Welcome to Ellwood Associates - No Conflicts of Interest Policy

Under the Investment Advisers Act of 1940 (Advisers Act), an investment adviser providing consulting services has a fiduciary duty to provide disinterested advice and disclose any material conflicts of interest to their clients. In this context, SEC staff examined the practices of advisers that provide pension consulting services to plan sponsors and trustees. The SEC examination staff concluded in its report released in May, 2005 that the business alliances among pension consultants and money managers can give rise to serious potential conflicts of interest under the Advisers Act that need to be monitored and disclosed to plan fiduciaries. In light of this, Ellwood Associates has undertaken to formalize its long standing policy of no conflicts of interest.

Policy

The purpose of this policy is to avoid conflicts of interest as we fulfill our obligation to our clients to provide unbiased independent advice. Ellwood Associates has always conducted its consulting practice without any conflicts of interest. Throughout the firm’s history, we have been steadfast in our refusal to enter into any relationship or service arrangement that would compromise our independence or objectivity. Our firm does not offer brokerage or money management services and we do not have any alliances or financial affiliations with money managers or other service providers. We do not receive any fees from money managers, investment funds, brokerage services or other service providers.

Our firm is registered with the SEC as an Investment Advisor. We do not sell products or services other than our investment advice to clients, as disclosed in our Form ADV Part II. We are an independent firm and do not have any affiliates who engage in the business of investment advisory services.

Responsibility

Susan B. Toth, President & Chief Compliance Officer who reports directly to Russell W. Hill, Chairman & Chief Executive Officer, has the responsibility for implementing and monitoring our Conflicts of Interest Policy.

Procedure

Ellwood Associates has adopted procedures to implement the firm's Conflicts of Interest Policy and reviews to monitor and insure the firm's policy is observed, implemented properly and amended or updated, as appropriate. To avoid conflicts of interest, Ellwood Associates has adopted the following procedures:

We do not offer products, research, or services to money managers. (For example selling data or software to money managers, sponsoring conferences that are subsidized by money managers or charging money managers to be included in our research database.)
We do not receive any direct or indirect compensation from money managers (For example, we do not receive referral fees from money managers we recommend, consider for recommendation, or otherwise mention to our clients for consideration.)
We do not have any arrangements with any broker-dealers under which our firm will benefit if money managers place trades for their clients with such broker-dealers.
We do not manage any commingled pools of capital.
Our firm and its employees do not accept gifts, tickets or meals from any service providers.



History No Conflicts of Interest Policy Organizational Structure Professional Biographies		Under the Investment Advisers Act of 1940 (Advisers Act), an investment adviser providing consulting services has a fiduciary duty to provide disinterested advice and disclose any material conflicts of interest to their clients. In this context, SEC staff examined the practices of advisers that provide pension consulting services to plan sponsors and trustees. The SEC examination staff concluded in its report released in May, 2005 that the business alliances among pension consultants and money managers can give rise to serious potential conflicts of interest under the Advisers Act that need to be monitored and disclosed to plan fiduciaries. In light of this, Ellwood Associates has undertaken to formalize its long standing policy of no conflicts of interest. Policy The purpose of this policy is to avoid conflicts of interest as we fulfill our obligation to our clients to provide unbiased independent advice. Ellwood Associates has always conducted its consulting practice without any conflicts of interest. Throughout the firm’s history, we have been steadfast in our refusal to enter into any relationship or service arrangement that would compromise our independence or objectivity. Our firm does not offer brokerage or money management services and we do not have any alliances or financial affiliations with money managers or other service providers. We do not receive any fees from money managers, investment funds, brokerage services or other service providers. Our firm is registered with the SEC as an Investment Advisor. We do not sell products or services other than our investment advice to clients, as disclosed in our Form ADV Part II. We are an independent firm and do not have any affiliates who engage in the business of investment advisory services. Responsibility Susan B. Toth, President & Chief Compliance Officer who reports directly to Russell W. Hill, Chairman & Chief Executive Officer, has the responsibility for implementing and monitoring our Conflicts of Interest Policy. Procedure Ellwood Associates has adopted procedures to implement the firm's Conflicts of Interest Policy and reviews to monitor and insure the firm's policy is observed, implemented properly and amended or updated, as appropriate. To avoid conflicts of interest, Ellwood Associates has adopted the following procedures: We do not offer products, research, or services to money managers. (For example selling data or software to money managers, sponsoring conferences that are subsidized by money managers or charging money managers to be included in our research database.) We do not receive any direct or indirect compensation from money managers (For example, we do not receive referral fees from money managers we recommend, consider for recommendation, or otherwise mention to our clients for consideration.) We do not have any arrangements with any broker-dealers under which our firm will benefit if money managers place trades for their clients with such broker-dealers. We do not manage any commingled pools of capital. Our firm and its employees do not accept gifts, tickets or meals from any service providers.