Disclosures

Maryland Capital Management (MCM) has adopted a Code of Ethics in accordance with rule 204A-1 of the Investment Advisors Act of 1940. MCM has adopted this Code for all supervised persons to promote the highest standard of ethical conduct among our employees and a culture of compliance. The Code sets forth our standards of business conduct as a fiduciary and specifically requires that employees comply with Federal Securities Laws.

The Code of Ethics includes provisions relating to personal trading and other securities related conduct of MCM employees as well as written policies and procedures governing the conduct of all advisers, employees and access persons of MCM. Under these procedures, any employee trades (including ETFs) are placed in a master account and allocated at the close of trading day. This ensures that all of our clients and/or access persons that trade in a security for that day receive the same average price.

MCM personnel must pre-clear all trades for personal securities accounts with the Chief Compliance Officer (or a designated senior trading person) except for trades with respect to U.S. government securities or open-ended mutual funds. Pre-clearance is valid on the day with which it is granted. Limitations also exist for participation in initial public offerings and private placements.

All of our personnel submit a quarterly personal securities transaction report to the Chief Compliance Officer due no later than 30 days after the end of the calendar quarter. The quarterly security transaction report details all transactions in covered securities in which MCM personnel have direct or indirect beneficial interest. Employees also prepare an annual statement of holdings for review by the Chief Compliance Officer.

*Investing in securities involves risk of loss that clients should be prepared to bear. The various types of securities that MCM purchases on behalf of clients (common stocks, preferred stocks, municipal bonds, corporate bonds, government bonds, exchange traded funds (ETFs), Master Limited Partnerships (MLPs), Real Estate Investment Trusts (REITs), mutual funds (including money market funds), carry some degree of market risk. Any security has the ability to decline in value.

*Not meant as recommendation to buy or sell.

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