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Code of Ethics

Ronald J. Kruszewski

Letter from Ronald J. Kruszewski, CEO of Stifel

Dear fellow directors, officers, and associates,

At a time in which corporate malfeasance and declining investor sentiment has become more prevalent, it is imperative that firms reiterate the importance of maintaining a commitment to integrity and respect for business ethics. Established in 1890, Stifel has long been a respected member of the St. Louis business community and has since grown to be a leading, investment banking and brokerage firm. The trust our clients, colleagues, regulators, shareholders, and the general public have placed in our firm can be considered our greatest asset, and we must handle this asset with the utmost care.

As a firm, Stifel has adopted a philosophy that can be best described as our "Of Choice" strategy. It is our mission to continue to be the Firm of Choice for our associates, the Advisor of Choice to our clients, and the Investment of Choice to our shareholders. In order to maintain these three, key relationships, we must, as directors, officers, and associates, adhere to a strict code of conduct.

Guidelines for our firm's Code of Conduct are clearly set forth in the Stifel Associate Handbook, which is distributed to each associate upon his or her "new hire" orientation. These guidelines provide each associate with an understanding of how they should conduct themselves on a daily basis and help each associate understand his or her duty, as a representative of Stifel, to preserve the integrity of the firm.

While human error in business is sometimes unavoidable, blatant violation of security laws, regulations, and business ethics will not be tolerated under any circumstances. The laws and regulations of the exchanges in which we have a membership, the Financial Industry Regulatory Authority (FINRA), and any other self-regulating organization must be respected and adhered to at all times.

The guidelines that have been set forth by Stifel cover the general business conduct of our firm. At times, there may be situations or circumstances in which an associate will have questions regarding these policies or procedures. Associates are encouraged to contact their supervisor, Stifel's Compliance Department or General Counsel, or any member of senior management for specific guidance.

At Stifel, we pride ourselves on our dedication to our clients, investors, and associates alike and foster an atmosphere that is built upon honesty, strong principles, and excellence. It is the role of each and every associate of Stifel to take a personal responsibility for their conduct in order to continue the outstanding tradition and commitment that Stifel's founders created.

CEO Signature
Ronald J. Kruszewski
Chairman and Chief Executive Officer