January2024

BH-DGSystematicTradingLLP

Code of Ethics

inaccordancewithRule17j-1undertheInvestmentCompanyActof1940

(the“1940Act”)

I.IntroductionandPurposeoftheCode

BH-DG Systematic Trading LLP (“BH-DG”) serves as an investment adviser or investment sub-adviser to

investment companies registered under the 1940 Act (each, a “Client”).In such capacity, BH-DG owes a

fiduciary responsibility to its Clients.BH-DG and every Access Person (defined below) of BH-DG owe those

Clients a duty of undivided loyalty.Clients expect BH-DG to act in their best interests at all times; therefore,

BH-DG seeks to maintain a reputation for fair dealing and honesty.

This Code of Ethics (“Code”) is intended to comply with the requirements of Rule 17j-1 under the 1940 Act,

applicable when BH-DG acts as an investment adviser or investment sub-adviser to a Client.It establishes

standards of conduct expected of each Access Person and addresses conflicts that arise from an Access Person’s

personaltrading and other activities.Every AccessPerson isexpectedto fully understandandadhereto the

policies and procedures set forth in the Code.BH-DG holds all Access Persons equally accountable to every

provision within this Code regardless of title and/or work function.As each Access Person must be aware, BH-

DG works in a highly regulated industry and is governed by an ever-increasing body of federal, state, and

internationallawsand numerousrulesand regulationswhich,ifnotobserved,can subjectBH-DGand/orAccess

Persons to regulatory sanctions.

The Code is designed to establish procedures for the detection and prevention of activities by which persons

having knowledge of the holdings, recommended investments and investment intentions of BH-DG’s Clients

may abuse their fiduciary duties, and otherwise to deal with the type of conflict of interest situations addressed

by Rule 17j-1 under the 1940 Act.

Although the Code is intended to provide each Access Person with guidance and certainty as to whether or not

certain actions or practices are permissible, it does not cover every issue an Access Person may face.In this

regard, BH-DG also maintains other compliance-oriented policies and procedures, including, among others, a

Personal Account Dealing Policy that may be directly applicable to an Access Person’s specific responsibilities

and duties.Nevertheless, this Code should be viewed as a guide for each Access Person with respect to how

BH-DG must conduct business, specifically, that the interests of Clients must always come first.

If you have any questions about the Code, you should discuss them with Legal and Compliance, as soon as

possible to ensure that you remain in compliance with the Code at all times.In the event that any provision of

this Code conflicts with any other BH-DG policy or procedure, the provisions of this Code shall apply.

Access Persons must promptly report any violations of the Code of Ethics to Legal and Compliance. Reports of

violations of others may be made on an anonymous basis and no Access Person will be penalized for reporting

violations or suspected violations.

AllAccessPersonsareexpectedtoreadtheCodecarefullyandobserveandadheretoitsguidanceatalltimes.

II.General

All Access Persons1 acting for a Client of BH-DG are subject to this Code of Ethics. The Code of Ethics is

predicatedontheprinciplethatBH-DGowesafiduciarydutytoitsClients.Accordingly,AccessPersonsmust

1 “Access Person” means any: (i) member, officer or employee of BH-DG (or of any company in a control

relationship to BH-DG) who,in connection with his or her regular functions or duties, makes, participates in, or

obtains information regarding, the purchase or sale of Restricted Instruments (as defined in BH-DG’s Personal

Account Dealing Policy) by a Client, or whose functions relate to the making of any recommendations with

respect to such purchases or sales; and (ii) any natural person in a control relationship to BH-DG who obtains

information concerning recommendations made to a Client with regard to the purchase or sale of Restricted

Instruments by the Client.

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avoid activities, interests and relationships that run contrary (or appear to run contrary) to the best interests of

Clients. At all times, Access Persons must:

Place Client interests ahead of BH-DG’s interests – As a fiduciary, BH-DG must serve its Clients’ best

interests. In other words, Access Persons may not benefit at the expense of Clients.

Engage in personal investing that is in full compliance with BH-DG’s Code of Ethics – Access Persons must

review, understand and abide by BH-DG’s Personal Account Dealing Policy set forth as Attachment 1 to the

Code of Ethics.

III.GuidingPrinciplesandStandardsofConduct

All Access Persons must act with competence, dignity and integrity, in an ethical manner, when dealing with

Clients, prospectiveClients, thepublic,third-partyserviceprovidersand fellowemployees.Thefollowingsetof

principles frames the professional and ethical conduct that BH-DG expects from its Access Persons:

•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 market

participants;

•Placetheintegrityoftheinvestmentprofession,theinterestsofClientsandtheinterestsofBH-DG

above one’s own personal interests;

•Adhere to the fundamental standard that the Access Person should not take inappropriate advantage of

his or her position;

•Conduct all personal securities transactions in a manner consistent with the Personal Account Dealing

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;

•Practiceandencourageotherstopracticeinaprofessionalandethicalmanner;and

•Promotetheintegrityof,andupholdtherulesgoverning,capitalmarkets.

IV.GeneralProhibitionsMandatedbyLaw

Access Persons and all employees of BH-DG are not permitted, in connection with the purchase or sale of a

security, directly or indirectly, to:

•employanydevice,schemeorartificetodefraudanyClient;

•make any untrue statement of a material fact or omit to state to such Client a material fact necessary in

order to make the statements made, in light of the circumstances under which they are made, not

misleading;

•engage in any act, practice, or course of business which operates or would operate as a fraud or deceit

upon any such Client; or

•engageinanymanipulativepracticewithrespecttosuchClient.

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V.PersonalAccountDealingPolicy

BH-DGhasadetailedpolicyinplaceforpersonalaccountdealingthatmustbecompliedwithbyAccess

Persons at all times.The Personal Account Dealing Policy is available in Attachment 1.

VI.ConflictsofInterest

As a fiduciary, BH-DG has an affirmative duty of care, loyalty, honesty, and good faith to act in the best

interestsof itsClients.Compliance with thisduty can be achievedby tryingtoavoidconflictsof interest andby

fully disclosing all material facts concerning any conflict that does arise with respect to any Client. All Access

Persons must try to avoid situations that have even the appearance of conflict or impropriety.

Conflicts of interest may arise when BH-DG or its Access Persons have reason to favor the interests of other

investment advisory clients of BH-DG over a Client (e.g., larger clients over smaller Clients, other clients that

pay performance fees over Clients that do not pay performance fees, other clients in which Access Persons have

made material personal investments, other clients of close friends or relatives of Access Persons).The Code

expressly prohibits favoritism of one investment advisory client over another.

VII.RemedialActions

BH-DG takes the potential for conflicts of interest caused by personal investing very seriously. Access Persons

should be aware that BH-DG reserves the right to impose varied sanctions on policy violators depending on the

severity of the policy violation, including possible termination of employment.

X.DistributionofCodeofEthics,AcknowledgementandAnnualCertification

This Code, including any amendments, shall be distributed to Access Persons by Legal and Compliance.On an

annual basis, and at such other times as Legal and Compliance may deem necessary or appropriate, Access

Persons shall sign an Acknowledgement and Disclosure Statement, a copy of which is located in Attachment 2,

and return it to Legal and Compliance.

XI.DocumentsandInformationProvidedbyBH-DGtoClients

TheHeadofLegalandCompliancewill:

•SubmittotheBoardofDirectorsoftheClientacopyofthisCode;

•Report to the Client in writing any material amendments to this Code promptly, but in no event later

than six months after the adoption of such amendment;

•Immediately furnish to the Client, without request, information regarding any material violation of this

Code by any person; and

•No less frequently than annually furnish to the Client's Board of Directors a written report that (a)

describesanyissuesarisingunderthisCodesincethe lastreporttotheBoard,including,butnotlimited

to, information about material violations of the Code and sanctions imposed in response to the material

violationsand(b)certifiesthatBH-DGhasadoptedproceduresreasonablynecessary topreventAccess

Persons from violating the Code.

XII.Recordkeeping

BH-DGwillmaintainrecordsassetforthbelow.TheserecordswillbemaintainedinaccordancewithRule17j-

1 underthe1940 Actand thefollowing requirements.Theywillbeavailableforexamination byrepresentatives

of the U.S. Securities and Exchange Commission.

•A copy of this Code and any other code of ethics which is, or at any time within the past five years has

been, in effect will be preserved in an easily accessible place.

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•A list of all persons who are, or within the past five years have been, required to submit reports under

this Code will be maintained in an easily accessible place.

•A copy of each report made by each Access Person under this Code and the Personal Account Dealing

Policyor the information provided in lieu of such report will be preserved for a period of not less than

five years from the end of the fiscal year in which it is made, the first two years in an easily accessible

place.

•A record of any Code violation and of any sanctions taken will 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

occurred, the first two years in an easily accessible place.

•A copy of each annual report to the Board of Directors of a Client will be maintained for at least five

years from the end of the fiscal year in which it is made, the first two years in an easily accessible

place.

•A record of any decision, and the reasons supporting the decision, to approve the acquisition by an

Access Person of securities in an “initial public offering” or in a “limited offering” (as defined in Rule

17j-1 under the 1940 Act) forat least five years after the end of the fiscal year in which the approval is

granted.

•A record of all Acknowledgement and Disclosure Statements provided to Legal and Compliance for

each person who is currently, or within the past five years was, an Access Person.

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Attachment1

PERSONALACCOUNTDEALINGPOLICY

BH-DGSystematicTradingLLP

January2024

Attachment 2

Codeof Ethics

AcknowledgementandDisclosureStatement

For:InitialAcknowledgement

I hereby certify to BH-DG Systematic Trading LLP (“BH-DG”) that, I have

received, read and understand the Code of Ethics (“Code”) of BH-DG.

Date:

Signature

PrintName

For:AnnualCertification

In accordance with the requirements of BH-DG’s Code, I hereby certify, as a

condition of my employment:

(1)Ihavecompliedwith therequirementsof theCode;

(2)I have disclosed or reported all personal transactions and

holdings as required under the Code and BH-DG’s Personal

Account Dealing Policy; and

(3)I have received, read and understand the Code and I recognize

that I am subject to it.

Date:

Signature

PrintName