CODE OF ETHICS

Meridian Wealth Management Code of Ethics

In an effort to ensure that Meridian Wealth Management (“Meridian”) maintains a reputation for integrity and high ethical standards, it is important that Meridian and its supervised persons comply with federal securities laws and also maintain high standards of personal and professional conduct. This Code of Ethics (the “Code”) is designed to help ensure that Meridian conducts its business consistent with these high standards.

Covered Individuals

All Meridian advisory representatives and employees (“Supervised Persons”) are covered by the Code and are required to acknowledge receipt of a copy of the Code in writing, as well as any amendments that may be provided in the future. It is the responsibilities of all Supervised Persons to read, understand and comply with the requirements of the Code. Failure to comply with the Code may result in disciplinary action, including termination of employment.

Standards of Business Conduct

Fiduciary Duty. As a fiduciary, Meridian has an affirmative duty of care, loyalty, honesty, and good faith to act in the best interests of its clients. This includes the obligation to place the interests of clients ahead of its own. Meridian requires that Supervised Persons place client transactions ahead of any transactions for the account of a Supervised Person. Meridian requires all Supervised Persons to conduct business in an ethical fashion.

Conflict of Interest. Supervised Persons should fully disclose all material facts concerning any conflicts of interest that does arise.

Standards of Conduct. All Supervised Persons must comply with all federal securities laws. Supervised Persons are not permitted, in connection with the purchase or sale, directly or indirectly, of a security held or to be acquired by a client:

• To defraud such client in any manner
• To mislead a client, including by making a statement that omits material facts To engage in any act, practice or course of conduct, which operates or would operate as a fraud or deceit on a client
• To engage in any manipulative practice with respect to such client
• To engage in any manipulative practice with respect to securities, including price manipulation

Insider Trading. Supervised Persons are prohibited from trading a security, either personally or on behalf of others, while in possession of material, non-public information about the security. Additionally, Supervised Persons are prohibited from communicating, sharing, or tipping such material, non-public information to others. Material information includes any information that a reasonable investor would consider in making an investment decision. Non-public information is information that has not been disseminated in a manner that would make it generally available to investors. A Supervised Person that believes he/she or a client may be in possession of material, non-public information, should immediately contact Meridian’s Chief Compliance Officer.

Confidentiality. Information concerning the security holdings and financial circumstances of clients, among other items, is confidential. All information about clients must be kept in strict confidence. Supervised Persons are prohibited from disclosing any information about any client, the investments made by Meridian on behalf of any client, information regarding Meridian’s trading strategies, except as required to provide services to client or for other legitimate business purposes. Please refer to Meridian’s Privacy Policy for additional information regarding safeguarding of confidential information.

Gifts and Entertainment. A Supervised Person may not accept inappropriate gifts, favors, entertainment, or other things of value that could influence decision-making or make the Supervised Person feel beholden to the person or firm. Similarly, Supervised Persons may not offer gifts, favors, entertainment or other things of value that could be viewed as overly generous or aimed at influencing decision-making or making a client feel beholden to Meridian or the Supervised Person.

Transaction Reporting and Holding Reports

Meridian permits Supervised Persons to maintain personal securities accounts or holdings at either LPL Financial (“LPL”) or another financial institution. Holdings include those securities in which the Supervised Person has any direct or indirect beneficial ownership. A Supervised Person is considered to be the beneficial owner of an account in which he/she has any financial interest or ability to exercise control and of any account belonging to immediate family members sharing the Supervised Persons household.

Meridian requires that each Supervised Person provide the following documents to Meridian for review:

• Duplicate copies of all account statements for accounts held at financial institutions other than LPL submitted directly to Meridian by the financial institution.
• For advisory representatives of Meridian that are securities registered with LPL, a copy of the form provided to LPL reporting accounts held at financial institutions other than LPL.
• Copies of statements for accounts of new hires are collected within ten days of the individual joining Meridian.

Transaction reporting and holding reports will be reviewed by Meridian’s Chief Compliance Officer or his designee on a periodic basis.

Education

Meridian provides initial and periodic education about the Code of Ethics, insider trading policy, and each person’s responsibilities and reporting requirements, under the Code.

Annual Certification

Each Supervised Person must acknowledge understanding and compliance with Meridian’s Code on an annual basis via execution of a certification. In addition, the certification requires confirmation that all personal securities accounts have been disclosed to Meridian.

Reporting Violations

Any violations of the Code or any instances of non-compliance with the Code must be immediately brought to the attention of Meridian’s Chief Compliance Officer.

Recordkeeping

Meridian retains relevant Code records as required, including but not limited to, copies of the Code as amended from time to time, acknowledgement or certification forms, initial and annual holdings reports, quarterly reports of personal securities transactions, violations and sanctions, among others.

November 2017