Clients shall be advised if an advisor or employee is also investing in any such securities and
investment opportunities must be offered first to clients before the advisor or employees may act
on them.
Associates shall fully describe methods of compensation and potential conflicts of interest to clients and specify the total cost of investments. Northstar will maintain “restricted lists” of issuers about which the advisory firm has inside information, and prohibit any trading (personal or for clients) in securities of those issuers.
Clients will be advised of the brokerages Northstar uses and will receive trade confirmation and
statements from said brokerages.
Under rule 204A-1, the adviser’s code all “access persons,” will report their personal securities
transactions and holdings and update the information no later than 30 days after the close
of each calendar quarter. The code of ethics may excuse access persons from submitting
transaction reports that would duplicate information contained in trade confirmations or account
statements.
Northstar will describe it’s codes of ethics to clients and, upon request, furnish clients with
a copy. Under rule 204-2(a)(12) advisors will keep copies of their code of ethics, records of
violations of the code, and actions taken as a result of the violations.
Northstar Associates and employees will endeavor to always take the high road and to be ever
mindful of the potential for misunderstanding that can accrue in normal human interactions.
Associates and employees will be diligent to keep actions and reactions far above board
that a client, or other professional would not doubt intentions. In all actions, associates and
employees will be mindful that in addition to serving our clients, we are about the business of
building a profession and our actions will reflect this.