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Proprietary Trading of the Adviser and Personal Trading Activities of Supervised Person

A. Proprietary Trading
CIS will never sell or trade its proprietary securities to its clients.

B. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of CIS or CIS may buy or sell securities for themselves that are also being
bought or sold for clients. The money manager will where appropriate group the reps trades in a block trade
with the clients to avoid any conflict of interest. The money manager will also at times review portfolios one at
a time and make re-balancing adjustments accordingly. Again, the reps will not be given any advantage and
will be traded as their number comes up in the review process.

C. Trading Securities At/Around the Same Time as Clients’ Securities
From time to time, CIS or representatives of CIS may buy or sell securities for themselves at or around the
same time as clients. See above.

Best Execution

Policy
As an investment advisory firm, CIS has a fiduciary and fundamental duty to seek best execution for client
transactions.

CIS, as a matter of policy and practice, seeks to obtain best execution for client transactions, i.e., seeking to obtain
not necessarily the lowest commission but the best overall qualitative execution in the particular circumstances.
CIS policies are modeled after the guidelines articulated by the regulators; specifically, it believes that, to a
significant degree, best execution is a qualitative concept. In deciding what constitutes best execution, the
determinative factor is not the lowest possible commission cost, but whether the transaction represents the best
qualitative execution. In making this determination, CIS's policy is to consider the full range of the broker's
services, including without limitation the value of research provided, execution capabilities, commission rate,
financial responsibility, administrative resources and responsiveness.

With regard to best execution, our RIA’s custodian has an excellent track record and is able to document and
create studies regarding their best execution better than CIS would be able to, simply because they have more
resources to do it better than we ever could.

Cornerstone Investment Services LLC Investment Adviser Representatives (IAR) are not also registered
representatives of a Broker-Dealer (BD). Transactions for CIS’s RIA clients are transacted through the RIA’s
custodian. There is no conflict since the reps do not get paid a commission.

Background
Best execution has been defined by the SEC as the “execution of securities transactions for clients in such a
manner that the clients’ total cost or proceeds in each transaction is the most favorable under the circumstances.”
The best execution responsibility applies to the circumstances of each particular transaction and an adviser must
consider the full range and quality of a broker-dealer’s services, including execution capability, commission rates,
the value of any research, financial responsibility and responsiveness, among other things.

Responsibility
John Riley has the responsibility for the implementation and monitoring of our best execution policy, practices,
disclosures and recordkeeping.

Procedure
CIS has adopted procedures to implement the firm’s policy and reviews to monitor and ensure the firm’s policy is
observed, implemented properly and amended or updated, as appropriate, which include the following: