Smart Portfolios^TM, LLC has established a Code of Ethics based on the principle that the Firm owes a fiduciary duty to its clients.

The confidence and trust placed in our firm and its employees by our clients is something we value and endeavor to protect. Smart Portfolios^TM LLC and its employees are subject to the following specific fiduciary obligations when working with clients:

• To place the client’s interest ahead of the Firm’s interest.
• Engage in personal investing that is in full compliance with the Firm’s Code of Ethics.
• Maintain independent and impartial advice by avoiding gifts or gratuities from individuals seeking to do business with the Firm.
• Maintain full compliance with the Federal Securities Laws.