|

The Board of Directors of Grandview Capital Inc.(GCI),
together with its affiliates, has adopted the following Code of
Ethics. The Code applies to all Financial Professionals employed by
GCI and is enforced with the intention of ensuring a continuous
level of integrity within the company’s financial reporting and
transactions. "Financial
Professional" means any professional employee in the area of finance
(including core and business finance, accounting, and financial
reporting), corporate audit, corporate risk management, corporate
tax, investor relations or treasury, and also includes the Chief
Executive Officer ("CEO"), Chief Financial Officer ("CFO"),
Controller, and any member of Executive Management who has similar
operating or oversight responsibilities regardless of such person's
designated title.
The Company's Guidelines for Business Conduct: Grandview Capital
Inc. Code of Ethics for Directors, Officers and Employees, sets
forth the fundamental principles and key policies and procedures
that govern the conduct of all of the Company's directors, officers
and employees. Financial Professionals are required to conduct their
personal and professional affairs in a manner that is consistent
with the ethical and professional standards set forth in the FINRA
Guidelines for Business Conduct, as well as this supplemental Code
of Ethics.
Financial
Professionals shall facilitate the work of the Company's independent
public auditors and shall not, directly or indirectly, take any action
to fraudulently influence, coerce, manipulate or mislead Grandview
Capital Inc. independent public auditors.
Each Financial Professional is accountable for his or her adherence to
this Code of Ethics and the Company's policies. Any violation of this
Code of Ethics may result in disciplinary action, including immediate
termination.
Any Financial Professional who believes, in the exercise of reasonable
judgment after a review of the facts, that a violation of this Code of
Ethics has occurred shall promptly report such violation to the Chief
Compliance Officer.
Grandview Capital Inc. policy prohibits retaliation against an employee
who reports a violation of this Code of Ethics in good faith. As
provided by law, Grandview Capital Inc. is not permitted to fire,
demote, suspend, harass or discriminate against an employee in
retaliation for such employee providing information to, or otherwise
assisting or participating in, any investigation or proceeding by a
regulatory or law enforcement agency, or by the Company, relating to
what the employee reasonably believes is a violation of the securities
laws, an act of fraud or a violation of any wage or discrimination laws.
No Grandview Capital Inc. director, officer, employee or representative
is permitted to take any such retaliatory action.All Grandview Capital
Financial Professionals must:
-
Engage in and promote honest
and ethical conduct, including the ethical handling of actual or
apparent conflicts of interest between personal and professional
relationships;
-
Take all reasonable measures to
protect the confidentiality of non-public information about
Grandview Capital Inc. or any subsidiary and Grandview Capital Inc.
customers obtained or developed in connection with their activities,
and to prevent the unauthorized disclosure of such information
unless required by applicable law or regulation or legal or
regulatory process;
-
Produce full, fair,
accurate, timely and understandable disclosure, in compliance with
applicable accounting standards, in reports and documents that
Grandview Capital Inc. or any subsidiary files with, or submits to,
any applicable regulatory body and in other public communications
made by Grandview Capital Inc. or any subsidiary;
-
Act in good faith,
responsibly, with due care, competence, prudence and diligence,
without misrepresenting material facts or allowing one's independent
judgment or decisions to be subordinated;
-
Comply with governmental laws
and FINRA Rule 2110. Standard of Commercial Honor and Principles of
Trade; and
-
Promptly bring to the attention
of senior management any information he or she may have concerning (i)
significant or material deficiencies or weaknesses in the design or
operation of the Company's internal controls, (ii) any fraud,
whether or not material, or any actual or apparent conflict of
interest between personal and professional relationships, involving
any member of management or other employee who has a significant
role in the Company's financial reporting, disclosures or internal
controls, or (iii) any other matters which could have a material
adverse effect on the Company's ability to record, process,
summarize and report financial data.
|