SOCIAL NETWORKING AND BLOGGING POLICY

SMS has adopted this social media policy. Social networking sites, when used for business purposes are considered forms of advertising communication and need proper compliance oversight. Below are the guidelines as to permissible and non-permissible uses of social media. All personnel are required to adhere to the following guidelines.

For purposes of this Social Media Policy, “social media” includes web applications that facilitate information sharing and collaboration such as forums, online social networking sites, blogs, micro-blogs, chat rooms, virtual worlds, online profiles, wikis, podcasts, picture and video, email, instant messaging and Voice over Internet Portocol. Examples of social media applications are LinkedIn, Facebook, Twitter, Instagram, Digg, Reddit, RSS, Wikipedia, YouTube, Yelp, Flickr, Yahoo groups, Google Plus, WordPress and Zoominfo.

At this time, SMS only permits associates to use approved social media sites for business purposes if approved by Compliance.

Personal Social Media Pages

All associates must disclose the social media sites used for personal reasons and document that you understand the approved guidelines. The firm may periodically check to confirm appropriate use related to the business guidelines below:

If you maintain any personal social media pages, you are subject to a few guidelines on usage related your position at SMS.

When using social media for personal uses, you may:

• Include SMS’s name and position as approved on your business card.

• Include company contact information as approved on your business card.

• Include a description of your job function as a part of your profile only if pre-approved through Compliance. See marketing for specific approved language or to create your own approved custom description.• Choosing to include a description will require appropriate disclosures

• Choose to comment related to SMS in a purely fun, social manner such as posting pictures at an event, sharing an upcoming event, etc.

When using social media for personal uses, you cannot:

• Discuss securities-related business.

• Outline or promote products or services offered by the firm, either in general or specific terms.

• Communicate with any current or prospective clients relative to business-related matters.

• Use the firm’s name to promote business or solicit clients or business.

• Disclose trade secrets.

• Allow social networking to interfere with your job duties.

• Use any of the logos or trademarks of the firm.

• Engage in discussions with any of the firm’s competitors, clients or vendors. Compliance Manual 11.2017 63

When using social media for personal use, you are required to:

• Follow the Code of Ethics and Compliance Manual at all items.

• Be personally responsible for any content that you post.

LinkedIn specifics:

Since the purpose of LinkedIn is considered business-related in any circumstance, there are specific guidelines for this network that must be adhered to:

• You should connect with SMS

• Your profile should be pre-approved as it is considered static content and may include approved business card information – but must be on file with Compliance

• LinkedIn recommendations specific to your work at SMS or any other related industry are not allowed, and need to be hidden on your profile.

• Adding skills to your profile is acceptable, but must be approved in advance.

• LinkedIn skills endorsements related to your work at SMS or industry related are not allowed and need to be hidden on your profile.

SMS has the right to view public information on associate’s pages at any time. Please keep in mind when setting up and maintaining your personal page that you are a reflection of SMS.

SMS IARs, employees and staff are never allowed to use social media communication tools for communicating in business-related conversation unless the conversations can be monitored/archived. This includes, but is not limited to, Facebook chat/messaging, wall posts, LinkedIn and Twitter messaging. All SMS IARs, employees and staff are not permitted to exchange communication via social media portals. If an IAR, employee or staff member happens to receive a social media message/communication, you may only reply with your approved email or work number.

Related to the above, the CCO is responsible for monitoring all social media to remove endorsements as appropriate. As stated above, this includes LinkedIn skills endorsements related to your work at SMS and those need to be hidden on LinkedIn profiles. Facebook endorsements (posts on walls, pages, etc.) will also be monitored and removed by the CCO. The only current situation where this does not apply is responses to posts on Twitter, as the recipients of a comment (including likes, favorites, retweets, etc.) do not have any control over said comments and they are unable to be removed by anyone other than the person posting the comment. The CCO is responsible for monitoring and reporting these instances, even though no action can be taken to remove them.

Use of Business Social Media Pages

All licensed associates are prohibited from engaging in business communications using a social media site that is not subject to the firm’s supervision and only those associated persons who have received appropriate training on our firm’s policies and procedures regarding interactive electronic communications may engage in such communications.

Associates are not permitted to establish or participate in an industry-related blog or any other form of interactive communication except to the extent that Compliance has pre-approved such activity and has reviewed and pre-approved any static or interactive information to be posted thereon. Compliance Manual 11.2017 64

In addition, all interactive electronic communications that recommend a specific investment product and any link to such a recommendation are expressly prohibited unless it complies with the specific rules outlined in the Advisers Act and are approved in advance by Compliance.

To comply with SEC regulations, associates requesting the use of social media for business purposes agree to have their pages monitored by Compliance and through our third-party monitoring company.

A business social media page, when used properly, allows you to:

• Communicate with clients on new business – related information via posts

• Share articles, blogs, stories relative to the firm and the financial market

• Like and share information from other clients and friends

• Promote upcoming firm events.

When using social media for business you must use only firm approved email and contact information, and you must at all times;

a) Comply with principles of fair dealing and good faith in communications with the public;

b) Make only statements that have a sound basis in fact;

c) Refrain from making false, exaggerated or misleading statements; and

d) Ensure that statements do not predict or project future performance, discuss the firm’s past performance, or provide investment-related advice.

All LinkedIn usage guidelines described above still pertain with business profiles.

Compliance Manual 11.2017