Elements 5 Investment Management is included in the First Class Registry of Best Practices Advisors A link to the firm’s listing can be found here. The Institute for the Fiduciary Standard’s Best Practices, a professional code of conduct for fiduciary advisors, outlines what advisors agree to do for clients. Each Best Practice is listed below and the requirements of each practice is in italics. These are the specific actions that aim to uphold a high standard. A firm subscribing to Best Practices affirms with these actions, that:

1. Affirm the fiduciary standard under the Advisers Act of 1940, common law and, if applicable, ERISA and DOL’s COI Rule, govern all professional advisory client relationships at all times. Fiduciary status, as required in law, applies at all times in all client engagements and this affirmation is stated in writing.
2. Establish and document a “reasonable basis” for advice in the best interest of the client. Advice is given on a “reasonable basis” and a summary of this “reasonable basis” will be provided by your advisor in writing upon request.
3. Communicate clearly and truthfully, both orally and in writing. Do not mislead. Make all disclosures and important agreements in writing. All important client agreements and disclosures are put in writing and that no written or verbal statements are misleading.
4. Provide a written statement of total fees and underlying investment expenses paid by the client. Include any payments to the advisor or the firm or related parties from any third party resulting from the advisor’s recommendations. Elements 5 provides a good faith estimate of fees and expenses in writing during the starting phase of the engagement when the investment policy is agreed to. Thereafter, Elements 5 will offer to all clients and will provide, upon request, an annual good faith estimate in writing of total fees and expenses incurred by each client and paid to the firm or related parties because of the advice.
5. Avoid conflicts and potential conflicts. Disclose all unavoidable potential and actual conflicts. Manage or mitigate material conflicts. Acknowledge that material conflicts of interest are incompatible with objective advice. Elements 5 seeks to avoid conflicts of interest. For unavoidable conflicts, Elements 5 shall (i) affirmatively disclose the conflict with ‘sufficiently specific facts’ to allow client understanding, and (ii) manage the conflict to preserve the client’s best interests. For material conflicts, Elements 5 shall obtain informed written consent from the client. Elements 5 affirms that transactions will remain consistent with the client’s best interests. Further, Elements 5 provides clients and prospective clients a written description of conflicts and steps to manage them.
6. Abstain from principal trading unless a client initiates an order to purchase the security on an unsolicited basis. Elements 5 abstains from principal trading – unless specifically requested by a client without your advisor’s urgings.
7. Accept compensation only in the form of fees paid directly by clients. Avoid compensation in association with client transactions. All payments to Elements 5 and its advisors that are associated with product sales are disallowed. Elements 5 does not receive compensation in association with a client transaction.
8. Avoid gifts or entertainment that are not minimal and not occasional. Avoid third party payments, “benefits”, and indirect payments that do not generally benefit the firm’s clients and may reasonably be perceived to impair objectivity. Any gifts and entertainment received by Elements 5 are minimal and occasional. Any third party compensation or benefits received by the firm generally benefit the firm’s clients and do not impair your advisor’s objectivity. The firm’s complete policy on gifts and entertainment and “soft dollars” is available on request.
9. Ensure baseline knowledge, competence and ongoing education appropriate for the engagement. Your advisor’s education, professional certifications and ongoing education are appropriate for the engagement and, at minimum, include an undergraduate degree and either a relevant post graduate education or a specialized designation or certification requiring significant additional education.
10. Institute an investment policy statement (IPS) or an investment policy process (IPP) that is appropriate to the engagement and describes the investment strategy. Have access to a representative universe of investment vehicles that provide ample options to meet the desired asset allocation in consideration of generally accepted criteria. An IPS, which documents the client’s financial objectives, risk tolerance and economic/market assumptions, is developed and furnished in writing to each investment management client. Elements 5 follows and documents a prudent process of due diligence to research and analyze investment vehicles. On request, document the prudent process applicable to any recommendation and the investment program is implemented consistent with the IPS or IPP.
11. Consider peer group rankings or apply specific procedures in ensuring underlying investment expenses are reasonable. Elements 5 benchmarks the fees and costs its clients incur with reliable services or surveys or other resources and/or has procedures to determine that client expenses are reasonable.

Affirm in writing that the advisor adheres to and shall meet these Best Practices. Elements 5 advisors affirm that they adhere to these Best Practices and that no firm policy interferes with this adherence.