Polero ICE Advisers, L.L.C.

Personal Financial Advisory and Planning Services

Business Philosophy

Clients of Polero ICE Advisers will always receive straightforward answers, and will be provided with relevant information in a clear and professional manner. Clients can expect to receive comprehensive financial assistance that is tailor-made to their specific needs, and can be certain that their interests will always be considered first. All business will be conducted with the highest integrity and with full transparency.

The Adviser believes that too many individuals are taken advantage of by high-pressured, overly-aggressive salespeople and professionals who do not act as true fiduciaries when dealing with clients. Instead of offering the best advice for a particular client, more expensive, sub-optimal solutions are often provided. This type of poor service can have long-term, highly detrimental effects on an individual's wealth.

Minimizing the costs of investing is critical to everyone’s financial health. It is important that we avoid the fee-laden, overly-complex products often pushed or selected by brokers and investment firms for their clients' accounts. Often, a broker has an economic incentive to get our money into funds with hard-to-identify fees that can add up to over 3% annually. This is money that comes directly out of our pockets each year -- money that will not be there when we need it for our retirement and other important goals.

Continuously paying high fees to have our money actively traded, is very likely to result in significantly less wealth accumulation than if we invest in a well-diversified, low-cost portfolio. Polero ICE Advisers can assist you in designing such a portfolio, and any fee that the Firm earns will be completely transparent to you.

Listening to your financial concerns and understanding both your short and long-term objectives is a crucial first step in formulating your financial plan. Your individual situation is unique, and many factors need to be considered when deciding what products and services are best for you.

Working closely with you, the Adviser can provide you with the peace of mind that comes from having a sound strategy to achieve your investment and estate planning goals.


Real Fiduciary™ Practices: Professional Conduct Guidance for Advisors

Polero ICE Advisers commits to a high code of professional conduct. As part of that commitment, the Adviser subscribes to The Institute of the Fiduciary Standard's Real Fiduciary™ Practices. An explanation of these Practices is provided below:

The Institute for the Fiduciary Standard’s Real Fiduciary™ Practices describe how conscientious and competent advisors serve clients today. They reflect principles that underlie fiduciary law and focus on the three overriding advisory duties of Loyalty, Due Care and Utmost Good Faith.

DEMONSTRATE LOYALTY

1. Act as a fiduciary at all times. Affirm this commitment to the client in writing.

2. Decline any sales-related compensation.

3. Avoid conflicts of interest.

4. Mitigate unavoidable conflicts.

ACT WITH DUE CARE

5. Maintain professional knowledge and competence.

6. Explain agreements and disclosures clearly and truthfully, both orally and in writing.

7. Establish and document a reasonable basis for advice.

8. Follow and document a prudent due diligence process for rendering investment advice.

ACT IN UTMOST GOOD FAITH

9. Decline gifts or entertainment or other benefits unless minimal in value, occasional in frequency, and consistent with your firm's gift and vendor relation policies.

10. Charge reasonable fees and incur reasonable investment costs. Disclose and fully explain.

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