Changes to the Compton Advisors, LLC Code of Conduct

The Compton Advisors, LLC Code of Conduct has been reviewed and revised effective March 5, 2017. It has been materially changed as follows:

Covered persons may now trade options, except those on single companies, without posting 24 hour notice.

It is often difficult to specify that far in advance which specific contracts in an option chain will be priced attractively as the option prices are highly sensitive to price and volatility changes in the underlying indexes.

Positions in these options are still to be reported as required in the quarterly transactions and annual holdings.

Planned transactions for options on individual companies must still give 24 hour notice.

The revised Code of Conduct is available on request and current clients will see it with their 1st quarter bills.