Fiduciary Responsibility

White Pine Advisory is based on the founding principle that the client’s interests always come first. Even though the much discussed Fiduciary Rule is not being implemented by US regulators, White Pine will adhere to it by always putting its clients’ financial interests ahead of its own.

Everyone associated with White Pine Advisory should consider themselves to be obligated to act in the best interests of clients and as a fiduciary of clients at all times, regardless of whether or not the law requires it. This commitment does not allow for any exceptions whatsoever.

Suitability of Investments

The starting point of all of our client relationships is to ascertain the client’s goals for their portfolio and their level of risk tolerance. Before any investment decision is taken the first step is to determine whether or not it is compatible with the client’s expressed priorities. It is just as crucial to confirm that the client fully understands the nature of every proposed investment and its risk-return profile before it is implemented.

If a client does not fully understand an investment or is not comfortable with the level of risk it presents, then it is not suitable for this client, regardless of whether or not White Pine deems it to be in the client’s interest. If White Pine is concerned that the client’s low level of risk tolerance is not compatible with his or her long term interests, then the appropriate course of action is to educate the client, not to insist on investments that the client is not comfortable with. A better educated client may then be in a position to take on a level of risk that is more commensurate with his or her long-term financial goals.

It goes without saying that White Pine will never recommend an investment product or strategy that its Principal is not comfortable explaining to clients or that clients are not comfortable with owning.

Confidentiality

Financial information is a deeply personal matter. For this reason we will ensure that all of our clients’ financial data remain secure and confidential and are only shared for the sole purpose of servicing client accounts. We will otherwise only release information to third parties on the express written authorization of the client or in response to a judicial order.

In practice this means that no information whatsoever about a client or a client’s investments is to be disclosed without permission to anyone other than the client him or herself or the client’s legally authorized representative. This does not apply, of course, to a judicial order received from an officer of the law.

Conflicts of Interest

White Pine will not make any investment decisions or enter into any business relationship that places its own interests or those of its employees ahead of the interests of its clients. Any potential such conflicts will always be decided in the client’s favor.

White Pine will not enter into any revenue sharing agreements, nor will it accept any compensation of any kind, whether direct or indirect, for directing its clients to invest in particular financial vehicles or instruments. White Pine will fully align its interests with those of its clients by being compensated solely as a standard percentage of client assets (See separate fee schedule) and not based on volume or type of trades. More generally, White Pine must avoid not just actual conflicts of interest but even the appearance of conflicts of interest.

Transparency

We will always be fully transparent in all of our dealings with clients with respect to their portfolios, our investment process and our dealings with third parties.

Before investing a client’s portfolio, White Pine will explain clearly and completely to the client what it intends to do and why. Clients will receive a detailed quarterly statement of all of their holdings. Any questions that clients have should always be answered fully and as promptly as possible.

Due Diligence

White Pine will always fully research any investment it makes for a client’s portfolio to determine whether it is both attractive and appropriate. In line with this principle, White Pine undertakes not to make any investment on a client’s behalf that either the firm or the client does not fully understand.

The only thing worse than making an investment on a client’s behalf that does not perform as expected is making an investment that does not perform without the advisor having done the proper research beforehand. To minimize the risk that an investment will go wrong, White Pine must always do careful research before investing in anything, whether it is a fund or an individual security.

Sustainability

We believe that we cannot truly provide sustainable investing guidance to our clients without embracing sustainability in every aspect of our business. In order to credibly give clients advice on sustainable investing, White Pine must be able to demonstrate both expertise and commitment. This requires us to continually stay up to date on the latest sustainability research relevant to investing and to our operations. It also requires us to take obvious measures such as minimizing the use of paper in this paper intensive business and working to keep our carbon footprint as low as possible.

Legal and Ethical Conduct

White Pine will always obey all relevant laws and regulations and will adhere to the highest ethical standards in all its dealings with clients and the market in general.

White Pine Advisory and all associated with it need to uphold the high standards outlined in this statement of values not just because it is the right thing to do but also because it is the necessary thing to do. If an investment advisory business loses the trust of its clients, it will lose the ability to do business. These values are not just an ethical question, they are also a matter of practical necessity.