Code of Ethics

Dale J Bowers...Chief Compliance Officer

June 30, 2021

· Portfolio Management Process - Client portfolios are selected according to each individual client's tolerance for risk. There are three specific and strategic types of client portfolios: growth, blended and conservative. Each portfolio contains a risk level which is evaluated during an in-depth interview and consultation with DJB.

· Accuracy of Disclosures - Clients receive their statements and fund prospectuses directly from the Mutual Fund Investment Company either by hard copy or through 24/7 access to their internet based account. On request, clients are also provided with Form ADV, Part II which is updated on a timely basis in accordance with the Securities and Exchange Commission guidelines.

· Proprietary Trading - DJB has sole trading authority for the WWFM client accounts. Trades within client accounts are always performed on a layered basis with respect to buy/sells. In all cases, client trades are accomplished first before those of DJB for his personal account.

· Safeguarding of Client Assets and Required Records - All client investment assets are placed with custodians at Mutual Fund Institutions or at Mutual Fund Broker-Dealers.

· Information Services - Clients are kept abreast of WWFM's assessment of current market conditions and its approach to meeting those conditions by newsletters accompanying their quarterly statements, as well as through monthly email bulletins.

· Privacy Protection Safeguards - All client records and information are kept secure under lock and key within the offices of WWFM, or on a password-protected computer kept in the personal possession of DJB. Such records pertaining to a terminated client are shredded 7 years from the date of termination of that client.

· Trading Practices - Clients having similar risk tolerance will have their monies invested in identical investments using simultaneous trades. All research and trading decisions will be made by DJB. The clients will be notified immediately of such trades by statements from the institution offering such investments and from WWFM on a quarterly basis. Such trades will be effected by fax transmission with telephone confirmation of any issues encountered while making such trades.

· Marketing Advisory Services - An authorized Investment Advisor Representative is utilized in selling investment services in the business.

· Process to Value Client Holdings and Assess Fees - Client fees are determined according to the net asset value of the mutual funds in their managed accounts at the end of each quarter. These fees are established through the Letter of Agreement signed at our initial consultation.

· Business Continuity Plans - A financial business broker will be contacted to insure that the clients will have an orderly option to continue professional Investment Advisory management services of their assets.