Exhibit (p)(17)

Code of Ethics

General

The Code of Ethics is predicated on the principle that SUMMIT GLOBAL INVESTMENTS, LLC owes a fiduciary duty to its clients. Accordingly, SUMMIT GLOBAL INVESTMENTS, LLC’s Employees must avoid activities, interests and relationships that run contrary (or appear to run contrary) to the best interests of clients. At all times, SUMMIT GLOBAL INVESTMENTS, LLC must:

· Place client interests ahead of SUMMIT GLOBAL INVESTMENTS, LLC’s — As a fiduciary, SUMMIT GLOBAL INVESTMENTS, LLC must serve in its clients’ best interests. In other words, SUMMIT GLOBAL INVESTMENTS, LLC Employees may not benefit at the expense of advisory clients. This concept is particularly relevant when Employees are making personal investments in securities traded by advisory clients.

· Engage in personal investing that is in full compliance with SUMMIT GLOBAL INVESTMENTS, LLC’s Code of Ethics — Employees must review and abide by SUMMIT GLOBAL INVESTMENTS, LLC’s Personal Securities Transaction and Insider Trading Policies.

· Avoid taking advantage of your position — Employees must not accept investment opportunities, gifts or other gratuities from individuals seeking to conduct business with SUMMIT GLOBAL INVESTMENTS, LLC, or on behalf of an advisory client, unless in compliance with the Gift Policy below.

· Maintain full compliance with the Federal Securities Laws(1) — Employees must abide by the standards set forth in Rule 204A-1 under the Advisers Act [17j-1] and Rule 17j-1 under the Investment Company Act of 1940.

Any questions with respect to SUMMIT GLOBAL INVESTMENTS, LLC’s Code of Ethics should be directed to the CCO. As discussed in greater detail below, Employees must promptly report any violations of the Code of Ethics to the CCO. All reported Code of Ethics violations will be treated as being made on an anonymous basis.

Guiding Principles & Standards of Conduct

All Employees of SUMMIT GLOBAL INVESTMENTS, LLC, and consultants closely associated with the Company, will act with competence, dignity and integrity, in an ethical manner, when dealing with clients, the public, prospects, third-party service providers and fellow Employees. The following set of principles frame the professional and ethical conduct that SUMMIT GLOBAL INVESTMENTS, LLC expects from its Employees and consultants:

(1) “Federal securities laws” means the Securities Act of 1933, the Securities Exchange Act of 1934, the Sarbanes-Oxley Act of 2002, the Investment Company Act of 1940, the Investment Advisers Act of 1940, Title V of the Gramm-Leach-Bliley Act, any rules adopted by the Commission under any of these statutes, the Bank Secrecy Act as it applies to funds and investment advisers, and any rules adopted thereunder by the Commission or the Department of the Treasury.

· Act with integrity, competence, diligence, respect, and in an ethical manner with the public, clients, prospective clients, employers, Employees, colleagues in the investment profession, and other participants in the global capital markets;

· Place the integrity of the investment profession, the interests of clients, and the interests of SUMMIT GLOBAL INVESTMENTS, LLC above one’s own personal interests;

· Adhere to the fundamental standard that you should not take inappropriate advantage of your position;

· Avoid any actual or potential conflict of interest;

· Conduct all personal securities transactions in a manner consistent with this policy;

· Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities;

· Practice and encourage others to practice in a professional and ethical manner that will reflect favorably on you and the profession;

· Promote the integrity of, and uphold the rules governing, capital markets;

· Maintain and improve your professional competence and strive to maintain and improve the competence of other investment professionals.

· Comply with applicable provisions of the federal securities laws.

SUMMIT GLOBAL INVESTMENTS, LLC HAS ZERO TOLERANCE FOR RETALIATORY ACTIONS AND THEREFORE MAY SUBJECT OFFENDERS TO MORE SEVERE ACTION THAN SET FORTH IN THIS CODE OF ETHICS. IN ORDER TO MINIMIZE THE POTENTIAL FOR SUCH BEHAVIOR, ALL REPORTS OF CODE OF ETHICS VIOLATIONS WILL BE TREATED AS BEING MADE ON AN ANONYMOUS BASIS.

1. Personal Security Transaction Policy

Employees may not purchase or sell any security in which the Employee has a beneficial ownership unless the transaction occurs in an exempted security or the Employee has complied with the Personal Security Transaction Policy set forth below.

Pre-Clearance Procedures

SUMMIT GLOBAL INVESTMENTS, LLC’s Employees must have written clearance for all personal securities transactions before completing the transactions. SUMMIT GLOBAL INVESTMENTS, LLC reserves the right to disapprove any proposed transaction that may have the appearance of improper conduct.

Generally, Employees shall complete SUMMIT GLOBAL INVESTMENTS, LLC’s Pre-Clearance Form (See Attachment A) or may request pre-clearance via email. All pre-clearance requests must be submitted to SUMMIT GLOBAL INVESTMENTS, LLC’s CCO or someone so designated by the CCO with the CCO’s oversight. Once pre-clearance is granted to an Employee, such Employee may only transact in that security for the remainder of the day. If the Employee wishes to transact in that security on the following or any other day, they must again obtain pre-clearance from the CCO. Unless otherwise noted, no pre-clearance is required for the exempted transactions noted below.

Reportable and Exempt Securities

SUMMIT GLOBAL INVESTMENTS, LLC requires Employees to provide periodic reports (See Reporting section below) regarding transactions and holdings in any security, as that term is defined in Section 202(a)(18) of the Advisers Act (“Reportable Security”), except that it does not Include:

· Direct obligations of the Government of the United States;

· Bankers’ acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, Including repurchase agreements;

· Shares issued by money market funds;

· Shares issued by open-end funds other than Reportable Funds(2); and

· Shares issued by unit investment trusts that are invested exclusively in one or more open-end funds, none of which are Reportable Funds.

Commodities, futures and options traded on a commodities exchange, Including currency futures are not considered securities. However, futures and options on any group or index of securities shall be considered securities.

PLEASE NOTE, SUCH EXEMPTION DOES NOT APPLY TO SHARES OF OPEN-END MUTUAL FUNDS THAT ARE ADVISED BY SUMMIT GLOBAL INVESTMENTS, LLC (OR AN AFFILIATE) OR ARE OTHERWISE AFFILIATED WITH SUMMIT GLOBAL INVESTMENTS, LLC (OR AN AFFILIATE)(“REPORTABLE FUNDS”). MORE SPECIFICALLY, EMPLOYEES MUST PRE-CLEAR AND REPORT ANY PERSONAL TRANSACTION IN A REPORTABLE FUND.

Beneficial Ownership

Employees are considered to have beneficial ownership of securities if they have or share a direct or indirect pecuniary interest in the securities. Employees have a pecuniary interest in securities if they have the ability to directly or indirectly profit from a securities transaction.

The following are examples of indirect pecuniary interests in securities:

· Securities held by members of Employees’ immediate family sharing the same household. Immediate family means any child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law or sister-in-law. Adoptive relationships are Included;

· Employees’ interests as a general partner in securities held by a general or limited partnership; and

(2) A “Reportable Fund” means (a) any fund for which SUMMIT GLOBAL INVESTMENTS, LLC serves as the investment adviser as defined in section 2(a)(20) of the Investment Company Act of 1940 (i.e., in most cases SUMMIT GLOBAL INVESTMENTS, LLC would need to be approved by the fund’s board of directors before you can serve); or (b) any fund whose investment adviser or principal underwriter controls SUMMIT GLOBAL INVESTMENTS, LLC, is controlled by SUMMIT GLOBAL INVESTMENTS, LLC, or is under common control with KENISON FINANCIAL SERVICES LLC Currently, SUMMIT GLOBAL INVESTMENTS, LLC does not manage or advise (or is otherwise affiliated with) a Reportable Fund. [17j-1]

· Employees’ interests as a manager/member in the securities held by a limited liability company.

Employees do not have an indirect pecuniary interest in securities held by entities in which they hold an equity interest unless they are a controlling equity holder or they share investment control over the securities held by the entity.

The following circumstances constitute beneficial ownership by Employees of securities held by a trust:

· Ownership of securities as a trustee where either the Employee or members of the Employees’ immediate family have a vested interest in the principal or Income of the trust;

· Ownership of a vested beneficial interest in a trust; and

· An Employee’s status as a settlor/grantor of a trust, unless the consent of all of the beneficiaries is required in order for the Employee to revoke the trust.

Investments in Limited Offerings and Initial Public Offerings (“IPOs”)(3)

No Employee shall acquire, directly or indirectly, any Beneficial Ownership in any limited offering or IPO without first obtaining prior approval of the CCO in order to preclude any possibility of their profiting improperly from their positions on behalf of a client. The CCO shall (a) obtain from the Employee full details of the proposed transaction (Including written certification that the investment opportunity did not arise by virtue of the Employee’s activities on behalf of a client; and (b) conclude, after consultation with a Portfolio Manager (who has no personal interest in the issuer of the limited offering or IPO), that no clients have any foreseeable interest in purchasing such security. A record of such approval by the CCO and the reasons supporting those decisions shall be kept as required in the Records section of this Policy. Please refer to Attachment B for a copy of the Limited Offering and IPO Request and Reporting Form.

Reporting

In order to provide SUMMIT GLOBAL INVESTMENTS, LLC with information to enable it to determine with reasonable assurance any indications of “scalping”, “front-running” or the appearance of a conflict of interest with the trading by SUMMIT GLOBAL INVESTMENTS, LLC clients, each Employee of SUMMIT GLOBAL INVESTMENTS, LLC shall submit the following reports in the forms attached hereto to the CCO showing all transactions in securities in which the person has, or by reason of such transaction acquires, any direct or indirect Beneficial Ownership except for exempt transactions listed in the section below entitled “Exceptions from Reporting Requirements”.

NOTWITHSTANDING ANYTHING TO THE CONTRARY SET FORTH HEREIN, EMPLOYEES MAY CHOOSE TO INSTRUCT THEIR BROKER-DEALER TO PROVIDE DIRECTELY TO SUMMIT GLOBAL

(3) The term “limited offering” is defined as an offering that is exempt from registration under the Securities Act of 1933 pursuant to section 4(2) or section 4(6) or pursuant to Rules 504, 505, or 506 of Regulation D. The term “initial public offering” means an offering of securities registered under the Securities Act of 1933, the issuer of which, immediately before the registration, was not subject to the reporting requirements of sections 13 or 15(d) of the Securities Exchange Act of 1934.

INVESTMENTS, LLC (1) DUPLICATEBROKERAGE STATEMENTS AND/OR (2) DUPLICATE TRADING CONFIRMATION FOR ALL TRADES (OF ANY AND ALL TYPES WHATSOEVER) BE SUBMITTED AS THEY ARE PROCESSED, IN FULFILLMENT OF THE QUARTERLY TRANSACTION REPORTING OBLIGATIONS SET FORTH IN THIS POLICY, PROVIDED HOWEVER THAT TRADING IN ANY SECURITIES THAT ARE NOT REFLECTED IN THE STATEMENTS AND/OR CONFIRMATIONS SET FORTH ABOVE MUST BE PROVIDED IN THE FORMAT, TIME AND MANNER SET FORTH BELOW.

Quarterly Transaction Reports

Employees shall be required to instruct their broker-dealers to send to SUMMIT GLOBAL INVESTMENTS, LLC duplicate broker trade confirmations and/or account statements of the Employee which shall be received by the CCO, at a minimum, no later than thirty (30) days after the end of each calendar quarter. If an Employee’s trades do not occur through a broker-dealer (i.e., purchase of a private investment fund), such transactions shall be reported separately on the quarterly personal securities transaction report provided in Attachment C or similar form. The quarterly transaction reports shall contain at least the following information for each transaction in a Reportable Security in which the Employee had, or as a result of the transaction acquired, any direct or indirect beneficial ownership(4): (a) the date of the transaction, the title, and as applicable the exchange ticker symbol or CUSIP number, the interest rate and maturity date (if applicable), the number of shares and the principal amount of each Reportable Security involved; (b) the nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition); (c) the price of the Reportable Security at which the transaction was effected; (d) the name of the broker, dealer or bank with or through which the transaction was effected; and (e) the date that the report is submitted.

[17j-1] Employees shall also report on a quarterly basis, not later than 30 days after the end of the calendar quarter, the name of any account established by the Employee during the quarter in which any securities were held during the quarter for the direct or indirect benefit of the Employee, the date the account was established, and the date the report was submitted.

EMPLOYEES ARE REMINDED THAT THEY MUST ALSO REPORT TRANSACTIONS BY MEMBERS OF THE EMPLOYEE’S IMMEDIATE FAMILY INCLUDING SPOUSE, CHILDREN AND OTHER MEMBERS OF THE HOUSEHOLD IN ACCOUNTS OVER WHICH THE EMPLOYEE HAS DIRECT OR INDIRECT INFLUENCE OR CONTROL.

(4) “Beneficial Ownership,” as set forth under Rule 16a-1(a)(2), determines whether a person is subject to the provision of Section 16 of the Securities Exchange Act of 1934, and the rules and regulations thereunder, which generally encompasses those situations in which the beneficial owner has the right to enjoy some direct or indirect “pecuniary interest” (i.e., some economic benefit) from the ownership of a security. This may also include securities held by members of an Employee’s immediate family sharing the same household; provided however, this presumption may be rebutted. The term immediate family means any child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law and includes adoptive relationships. Any report of beneficial ownership required thereunder shall not be construed as an admission that the person making the report has any direct or indirect beneficial ownership in the Covered Securities to which the report relates.

Initial and Annual Holdings Reports

New SUMMIT GLOBAL INVESTMENTS, LLC Employees are required to report all of their personal securities holdings not later than 10 days after the commencement of their employment using either Attachment D or a similar form). The initial holdings report must be current as of a date not more than 45 days prior to the date the person becomes subject to this Code.

Existing Employees are required to provide SUMMIT GLOBAL INVESTMENTS, LLC with a complete list of securities holdings on an annual basis, or on or before January 31st (as determined by SUMMIT GLOBAL INVESTMENTS, LLC) of each year. The report shall be current as of December 31st, which is a date no more than 45 days from the final date the report is due to be submitted. The report may be filed using Attachment E or a similar form.

Each holdings report (both the initial and annual) must contain, at a minimum: (a) the title and type of security, and as applicable the exchange ticker symbol or CUSIP number, number of shares, and principal amount of each Reportable Security in which the Employee has any direct or indirect beneficial ownership; (b) the name of any broker, dealer or bank with which the Employee maintains an account in which any securities are held for the Employee’s direct or indirect benefit; and (c) the date the Employee submits the report. In the event that Employee submits brokerage or custodial statements to satisfy the initial and/or annual holdings report requirement, Employee must be certain that such statements Include the information listed above.

AS NOTED ABOVE, EMPLOYEES MUST REPORT THE NAME OF ANY BROKER, DEALER OR BANK WITH WHICH THE EMPLOYEE MAINTAINS AN ACCOUNT IN WHICH ANY SECURITIES ARE HELD FOR THE EMPLOYEE’S DIRECT OR INDIRECT BENEFIT. PLEASE NOTE THAT THIS REQUIREMENT DOES NOT PROVIDE FOR ANY EXEMPTIONS TO THE DEFINITION OF A SECURITY, AS THAT TERM IS DEFINED IN SECTION 202(A)(18) OF THE ADVISERS ACT. THUS, IF EMPLOYEES HAVE A BENEFICIAL INTEREST IN A NON-REPORTABLE SECURITY IN AN ACCOUNT THAT HAS NOT PREVIOUSLY BEEN REPORTED, THE NAME OF THE BROKER, DEALER OR BANK WHERE THESE ACCOUNTS ARE MAINTAINED MUST BE REPORTED (SEE ATTACHMENT F FOR A COPY OF THE ANNUAL ACCOUNT OPENING REPORTING FORM).

Duplicate Copies

A form brokerage letter is attached to this Policy as Attachment G. In order to help ensure that duplicate brokerage confirmations are received for all accounts pertaining to a particular Employee, such Employee may complete and send a brokerage letter similar to Attachment G to each bank, broker or dealer maintaining an account on behalf of the Employee.

Exceptions from Reporting Requirements

An Employee is not required to submit: 1) a transaction or initial and annual holdings report with respect to securities held in accounts over which the Employee had no direct or indirect influence or

control (i.e., any transactions occurring in an account that is managed on a fully-discretionary basis by an unaffiliated money manager and over which such employee has no direct or indirect influence or control), and 2) a transaction report with respect to transactions effected pursuant to an automatic investment plan.(5) The CCO will determine on a case-by-case basis whether an account qualifies for either of these exceptions. In addition, from time to time, the CCO may exempt certain transactions on a fully documented trade-by-trade basis.

Trading and Review

Except for limited circumstances and subject to pre-clearance approval, SUMMIT GLOBAL INVESTMENTS, LLC forbids its Employees to trade opposite of the Company’s recommendations. SUMMIT GLOBAL INVESTMENTS, LLC strictly forbids “front-running” client accounts, which is a practice generally understood to be Employees personally trading ahead of client accounts. Employees are strictly prohibited from engaging in frequent short-term trading of most mutual fund shares, as to avoid even the appearance of market timing activities. The CCO will closely monitor Employees’ investment patterns to detect these abuses.

If SUMMIT GLOBAL INVESTMENTS, LLC discovers that an Employee is personally trading contrary to the policies set forth above, the Employee shall meet with the CCO to review the facts surrounding the transactions. This meeting shall help SUMMIT GLOBAL INVESTMENTS, LLC to determine the appropriate course of action.

Reporting Violations and Remedial Actions

SUMMIT GLOBAL INVESTMENTS, LLC takes the potential for conflicts of interest caused by personal investing very seriously. As such, SUMMIT GLOBAL INVESTMENTS, LLC requires its Employees to promptly report any violations of the Code of Ethics to the CCO. SUMMIT GLOBAL INVESTMENTS, LLC’s management is aware of the potential matters that may arise as a result of this requirement, and shall take action against any Employee that seeks retaliation against another for reporting violations of the Code of Ethics.

If any violation of SUMMIT GLOBAL INVESTMENTS, LLC’s Personal Security Transaction Policy is determined to have occurred, the CCO may impose sanctions and take such other actions as he/she deems appropriate, Including, without limitation, requiring that the trades in question be reversed, requiring the disgorgement of profits or gifts, issuing a letter of caution or warning, issuing a suspension of personal trading rights or suspension of employment (with or without compensation), imposing a fine, making a civil referral to the SEC or state securities regulator, making a criminal referral, and/or terminating employment for cause or any combination of the foregoing. All sanctions and other actions taken shall be in accordance with applicable employment laws and regulations. Any profits or gifts forfeited shall be paid to the applicable client(s), if any, or given to a charity, as the CCO shall determine is appropriate.

(5) “Automatic investment plan” means a program in which regular periodic purchases (or withdrawals) are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation. An automatic investment plan includes a dividend reinvestment plan.

Disclosure

SUMMIT GLOBAL INVESTMENTS, LLC shall describe its Code of Ethics to clients in Part II of Form ADV and, upon request, furnish clients with a copy of the Code of Ethics. All client requests for SUMMIT GLOBAL INVESTMENTS, LLC’s Code of Ethics shall be directed to the CCO.

2. Insider Trading Policy

Section 204A of the Advisers Act requires every investment adviser to establish, maintain, and enforce written policies and procedures reasonably designed, taking into consideration the nature of such investment adviser’s business, to prevent the misuse of material, nonpublic information by such investment adviser or any person associated with such investment adviser. In accordance with Section 204A, SUMMIT GLOBAL INVESTMENTS, LLC has instituted procedures to prevent the misuse of nonpublic information.

Although “insider trading” is not defined in securities laws, it is generally thought to be described as trading either personally or on behalf of others on the basis of material non-public information or communicating material non-public information to others in violation of the law. In the past, securities laws have been interpreted to prohibit the following activities:

· Trading by an insider while in possession of material non-public information; or

· Trading by a non-insider while in possession of material non-public information, where the information was disclosed to the non-insider in violation of an insider’s duty to keep it confidential; or

· Communicating material non-public information to others in breach of a fiduciary duty.

· SUMMIT GLOBAL INVESTMENTS, LLC’s Insider Trading Policy applies to all of its Employees. Any questions should be directed to the CCO.

Whom Does the Policy Cover?

This policy covers all of SUMMIT GLOBAL INVESTMENTS, LLC’s Employees as well as any transactions in any securities participated in by family members, trusts or corporations directly or indirectly controlled by such persons. In addition, the policy applies to transactions engaged in by corporations in which the Employee is an officer, director or 10% or greater stockholder and a partnership of which the Employee is a partner unless the Employee has no direct or indirect control over the partnership.

What Information is Material?

Individuals may not be held liable for trading on inside information unless the information is material. “Material information” is generally defined as information for which there is a substantial likelihood that an investor would consider it important in making his or her investment decisions, or information that is reasonably certain to have a substantial effect on the price of a company’s securities.

Advance knowledge of the following types of information is generally regarded as “material”:

· Dividend or earnings announcements

· Write-downs or write-offs of assets

· Additions to reserves for bad debts or contingent liabilities

· Expansion or curtailment of company or major division operations

· Merger, joint venture announcements

· New product/service announcements

· Discovery or research developments

· Criminal, civil and government investigations and indictments

· Pending labor disputes

· Debt service or liquidity problems

· Bankruptcy or insolvency problems

· Tender offers, stock repurchase plans, etc.

· Recapitalization

Information provided by a company could be material because of its expected effect on a particular class of a company’s securities, all of the company’s securities, the securities of another company, or the securities of several companies. The misuse of material non-public information applies to all types of securities, Including equity, debt, commercial paper, government securities and options.

Material information does not have to relate to a company’s business. For example, material information about the contents of an upcoming newspaper column may affect the price of a security, and therefore be considered material.

What Information is Non-Public?

In order for issues concerning insider trading to arise, information must not only be material, but also non-public. “Non-public” information generally means information that has not been available to the investing public.

Once material, non-public information has been effectively distributed to the investing public, it is no longer classified as material, non-public information. However, the distribution of non-public information must occur through commonly recognized channels for the classification to change. In addition, the information must not only be publicly disclosed, there must be adequate time for the public to receive and digest the information. Lastly, non-public information does not change to public information solely by selective dissemination.

SUMMIT GLOBAL INVESTMENTS, LLC’s Employees must be aware that even where there is no expectation of confidentiality, a person may become an insider upon receiving material, non-public information. Whether the “tip” made to the Employee makes him/her a “tippee” depends on whether the corporate insider expects to benefit personally, either directly or indirectly, from the disclosure.

The “benefit” is not limited to a present or future monetary gain; it could be a reputational benefit or an expectation of a quid pro quo from the recipient by a gift of the information. Employees may also become insiders or tippees if they obtain material, non-public information by happenstance, at social gatherings, by overhearing conversations, etc.

Penalties for Trading on Insider Information

Severe penalties exist for firms and individuals that engage in the act of insider trading, including civil injunctions, treble damages, disgorgement of profits and jail sentences. Further, fines for individuals and firms found guilty of insider trading are levied in amounts up to three times the profit gained or loss avoided, and up to the greater of $1,000,000 or three times the profit gained or loss avoided, respectively.

Procedures to follow if an Employee Believes that he/she Possesses Material, Non-Public Information

If an Employee has questions as to whether they are in possession of material, non-public information, they must inform the CCO and as soon as possible. From this point, the Employee, CCO will conduct research to determine if the information is likely to be considered important to investors in making investment decisions, and whether the information has been publicly disseminated.

Given the severe penalties imposed on individuals and firms engaging in insider trading, Employees:

· Shall not trade the securities of any company in which they are deemed insiders who may possess material, non-public information about the company.

· Shall not engage in securities transactions of any company, except in accordance with SUMMIT GLOBAL INVESTMENTS, LLC’s Personal Security Transaction Policy and the securities laws.

· Shall submit personal security trading reports in accordance with the Personal Security Transaction Policy.

· Shall not discuss any potentially material, non-public information with colleagues, except as specifically required by their position.

· Shall immediately report the potential receipt of non-public information to the CCO.

· Shall not proceed with any research, trading, etc. until the CCO informs the Employee of the appropriate course of action.

3. Serving As Officers, Trustees and/or Directors of Outside Organizations

Employees may, under certain circumstances, be granted permission to serve as directors, trustees or officers of outside organizations by completing Attachment H. These organizations can include public or private corporations, partnerships, charitable foundations and other not-for-profit institutions. Employees may also receive compensation for such activities.

At certain times, SUMMIT GLOBAL INVESTMENTS, LLC may determine that it is in its clients’ best interests for an Employee(s) to serve as an officer or on the board of directors of an outside organization. For example, a company held in clients’ portfolios may be undergoing a reorganization that may affect the value of the company’s outstanding securities and the future direction of the company. Service with organizations outside of SUMMIT GLOBAL INVESTMENTS, LLC can, however, raise serious regulatory issues and concerns, including conflicts of interests and access to material non-public information.

As an outside board member or officer, an Employee may come into possession of material non-public information about the outside company, or other public companies. It is critical that a proper information barrier be in place between SUMMIT GLOBAL INVESTMENTS, LLC and the outside organization, and that the Employee does not communicate such information to other SUMMIT GLOBAL INVESTMENTS, LLC Employees in violation of the information barrier.

Similarly, SUMMIT GLOBAL INVESTMENTS, LLC may have a business relationship with the outside organization or may seek a relationship in the future. In those circumstances, the Employee must not be involved in the decision to retain or hire SUMMIT GLOBAL INVESTMENTS, LLC

SUMMIT GLOBAL INVESTMENTS, LLC Employees are prohibited from engaging in such outside activities without the prior written approval from the CCO. Approval will be granted on a case by case basis, subject to proper resolution of potential conflicts of interest. Outside activities will be approved only if any conflict of interest issues can be satisfactorily resolved and all of the necessary disclosures are made on Part II of Form ADV.

4. Diversion of Firm Business or Investment Opportunity

No Employee may acquire, or receive personal gain or profit from, any business opportunity that comes to his or her attention as a result of his or her association with SUMMIT GLOBAL INVESTMENTS, LLC and in which he or she knows SUMMIT GLOBAL INVESTMENTS, LLC might be expected to participate or have an interest, without disclosing in writing all necessary facts to the CCO, offering the particular opportunity to SUMMIT GLOBAL INVESTMENTS, LLC, and obtaining written authorization to participate from the CCO.

Any personal or family interest of an Employee in any SUMMIT GLOBAL INVESTMENTS, LLC business activity or transaction must be immediately disclosed to the CCO. For example, if an Employee becomes aware that a transaction being considered or undertaken by SUMMIT GLOBAL INVESTMENTS, LLC may benefit, either directly or indirectly, an Employee or a family member thereof, the Employee must immediately disclose this possibility to the CCO.

5. Loans

No Employee may borrow funds from or become indebted to, any person, business or company having business dealings or a relationship with SUMMIT GLOBAL INVESTMENTS, LLC, except with respect to customary personal loans (e.g., home mortgage loans, automobile loans, lines of credit, etc.), unless the arrangement is disclosed in writing and receives prior approval from the CCO. Loans, whether or not customary, from any person, business or company having business dealings with SUMMIT GLOBAL INVESTMENTS, LLC with respect to which the Employee has had personal involvement will require the prior written approval of the CCO. No Employee may use SUMMIT GLOBAL INVESTMENTS, LLC’s name, position in a particular market or goodwill to receive any benefit on loan transactions without the prior express written consent of the CCO.

6. Dealings with Government and Industry Regulators

SUMMIT GLOBAL INVESTMENTS, LLC’s policy forbids payments of any kind by it, its Employees or any agent or other intermediary to any government official, self-regulatory official, corporation or other similar person or entity, within the United States or abroad, for the purpose of obtaining or retaining business, or for the purpose of influencing favorable consideration of any application for a business activity or other matter. This policy covers all types of payments, even to minor government officials and industry regulators, regardless of whether the payment would be considered legal under the circumstances. This policy encourages Employees to avoid even the appearance of impropriety in their dealings with industry and government regulators and officials.

It is expected and required that all Employees fulfill their personal obligations to governmental and regulatory bodies. Those obligations include the filing of appropriate federal, state and local tax returns, as well as the filing of any applicable forms or reports required by regulatory bodies.

All Employees are required to cooperate fully with management in connection with any internal or independent investigation and any claims, actions, arbitrations, litigations, investigations or inquiries brought by or against SUMMIT GLOBAL INVESTMENTS, LLC Employees are expected, if

requested, to provide SUMMIT GLOBAL INVESTMENTS, LLC with reasonable assistance, including, but not limited to, meeting or consulting with SUMMIT GLOBAL INVESTMENTS, LLC and its representatives, reviewing documents, analyzing facts and appearing or testifying as witnesses or interviewees or otherwise.

7. Political Contributions and Public Office

The following outlines SUMMIT GLOBAL INVESTMENTS, LLC’s policies with respect to political contributions and public office:

· Political contributions, gifts, subscription, loans, advance, or deposit of money or anything of value are not to exceed $250.00 per candidate per election;

· An Employee is permitted to make a contribution to a candidate only if the Employee is entitled to vote for him/her at the time of the contribution; and

· No Employee is permitted to make any soft dollar contributions.

No Employee can hold a public office if it in any way conflicts with SUMMIT GLOBAL INVESTMENTS, LLC’s business.

8. Improper Use of SUMMIT GLOBAL INVESTMENTS, LLC Property

No Employee may utilize property of SUMMIT GLOBAL INVESTMENTS, LLC or utilize the services of SUMMIT GLOBAL INVESTMENTS, LLC, its principals or employees, for his or her personal benefit or the benefit of another person or entity, without proper and express written approval of the CCO. For this purpose, “property” means both tangible and intangible property, including SUMMIT GLOBAL INVESTMENTS, LLC and Employee funds, premises, equipment, supplies, information, business plans, business opportunities, confidential research, intellectual property or proprietary processes, and ideas for new research or services.

9. Protection of SUMMIT GLOBAL INVESTMENTS, LLC’s Name

Employees should at all times be aware that SUMMIT GLOBAL INVESTMENTS, LLC’s name, reputation and credibility are valuable assets and must be safeguarded from any potential misuse. Care should be exercised to avoid the unauthorized use of SUMMIT GLOBAL INVESTMENTS, LLC’s name in any manner that could be misinterpreted to indicate a relationship between SUMMIT GLOBAL INVESTMENTS, LLC and any other entity or activity.

10. Employee Involvement in Litigation or Proceedings

Employees must advise the CCO immediately if he or she becomes involved in or threatened with litigation or an administrative investigation or proceeding of any kind, is subject to any judgment, order or arrest, or is contacted by any regulatory authority.

11. Gifts

Employees may not accept investment opportunities, gifts or other gratuities from individuals seeking to conduct business with SUMMIT GLOBAL INVESTMENTS, LLC, or on behalf of an advisory client. However, Employees may accept gifts from a single giver in aggregate amounts not exceeding $100, and may attend business meals, sporting events and other entertainment events at the expense of a giver, as long as the expense is reasonable and both the giver(s) and the

Employee(s) are present. Employees must report their receipt of gifts to the CCO by completing Attachment I.

Recordkeeping

SUMMIT GLOBAL INVESTMENTS, LLC shall maintain records in the manner and to the extent set forth below, which records shall be available for appropriate examination by representatives of regulatory authorities or SUMMIT GLOBAL INVESTMENTS, LLC’s management.

· A copy of this Policy and any other code which is, or at any time within the past five years has been, in effect shall be preserved in an easily accessible place;

· A record of any violation of this Policy and of any action taken as a result of such violation shall be preserved in an easily accessible place for a period of not less than five years following the end of the fiscal year in which the violation occurs;

· A record of all written acknowledgements (annual certifications) as required by this Policy for each person who is currently, or with the past five years was, an Employee of SUMMIT GLOBAL INVESTMENTS, LLC

· A copy of each report made pursuant to this Policy by an Employee, including any information provided in lieu of reports, shall be preserved by the Company for at least five years after the end of the fiscal year in which the report is made or the information is provided, the first two years in an easily accessible place;

· A list of all persons who are, or within the past five years have been, required to make reports pursuant to this Policy, or who are or were responsible for reviewing these reports, shall be maintained in an easily accessible place;

· The Company shall preserve a record of any decision, and the reasons supporting the decision, to approve the acquisition of any limited offering or IPO by Employees for at least five years after the end of the fiscal year in which the approval is granted, the first two years in an easily accessible place.

Responsibility

The CCO will be responsible for administering the Code of Ethics. All questions regarding the policy should be directed to the CCO. All Employees must acknowledge their receipt and understanding of the Code of Ethics upon commencement of their employment.

Attachment A

Personal Trading Pre-Clearance Form

The pre-clearance form documents that the proposed transaction is not a conflicting transaction. Pre-clearance must be granted prior to placing a trade, and is only good for the day of the approval.

Buy

Sell

Short

Security

Common Stock

Option

Debt

Other

If applicable, is the Equity a “New Issue”? Yes

Symbol

Number of Shares/Contracts/Principal

Brokerage Account Number

Custodian

Employee has no inside information or other knowledge pertaining to this proposed transaction that constitutes a violation of Company policy or securities laws.

10.

Any transaction described above establishing a position in a security is undertaken with the intention of holding such position for not less than thirty (30) days if the security is held in a client account as of the date below.

Employee			(PRINT NAME)

Signed
			Date

By signing below, the individual verifies that the proposed transaction described above does not violate SUMMIT GLOBAL INVESTMENTS, LLC’s Personal Security Transaction Policy. Note: One signature is required for pre-clearance.


Chief Compliance Officer		Date


Chief Executive Officer/Trader/Portfolio Manager		Date

Attachment B

Limited Offering & IPO Request and Reporting Form

Name of Issuer:

Type of Security:

Public Offering Date:
(for proposed IPO investments only)

By signing below, I certify and acknowledge the following:

1. I am not investing in this limited offering or IPO to profit improperly from my position as an SUMMIT GLOBAL INVESTMENTS, LLC Employee;

2. The investment opportunity did not arise by virtue of my activities on behalf of an SUMMIT GLOBAL INVESTMENTS, LLC client; and

3. To the best of my knowledge, no SUMMIT GLOBAL INVESTMENTS, LLC clients have any foreseeable interest in purchasing this security.

Furthermore, by signing below, I certify that I have read the SUMMIT GLOBAL INVESTMENTS, LLC Code of Ethics and believe that the proposed trade fully complies with the requirements of this policy. I understand SUMMIT GLOBAL INVESTMENTS, LLC reserves the right to direct me to rescind a trade even if approval is granted. I also understand that a violation of this policy will be grounds for disciplinary action or dismissal and may also be a violation of federal and/or state securities laws.

Date:				Signature:

Print Name:

Internal Use Only

o	Approved	o	Not Approved Person Approving

Reasons Supporting Decision to Approve/Not Approve:

Attachment C

QUARTERLY TRANSACTION REPORTING FORM

REPORTING EMPLOYEE:

FOR QUARTER ENDED

Number
of Shares

Security
Name

Type (e.g.,
equity;
fixed income)

Ticker or
CUSIP
(if app.)

Principal
Amount

Buy (acquire)/
Sell (dispose)

Interest
rate/
maturity

Price

Date

Broker, Dealer or Bank

In accordance with SUMMIT GLOBAL INVESTMENTS, LLC’s Code of Ethics, please provide a list of all securities transactions that have occurred during the previous calendar quarter in any account in which you maintain a pecuniary interest.

TO BE USED FOR TRANSACTIONS THAT OCCUR OUTSIDE OF YOUR BROKERAGE ACCOUNTS.

DELIVER TO WITHIN 30 DAYS OF THE END OF EACH CALENDAR QUARTER.

USE ADDITIONAL SHEETS IF NECESSARY.

Attachment D

Initial Holdings Form-Page 1

Employee				(PRINT NAME)

Information submitted current as of				(PRINT DATE)

In accordance with SUMMIT GLOBAL INVESTMENTS, LLC’s Code of Ethics, please provide a list of all securities accounts in which you have a pecuniary interest.

Name of Broker, Dealer or Bank	Account Title	Account Number

I certify that this form fully discloses all of the securities in which I have a pecuniary interest. Nothing in this report should be construed as an admission that the person making the report has any direct or indirect beneficial ownership in the security to which the report relates.


Signature					Date


Reviewed by:

Date of Review:

Exception(s) Noted:	o	No	o	Yes

If Yes, Describe:

Initial Holdings Form-Page 2

In accordance with SUMMIT GLOBAL INVESTMENTS, LLC’s Code of Ethics, please provide a list of all securities in which you have a pecuniary interest. This includes securities held by broker/dealers and other custodians, at your home, in safe deposit boxes, and by an issuer.

Number of Shares	Security Name	Type (e.g., equity; Fixed income)	Ticker or CUSIP (if applicable)	Principal Amount

Use additional sheets as necessary.

Attachment E

Annual Reporting Form-Page 1

Employee				(PRINT NAME)

Information submitted current as of				(PRINT DATE)

In accordance with SUMMIT GLOBAL INVESTMENTS, LLC’s Code of Ethics, please provide a list of all securities accounts in which you have a pecuniary interest.

Name of Broker, Dealer or Bank	Account Title	Account Number


Signature					Date


Reviewed by:

Date of Review:

Exception(s) Noted:	o	No	o	Yes

If Yes, Describe:

Annual Reporting Form-Page 2

Number of Shares	Security Name	Type (e.g., equity; Fixed income)	Ticker or CUSIP (if applicable)	Principal Amount

Use additional sheets as necessary.

Attachment F

ANNUAL ACCOUNT OPENING REPORTING FORM

	REPORTING EMPLOYEE:

	FOR YEAR ENDED

In accordance with SUMMIT GLOBAL INVESTMENTS, LLC’s Code of Ethics, please provide a list of all securities accounts that have opened during the previous calendar year for which you have a direct or indirect benefit.

Name of Broker, Dealer or Bank		Security Type

I certify that this form fully discloses all newly opened securities accounts in which any securities are held for my direct or indirect benefit.

Reviewed by:

Print Name

Date of Review:

Signature

Date

Exception(s) Noted:

Yes

If Yes, Describe:

Attachment G

Sample of Brokerage Letter

<DATE>

<CITY, STATE ZIP>

Re: Account No.

Account Name

Dear <NAME>,

As of <DATE>, please send to the undersigned a duplicate confirmation of each transaction in the above named account and monthly brokerage account statements for the above named account.

Please mail the confirmations and account statements to:

SUMMIT GLOBAL INVESTMENTS, LLC

Attn: Mark L Kenison

8200 Avanti Dr.

Waxhaw, NC 28173

If you have any questions or concerns, please feel free to give me a call at (919) 968-8888. Thank you for your immediate attention to this matter.

Sincerely,

<Name>

cc: <Name>

Attachment H

Request for Approval of Outside Activity Form

The undersigned hereby requests approval for participation in the following outside activity:



Name and address of company or organization:

Nature of organization’s primary business or purpose:

Is this a public company? (YES/NO) If YES, stock symbol:

Complete description of anticipated role with organization:



Describe any compensation you will receive:

If this request for approval is granted:

· I agree to notify the Chief Compliance Officer of any change in the above information.

· I agree, for private or not-for-profit organizations, to seek approval to retain my position, as described above, if the organization decides to offer securities to the public, or ceases to maintain its not-for-profit status.

· I am aware of no other employees who are officers or directors of the organization noted above.

· I agree to adhere to the insider trading policies of both Adviser SUMMIT GLOBAL INVESTMENTS, LLC (“SUMMIT GLOBAL INVESTMENTS, LLC”) and the organization, and not to communicate any material non-public information in my possession regarding the organization to SUMMIT GLOBAL INVESTMENTS, LLC’s investment advisory or research staff.

· I will avoid participation in discussions regarding service, investment management, or other arrangements with SUMMIT GLOBAL INVESTMENTS, LLC or its affiliates, and will recuse myself from voting on any such matters.

Signature of Employee:				Date:


Approved By:				Date:

Attachment I

Gift Receipt Report

Employee(s) Receiving the Gift:




Describe the Gift:






Approximate Total Dollar Amount of Gift: $

Giver of the Gift:




Has Employee Received Additional Gifts from Giver within the Past 12 Months? If yes, list the gifts received and the approximate Value of the Gifts:




Relationship of Giver to SUMMIT GLOBAL INVESTMENTS, LLC and/or Employee(s):




Reason (if known) the Gift will be given to SUMMIT GLOBAL INVESTMENTS, LLC and/or Employee(s):