Mark Clemons & Raymond R. Fletcher
and MonteClare, LLC

1. Purpose: This Code of Conduct sets forth the principles and standards that govern the professional behavior of Mark Clemons and Raymond R. (Bob) Fletcher, Private Trustees, individually, and MonteClare, LLC’s, employees, officers and directors. Our commitment is to act with integrity, transparency and fairness in all business activities and to uphold the trust placed in us by clients, beneficiaries and the public.

2. Core Principles

 Fiduciary Duty: When conducting fiduciary activities, always act in the best interest of clients and beneficiaries, placing their interests above personal gain.

 Integrity: Conduct business honestly and ethically, avoiding conflicts of interest and maintaining full transparency.

 Confidentiality: Safeguard client information and use it solely for authorized purposes.

 Compliance: Adhere strictly to all applicable laws, regulations, policies and in accordance with standards of sound business principles.

 Professionalism: Maintain the highest standards of competence, courtesy and respect in all interactions.


3. Conflicts of Interest: Avoid situations where personal interests may conflict with the interests of clients or the business.

4. Gifts and Entertainment: Personnel shall not accept gifts, entertainment or other benefits that could influence, or appear to influence, their decision-making. All gifts must be reported and approved in accordance with acceptable guidelines.

5. Confidential Information: Access to confidential information is restricted to personnel with a legitimate business need. Unauthorized disclosure, reproduction or use of such information is strictly prohibited.

6. Fair Dealing and Communication: All client communications must be clear, truthful and not misleading.

7. Reporting and Accountability: Personnel are encouraged to report ethical concerns, suspected violations of this code or illegal activities. Retaliation against whistleblowers is strictly prohibited. Violations may result in disciplinary action, up to and including termination.

8. Acknowledgment: All personnel must annually acknowledge their understanding and commitment to uphold this Code of Conduct.

Effective Date: June 1, 2025 

Mark Clemons, Private Trustee
Raymond. R. Fletcher, Private Trustee
Shara L. Fletcher, Director of Operations, MonteClare, LLC