Introduction

This manual sets forth the official compliance policies of Edward Jones. All individuals employed by or working at the firm are required to familiarize themselves with the content and review the manual at least annually.
While the manual addresses policies of a compliance nature, individuals are expected to conform to the laws, rules and regulations of the industry and their particular jurisdiction regardless of whether they are covered in this manual.
Standards of fairness and good business practice apply in all circumstances. Violations of laws, rules, regulations and firm policies can result in disciplinary or regulatory sanctions against an associate, as well as fines or responsibility for consequential losses resulting from the violation.
References to "associate" or "associates" in this manual include general principals and financial advisors unless otherwise specified. Such references also include individuals working both in the home office and in a branch office.
Please do not keep the printed manual as a reference as it will eventually be out-of-date.
Commissions and Sales

Background
FINRA Rule 2121 requires prices and commissions charged to the client be fair and reasonable.
Policy
The firm and vendors with whom it has dealer agreements has either set commission amounts or a range of commissions that may be acceptably charged to a client. Individuals may not make any arrangements with clients outside the parameters set by the firm in its commission policy.
The Field Supervision department may review commissions charged on a transaction as part of the normal supervisory review process to determine if the commissions charged were fair and reasonable based on all relevant factors.
These include but are not limited to:
Reason for the transaction or repositioning
How commissions charged matched intended and actual holding periods
Various other factors
Field Supervision may complete adjustments designed to keep the commissions charged fair and reasonable where:
Long-term investments (bonds, mutual funds, annuities, etc.) are repositioned after a short holding period, or
Commissions charged could be viewed as high based on the holding period.
Client contacts or acknowledgment letters may be requested to document the clients' understanding of the transactions and commissions paid. Commissions on long-term investments, such as bonds and various other investments, are based on expected holding periods.
Field Supervision may determine commissions need to be adjusted even in situations where:
Client profited from the short hold, or
Edward Jones published guidance that prompted the financial advisor to suggest a move to the client
Purpose of Policy
To make sure clients are treated fairly, commissions and sales charges may not be set unreasonably high. The amount or range set by the firm is designed to reflect a fair price charged for executing the transaction given the level of risk to the firm. Continuing Education

Background
NYSE Rule 345A and FINRA Rule 1250 require continuing education for certain registered individuals.
Policy
Associates subject to these rules are required to complete the FINRA Regulatory Element and the firm element courses required of them by the firm. Associates are notified by the Continuing Education department regarding regulatory element and firm element continuing education required to be completed.
Failure to complete the continuing education obligations set out in this policy will result in the firm suspending you from any responsibilities requiring registration until the requirements are met.
Purpose of Policy
The rules of the securities industry are constantly changing. To make sure you stay apprised of these changes, regulators and the industry agreed on continuing education requirements registered individuals must meet.
Contact
Continuing Education or Compliance Registration department Diminished Capacity and Suspected Financial Abuse of Seniors

Background

FINRA Regulatory Notice 07-43 reminds firms of their obligations to senior investors and highlights industry practices to serve these clients.

Policy

If an associate suspects a client is no longer able to understand investment features or concepts to the extent necessary to make decisions on their accounts or if they believe the client may be the victim of financial abuse by a family member, caregiver or other third party, the associate should immediately contact the Field Supervision department.

A review of the situation will be performed to determine if the situation merits further action. Should the review result in continued concerns, actions may include:
Client contacts
Information requests from the branch or other home office departments
Account restrictions
Contacts to local, state or federal agencies
Purpose of Policy
Diminished capacity and suspected financial abuse are issues associates may encounter when dealing with senior clients. Ethics Hotline

Background

The Sarbanes-Oxley Act of 2002 requires the firm to establish formal procedures to receive, keep and address complaints regarding accounting and auditing matters. Section 240.21 of the Securities and Exchange Act of 1934, as amended by Dodd Frank Act of 2010, provides a mechanism for direct reporting to the SEC of any activities which violate any securities laws or regulations in an effort to help address potential fraudulent activities in the securities industry.
Edward Jones is committed to compliance with laws, rules and regulations that govern our business and expects associates to report potential unlawful and/or inappropriate conduct to the firm.

Policy

Associates should contact Compliance Service or Associate Relations to report concerns or information regarding potential unethical, fraudulent or illegal conduct. For possible securities law violations, associates should contact the Whistleblower Line directly. However, if the associate would like to report anonymously, they may contact the Ethics Hotline.

The Ethics Hotline may be used for reports regarding:
Possible fraudulent or illegal conduct
Potential theft
Accounting or financial reporting issues
Possible securities law violations
Conflicts of interest, including those pertaining to financial incentives
Other potential ethical concerns
Callers can remain anonymous; however, all reports are forwarded to Internal Audit for review and, if warranted, forwarded to Associate Relations, Compliance and/or Legal for further investigation. To the extent practicable, the firm will keep confidential all communications with the reporting associate relating to that associate’s reported matter.

The firm prohibits any form of retaliation or unlawful discrimination or taking any adverse action against associates for providing information or otherwise assisting or participating in an investigation regarding any conduct he or she reasonably believes violates regulatory organization rules, federal and/or state laws, and/or firm policies.

Purpose of Policy

The firm is committed to compliance with the laws, rules, and regulations that govern our business, and expects associates to report potential unlawful or inappropriate conduct. The Ethics Hotline is not intended to replace other resources such as the Whistleblower Line, Compliance Service or Associate Relations which the firm has in place to address other issues.

Contact
Whistleblower Line
I
Obligation of Disclosure

Background
FINRA Rule 2010 imposes standards upon members of the securities industry to deal honestly and fairly with clients.
Policy
A financial advisor has a duty to disclose all material information in connection with an investment recommendation. The financial advisor may not fail to disclose or misstate a material fact.
Financial advisors have an obligation to disclose all information which may be reasonably relevant to an investor to take into consideration in making an informed decision, including the various risks and costs involved with the investment or strategy being recommended.
Purpose of Policy
A financial advisor has a duty to be truthful in all communications with clients. Communications should provide a sound basis for evaluating any securities being recommended. nternal Audit
Outside Activities

Background
FINRA Rule 3270 concerns outside activities of associated persons.
Policy
No associate may participate in an outside business activity without prior written approval from the Field Supervision department. An "outside business activity" is defined as:
Engaging in any business activity for another entity
Accepting compensation from any other entity
Being an officer, director, partner, trustee or employee of another entity
Having a financial interest in a securities firm or other similar entity
In addition to the initial approval process, the status of your outside business activities must be reported annually.
Purpose of Policy
Individuals working in the industry are required to put the interest of the client first and put primary emphasis on their employment in the securities industry to the exclusion of other business activities. Individuals are generally prohibited from being employed by more than one financial-service provider at a time. The firm reviews any proposed business activity to identify conflicts of interest and to take steps to eliminate and/or to mitigate certain conflicts of interest where possible.

Trade Secrets

Background
The Uniform Trade Secrets Act forms the basis for this policy.
A "trade secret" is defined by the Uniform Trade Secrets Act as "information, including a formula, pattern, compilation, program, device, method, technique, or process, that:
Derives independent economic value, actual or potential, from not being generally known to, and
Not being readily ascertainable, by proper means, by other persons who can obtain economic value from its disclosure or use, and
Is the subject of efforts that are reasonable under the circumstances to maintain its secrecy"
Policy
Edward D. Jones & Co., L.P. (collectively with its affiliates, "Edward Jones") considers as its trade secrets, ("Trade Secrets"), and intends to keep confidential, everything protected under the Uniform Trade Secrets Act as well as the following:
Computer programs (whether in the form of source code, assembly language, object code, or any other form, including software, firmware, and programmable array logic)
Formulas, algorithms
Methods, techniques, processes
Designs, specifications, diagrams, flow charts
Manuals, descriptions, instructions, explanations, improvements
All ideas, systems, and methods of operation
Information concerning or resulting from research and development work performed by Edward Jones;
Information concerning Edward Jones' management, financial condition, financial operation, purchasing activities, sales activities, marketing activities and business plans, or other activities
Information concerning actual or potential Edward Jones clients, including their identities, contact information, and financial information
All other types and categories of information for which Edward Jones intends or expects secrecy to be maintained and for which the firm has made reasonable efforts to maintain its secrecy
Trade Secrets include both information learned by Edward Jones partners and associates (collectively, "Associates") during their time working for Edward Jones and information developed by Associates in the course of their work for Edward Jones.
By virtue of employment with Edward Jones, or as owner of The Jones Financial Companies, L.L.L.P.,one may be entrusted with or have access to Trade Secret information. Under the law, associates are obligated not to disclose or use, except in their work at Edward Jones, any Trade Secret. This obligation exists both during and after one's employment with Edward Jones and for so long as the Trade Secret is not generally known outside Edward Jones.
Associates may also be advised from time to time as to restrictions upon the use or disclosure of specified information that has been licensed or otherwise disclosed to Edward Jones by third parties per license or confidential disclosure agreements. Such agreements may contain restrictions upon the use or disclosure of such information. Associates must abide by the restrictions upon use and disclosure contained in such agreements.
All documents, encoded media and other tangible items provided by Edward Jones or prepared, generated, or created in connection with any business activity of Edward Jones are the property of Edward Jones.
Upon termination of employment with Edward Jones, one must promptly deliver to Edward Jones all such documents, media and other items in one's possession, including all complete or partial copies, recordings, abstracts, notes or reproductions of any kind made from or about such documents, media, items or information contained therein.
Purpose of Policy
Edward Jones has spent and continues to spend significant resources developing and collecting information required to successfully operate its business. This information is entrusted to Associates.
Certain information is to be kept confidential due to its value to Edward Jones. Failure to keep this information confidential can cause significant harm to Edward Jones, including monetary loss. Unauthorized use or misappropriation of Trade Secrets violates Edward Jones policy, and state and federal law. Whistleblower Line

Background
Section 240.21 of the Securities and Exchange Act of 1934, as amended by the Dodd Frank Act of 2010, provides a mechanism for direct reporting to the SEC of any activities which violate any securities laws or regulations in an effort to help address potential fraudulent activities in the securities industry. Edward Jones is committed to compliance with the laws, rules and regulations that govern our business and expects associates to report potential unlawful and/or inappropriate conduct to the firm.
Policy
Associates should submit reports, concerns, and information regarding potential unethical, fraudulent or illegal conduct, and/or allegations of securities law violations or corporate fraud to the Whistleblower Line or the Ethics Hotline directly at:
Whistleblower Line: 1-855-223-8869
Available M – F 8:30am – 5:30pm
Ethics Hotline: 1-800-620-7395
Available 24 hours a day, 7 days a week
Reports
Reports may be made anonymously to the Ethics Hotline. Associates who choose to identify themselves when submitting a report may be contacted by a firm representative, possibly counsel, in order to gain additional information. To the extent practicable, the firm will keep confidential communications with a reporting associate relating to that associate's complaint.
When submitting a report, associates should provide as much detailed information as possible, including the background and history of the concern, names, dates and places, and the reasons why the situation is cause for concern. This is particularly important where an associate submits a report on an anonymous basis, as the firm will be unable to contact the reporting associate with requests for additional information or clarification.
Anti-Retaliation
The firm prohibits any form of retaliation or unlawful discrimination or taking any adverse action against associates for engaging in the following conduct: (a) providing information or otherwise assisting in an investigation regarding any conduct he or she reasonably believes violates federal or state law or regulations; or (b) filing, testifying, participating in or otherwise assisting in any proceeding relating to any alleged violation of federal or state securities laws or regulations. Examples of retaliation include, but are not limited to, termination, reductions in pay (including bonuses), discipline and demotions. Any associate who believes that he or she has been retaliated against should immediately notify Associate Relations or his or her designated Human Resources Representative. For further details, see the firm's Anti-Retaliation Policy.
Purpose of Policy
The firm is committed to compliance with the laws, rules, and regulations that govern our business, and expects associates to report concerns of potential unlawful conduct to the firm. Our goal is to be able to quickly identify and appropriately address potential violations.

INVESTMENT ADVISER CODE OF ETHICS
Revised 12/12/2011
Page 1 of 4
EDWARD D. JONES & CO., L.P.
INVESTMENT ADVISER
CODE OF ETHICS
Edward Jones is a dually registered broker-dealer and investment adviser. Consistent with its Securities and Exchange Commission (SEC) registration, Edward Jones was required to adopt a code of ethics as part of Rule 204A-1 of the Investment Advisers Act.
This code is intended to help ensure that partners and associates of Edward Jones act in the best interest of its clients. Unless otherwise noted, Section I applies to all Edward
Jones partners and associates. Section II applies specifically to associates who are identified as “access persons” under Rule 204A-1. “Access persons” are associates who may receive material, nonpublic information about orders or portfolio holdings with possible market implications that are connected to an account in which investment advisory services are rendered.
Access persons generally include, but are not limited to, associates who directly provide assistance to one of the firm's investment advisory programs or who have information related to such.
I. CODE OF ETHICS
Securities regulations require members of the industry to adhere to the principles of good business practice and observe high standards of commercial honor and just and equitable principles of trade at all times. All Edward Jones associates are expected to meet the standards of fairness and good business practice in all circumstances. Fair and good business practice includes treating clients fairly, with respect and confirming that all recommendations are made with the best interests of the client as the focus. Requirements under this code include but are not limited to:
A. Using due diligence to learn the essential facts relative to every client. This includes having reasonable grounds for believing that all recommendations are suitable based on information provided by the client regarding other security holdings and his or her financial situation and needs.
B. Clearly and completely explaining all material information in connection with a recommendation to the client. The client is entitled to receive any information, including risks, relevant to making an informed decision.
C. Complying with applicable federal securities laws and the laws, rules and regulations of the industry or other applicable geographic, regulatory or legal entities. INVESTMENT ADVISER CODE OF ETHICS
Revised 12/12/2011
Page 2 of 4
D. All Edward Jones associates are prohibited from using information concerning client accounts for their personal benefit. This includes, but is not limited to portfolio holdings and transactions that are recommended or entered into client accounts. The personal securities transactions of Edward Jones associates must be conducted in a manner consistent with both the letter and spirit of this code, including avoiding any actual or potential conflict of interest or any abuse of the associate’s position of trust and responsibility.
E. All Edward Jones associates are required to promptly report any violation of this code of ethics to the Compliance Resolution Team in the Compliance
Division.
F. Any violation of this code of ethics will be investigated and could result in disciplinary action, including but not limited to reprimand, fines, suspension, termination of employment and the referral of the matter to regulatory or criminal authorities when appropriate.
G. Nothing in this code of ethics diminishes or eliminates the responsibility of
Edward Jones associates to comply with all other firm codes, policies and procedures. Any Edward Jones associate who is considered an “access person” under Rule 204A-1 of the Investment Advisers Act is also required to review and comply with the provisions of
Section II of this code. Edward Jones associates are considered to be “access persons” if, in connection with a client account held through or provided with Edward Jones investment advisory services in some other form, they (a) have access to material nonpublic information that could have market implications regarding the client’s purchase or sale of securities or portfolio holdings or (b) are involved in making securities recommendations to those clients or have access to such recommendations that are nonpublic. Access persons generally include, but are not limited to, associates who directly provide assistance to one of the firm's investment advisory programs or who have information related to such. The Compliance Division has taken steps to identify and contact the “access persons” within the firm. Any associate who has not been contacted and believes he or she may be receiving material nonpublic information should contact the Investment Company and Advisory Compliance Team in the Compliance Division.
Rule 204A-1 requires that a copy of this code of ethics be provided to all Edward Jones associates and that an acknowledgment of their receipt of the code and all amendments be obtained and kept on file. Please acknowledge your receipt of this code by clicking the
“I’ve read this document” button below.
II. SPECIAL REQUIREMENTS FOR “ACCESS PERSONS”
A. Pre-approval of certain investments. Rule 204A-1 requires access persons receive prior approval from the Compliance Division before directly or indirectly acquiring a beneficial ownership interest in any security in an initial
INVESTMENT ADVISER CODE OF ETHICS
Revised 12/12/2011
Page 3 of 4 public offering, limited offering, or hedge fund transaction. Edward Jones associates are barred from participation in IPOs pursuant to FINRA 2790, and the firm does not offer private placements or hedge funds. Pre-clearance approval should be directed to the Capital Markets and Operations Compliance team. B. Reporting requirements. Rule 204A-1 requires all access persons to report current securities holdings and recent securities transactions that meet certain requirements to the Compliance Division. The rule requires the first report to be submitted no later than 10 days after the associate becomes an access person, and the information must be current as of a date no more than 45 days prior to the date the associate becomes an access person. If all applicable accounts and securities are held through Edward Jones, this requirement can be satisfied by notifying the Compliance Division of the accounts in which the access person has a direct or indirect beneficial ownership interest. Accounts held outside
Edward Jones require special approval from the Compliance Division, and a prior approval may be reconsidered based on the reporting requirements in Rule
204A-1. If an access person receives approval for an outside account or holds other securities covered by Rule 204A-1, in certificate or other form outside any account, he or she is required to comply with the following reporting requirements: 1. Holdings reports.
a. Content of holdings reports. Each holdings report must contain, at a minimum: i. The title and type of security, and, as applicable, the exchange ticker symbol or CUSIP number, number of shares, and principal amount of each security in which the access person has direct or indirect beneficial ownership; ii. The name of any broker, dealer or bank with which the access person maintains an account in which securities are held for the access person’s direct or indirect benefit; and iii. The date the access person submits the report.
b. Timing of holdings reports. The access person must submit holdings reports: i. No later than 10 days after the associate becomes an access person, and the information must be current as of a date no more than 45 days prior to the date the associate became an access person.
INVESTMENT ADVISER CODE OF ETHICS
Revised 12/12/2011
Page 4 of 4 ii. At least once each 12-month period thereafter on a date the firm selects, and the information must be current as of a date no more than 45 days prior to the date the report was submitted.
2. Transactions reports. Access persons are required to submit to the
Compliance Department quarterly securities transactions reports that meet the following requirements:
a. Content of transactions reports. Each transactions report must contain, at a minimum, the following information about each transaction involving a security in which the access person had, or as a result of a transaction acquired, any direct or indirect beneficial ownership:
i. The date of the transaction, the title, and, as applicable, the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares, and principal amount of each security involved; ii. The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition); iii. The price of the security at which the transaction was effected; iv. The name of the broker, dealer, bank or other entity with or through which the transaction was effected; and
v. The date the access person submits the report.
b. Timing of transactions reports. The reports must be submitted no later than 30 days after the end of each calendar quarter and must cover, at a minimum, all transactions during the quarter.
c. Exceptions from reporting requirements. An access person does not need to submit a report in the following situations:
i. When securities are held in accounts over which the access person had no direct or indirect influence or control; ii. When transactions are effected pursuant to an automatic investment plan; iii. When the report would duplicate information contained in broker trade confirmations or account statements that Edward Jones already has received or will receive within 30 days of the end of the applicable calendar quarter. Types of Audits
There are 3 types of compliance or regulatory visits a branch can receive:
Edward Jones Compliance audit - conducted by an associate from the Branch Audit department
Edward Jones Field Supervision visit -- conducted by an associate from Field Supervision, usually announced
External audit – likely conducted by a regulator from the state, FINRA, or the SEC
Edward Jones Compliance Audits
Branch audits are conducted annually to fulfill regulatory requirements and to provide education to branch associates. These audits are normally unannounced. For this reason, it may be necessary for a bran