CodeofEthics

for JLens

September27,2024

JLens is the sole owner of all rights to this document. Upon termination of employment, return this documentandanycopiesofthisdocumenttotheFirmimmediately.Theinformationcontainedhereinis confidential and proprietary and may not be disclosed to any third party or otherwise shared or disseminated in any way without the prior written approval of the Chief Compliance Officer.

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TableofContents

INTRODUCTION	2
CODE OF ETHICS	5
Personal Account Trading	7
Conflicts of Interest	8
Gifts and Entertainment	8
Political Contributions	9
Personal Securities Transactions Procedures and Reporting	11
Insider Trading	17
APPENDIX 3	23
APPENDIX 4	23
APPENDIX 5	26
APPENDIX 6	26
APPENDIX 7	28

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INTRODUCTION

EntityStructure

JLens (also referred to as “Firm,” “we,” “our,” and “us”),formedin2012,isa501(c)(3)nonprofitcorporation that conducts research and advocacy inspired by Jewish values and on behalf of the Jewish community. The Firm was formed in California and maintains its principal place of business in New York, NY. JLens became affiliated with the Anti-Defamation League (“ADL”) in 2022 to strengthen efforts to fight anti-Israel and antisemiticpoliciesandactionsinthevalues-basedinvestmentfield.WhiletheADLhasnodirectequityinterest in JLens, it provides funding and administrative support.

Services-Sub-Adviser

JLens willserveasadiscretionaryinvestmentSub-Advisertoa1940InvestmentCompanyActproduct(“JLens 500 Jewish Advocacy U.S. ETF” or the “Fund”). The Fund expects to launch in1Q2025.JLenswillprovide sub-advisoryservicestothe Fund for an annual fee based on the percentage of the value of the assets that are sub-advised (“sub-advisory fee”). TheFundwillusea“passivemanagement”(orindexing)approachtoseekto track the total return performance, before fees andexpenses,oftheJLens500JewishAdvocacyU.S.Index(the “Index”). The Index was developed in 2024 by JLens and is administered and calculated by VettaFi LLC.

Services-DataLicensingAgreement

JLens offers data licensing services primarily to unaffiliated investmentadvisoryfirmsandotherinvestorssuch as familyoffices.TheseservicesentailJLensprovidingalistofJewishvalues-basedexclusionsforUSlargecap equity portfolios (including security names and tickers) from which unaffiliated investment advisory firms construct portfolios on behalf of their investors. The list is prepared using publicly available information, and internal research and analysis conducted on large cap US companies by JLens.

JLens provides data in accordance with the terms set forth in legal agreements with each data licensing client. Following the submission of the initial list of issuer exclusions, JLens provides list changes periodically as appropriate based on market conditions and client direction. Data licensing clients retain full authority to construct and trade investor portfolios and handle all administrative aspects of investor account management.

RegulatoryBackground

This Code of Ethics has been prepared to assist Access Persons (defined below) in complying with applicable securities laws and adopting a compliance program consistent with sound business practices.This Code of Ethics is intended to comply with the Investment Advisers Act of 1940, as amended (“Advisers Act”), the applicable provisions of the Investment Company Act of 1940, as amended (“1940 Act”),andotherapplicable rules and regulations adopted by the SEC and other functional regulators.

As Sub-Adviser totheFund,JLensanditsemployeesarerequiredtocomplywithcertainprovisionsofthe1940 Act, as amended.The Sub-Advisory Agreement executed between JLens and the investment adviser of the Fund, EA Advisers, istheprimarygovernancedocumentwhichconveysexplicitresponsibilitiesandobligations to JLens and its employees relative to portfolio management and monitoring, risk management reporting, and compliance with the 1940 Act. It is JLens’ stated policy to manage the Fund for the benefit ofitsshareholders rather than its own benefit.

Preamble

These guidelines are not intended to address every situation. Access Persons are expectedtoobeyallsecurities laws. JLens recognizes its need to respond flexibly to dynamic businessneedsandcircumstances.Accordingly, JLens reserves the right to revoke, modify, interpret, and apply its guidelines, policies, orproceduresatitssole discretion, and without prior notice. This Code of Ethics is not intended to be a contract or legally binding agreement, nor does it promise specific treatment in specific situations.

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Rule 204A-1 under the Advisers Act requires each investment adviser registered with the SEC to adoptacodeofethicsthatsetsforthastandardofbusinessconductrequiredandexpectedofallitsAccessPersons.Rule 17j-1 under the 1940 Act also requires advisers to an ETF to adopt written codes of ethics.As a registered investment adviser, as well as the adviser to the Fund, JLens has adopted this Code of Ethics (“Code”) in accordance with these rules.

JLens expects Access Persons to comply with the letter of the Code and to observe its spirit. Always consider how your actions will reflect on the Firm as a whole and yourself as a professional. At the commencement of your employment or designation as an Access Person with JLens, and each time a new version of the Code is issued, you must certify that you understand andagreetoabidebythetermsoftheCodebysigningtheCodeof Ethics Certification, found in Appendix 1.

If an Access Person acts in a manner contrary to the Code, s/he could be subject to disciplinary sanctions dependingontheevaluationofthecircumstances.Thestandardsofconductsetforthhereinareappliedfullyand fairly without reliance upon technical distinctions to justify questionable conduct. Intentional and inadvertent Code violations may trigger disciplinary action, up to and including termination of employment, dependingupon the severity or frequency.

CODEOFETHICS

ImportantNote

ForpurposesofthisCodeofEthics,the term “client” is interpreted to mean EA Advisers, JLens data license clients, and any future clients, including prospective sub-advised separate account clients.

General

This is the Code of Ethics of JLens. The Firm's Personal Securities Transactions reporting and Insider Trading Procedures can be found in this Code.

FiduciaryDuty

ThisCodeofEthicsispredicatedontheprinciplethattheFirmowesafiduciarydutytoitsclients.Afiduciary is to approach his or her client’s affairs with the same prudence as would be used in the management of hisor her own affairs. Fiduciaries are expected to place the interests of theclientbeforetheirown.Fiduciariescannot withhold material information from a client that would affect the client’s investment decision. Accordingly, Access Persons must avoid activities, interests and relationships that run contrary (orappeartoruncontrary)to the best interests of clients.

Atalltimes,theFirmwill:

●Place client interests ahead of the Firm’s – As a fiduciary, theFirmwillserveitsclients’bestinterests. In other words, Access Persons may not benefit at the expense of advisory clients. This concept is particularly relevant when Access Persons are making personal investments in securities traded by advisory clients.

●Engage in personal investing that is infullcompliancewiththeFirm’sCodeofEthics–AccessPersons must review and abide by the Firm’s Personal Securities Transaction and Insider Trading Policies.

●Avoid taking advantage of your position – Access Persons must not accept investment opportunities, gifts or other gratuities from individuals seeking to conduct business with the Firm, or on behalf of an advisory client, unless in compliance with the Gift Policy below.

●Maintain full compliance with the Federal Securities Laws – Access Persons must abide by the standards set forth in Rule 204A-1 under the Advisers Act and Rule 17j-1 under the 1940 Act.

Any questions with respect to this Code of Ethics should be directedtotheCCO.Asdiscussedingreaterdetail below, Access Persons mustpromptlyreportanyviolationsoftheCodeofEthicstotheCCO.AllreportedCode of Ethics violations will be treated on an anonymous basis when it is necessary and appropriate to do so.

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Definitions

CCO:ChiefComplianceOfficerperrule206(4)-7oftheAdvisersAct.TheFirmhasdesignatedaChief Compliance Officer.

Associated Person: All directors, officers, and partnersoftheFirm(orotherpersonsoccupyingasimilarstatus or performing similar functions);employeesoftheFirm;andanyotherpersonwhoprovidesadviceonbehalfof the Firm and is subject to the Firm’s supervision and control.

Access Person (“you”): Access Persons are those who have access to nonpublic information regarding any clients' purchase or sale of securities, or nonpublic information regarding the portfolio holdings of anyreportable fund, or any Access Person who isinvolvedinmakingsecuritiesrecommendationstoclients,orwho has access to such recommendations that are nonpublic. All JLens’ Associated Persons (as defined in the Compliance Manual) are deemed to be Access Persons. Please see the CCO for a current list of Access Persons.

Beneficial Ownership: Access Personsareconsideredtohavebeneficialownershipofsecuritiesiftheyhaveor share a direct or indirect pecuniary interest in the securities. They have a pecuniaryinterestinsecuritiesifthey have the ability to profit from a securities transaction directly or indirectly.

Thefollowingareexamplesofindirectpecuniaryinterestsinsecurities:

●Securities held by members of Access Persons’ 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;

●AccessPerson’sinterestsasageneralpartnerinsecuritiesheldbyageneralorlimitedpartnership;and

●AccessPerson’sinterestsasamanager/memberinthesecuritiesheldbyalimitedliabilitycompany.

Access Persons 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.

ThefollowingcircumstancesconstitutebeneficialownershipbyAccessPersonsofsecuritiesheldbyatrust:

●Ownership ofsecuritiesasatrusteewhereeithertheAccessPersonormembersoftheimmediatefamily have a vested interest in the principal or income of the trust;

●Ownershipofavestedbeneficialinterestinatrust; and

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

Reportable Fund: The JLens 500 Jewish Advocacy U.S. ETF (the “Fund”) is considered a reportable fund because JLens serves as Sub-Adviser to the Fund.

Reportable Security: any note, stock, treasury stock, bond, debenture, evidence of indebtedness, certificateof interest or participation in any profit-sharing agreement, collateral-trust certificate, pre-organization certificateor subscription, transferable share, investment contract, voting-trust certificate, certificate of deposit for a security, fractional undivided interest in oil, gas, or other mineral rights, any put, call, straddle, option, or privilege onanysecurity(includingacertificateofdeposit)oronanygrouporindexofsecurities(includingany interest therein or based on the value thereof), or any put, call, straddle, option, or privilege entered into on a national securities exchange relating to foreign currency, or, in general, any interest or instrument commonly known as a "security," or any certificate of interest or participation in, temporary or interim certificate for, receipt for, guaranty of, or warrant or right to subscribe to or purchase any of the foregoing.

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ReportableSecuritydoesnotinclude(ExceptedSecurities):

1.DirectobligationsoftheGovernmentoftheUnitedStates;

2.Bankers' acceptances, bank certificates of deposit, commercial paper, and high-quality short-term debt instruments, including repurchase agreements;

3.Sharesissuedbymoneymarketfunds;

4.Sharesissuedbyopen-endfundsotherthanreportablefunds; and

5.Sharesissuedbyunitinvestmenttruststhatareinvestedexclusivelyinoneormoreopen-end funds, none of which are reportable funds

Initial Public Offering: 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 Section 13 or Section 15(d) of the Securities Exchange Act of 1934.

LimitedOffering:Anofferingthatisexemptfromregistrationunderthe Securities Act of 1933 pursuant to Section 4(2) or Section 4(6) thereof or pursuant to Rule 504, Rule 505, or Rule 506 thereunder.

ConflictofInterest:Forthe purposes of this Code of Ethics, a “conflict of interest” will be deemed to be present when an individual’s private interestinterferesinanyway,orevenappearstointerfere,withtheinterests of a client, the Firm, or one or more of its affiliates, as a whole.

This Code’s procedures, standards, and restrictions do notandcannotaddresseachpotentialconflictofinterest. Rather,theyattemptto prevent some of the more common types of problems. Ethics and faithful discharge of our fiduciary duties require adherence to the spirit of this Code and activities other than personal securities transactions could involve conflicts of interest. If there isanydoubtaboutatransactionforareportableaccount or for an Employee's personal account, the CCO should be consulted.

PersonalAccountTrading

Personal tradingforanyCoveredAccountshouldneverbeconductedinsuchawayastocreateanyquestionsof “front running,” otherwise taking personal advantage of the tradingactivitythatisconductedfortheFirm,orin any way seeking personal profits at the expense of the tradingconductedfortheFirm.AnAccessPerson’sfirst priority in all trading decisions must be to benefit the Firm’s clients.

PrivateInvestmentFundsandDistributions

Pre-approval of an investment in a private investment fund is required. Moreover, when an Access Person is notified by the Fundofadistributionofsecurities,theAccessPersonmustnotifytheCCOinordertorecordthe manner of acquisition of the securities. Any subsequent sales of such shares aresubjecttothetraderestrictions outlined in this Code.

InitialPublicOfferings

Access Persons must obtain prior written approval before acquiring direct or indirect beneficial ownership (through purchase or otherwise) of a security in an initial public offering. This restriction ensures that Access Persons do not cause a violation of applicable broker-dealer rules relating to new issues.

OtherTradingRestrictions

Itisprohibitedtoengageinanytrading(inapersonalaccountorforJLens)thatviolatesthelaw1.Inaddition,an Access Person may not receive from another party “hot tips,” favored commission rates, or other personal brokerage or other trading benefits in exchange for the employee’s giving the other party Company business, such as allocation of brokerage, oranyotherbenefit.ReceivinggiftsorentertainmentconsistentwiththeFirm’s Gift and Entertainment Policy is permissible, as is attendance at sponsored seminars or conferences within the guidelines contained in that policy,butinallinstances,itisimportanttoavoideventheappearanceofproviding business in exchange for personal

1Forexample,anAccessPersonmaynottradeonthebasisofmaterialnonpublicinformation.

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benefits. Access Persons are restricted as to the purchase and sale of their personal security holdings to the extent that a Fund advised by the Firm holds or is expected to tradethesame security. The Code also contains restrictions on, and procedures designed to help prevent inappropriate trading while JLens is in possession of material nonpublic information.

Prohibited,Dishonest,andUnethicalPractices

Thefollowingactivitiesareexpresslyprohibited:

●Recommending to the Fund the purchase, sale, or exchangeofanysecuritywithoutreasonablegrounds to believe that the recommendation is suitable for the Fund;

●Borrowingorloaningmoneyorsecuritiesfromortoaclientunlesstheclientisabroker-dealer,an affiliate of the Firm, or a financial institution engaged in the business of loaning funds;

●Misrepresentingtoanyclient,orprospectiveclient,thequalificationsoftheAccessPerson,or misrepresenting the nature of the advisory services being offered or fees to be charged for such service;

●Guaranteeingaclientthataspecificresultwillbeachievedwithadvicerendered;

●Engaginginanyact,practice,orcourseofbusinesswhichisfraudulent,deceptive,manipulative,or unethical; or

●Engaging in conduct or any act, indirectly or through or byanyotherperson,whichwouldbeunlawful for such person to do directly under the provisions of the Advisers Act and any rule or order thereunder.

ConflictsofInterest

The Firm has an affirmative duty of care, loyalty,honesty,andgoodfaithtoactinthebestinterestofitsclients. Access Persons must strive to avoid any activity or a personal interest that presents a “conflict of interest.” A conflict of interest may arise if the Access Person's personal interest interferes or appears to interfere with the interests of the Firm or itsclients.AconflictofinterestcanarisewheneveranAccessPersontakesactionorhas an interest that makes it difficult for him/her to perform his/her duties and responsibilitiesattheFirmhonestly, objectively, and effectively.

While it is impossible to describe all of the possible circumstancesunderwhichaconflictofinterestmayarise, below are situations that most likely could result in aconflictofinterestandthatareprohibitedunderthisCode of Ethics:

●Access Persons are prohibited from using knowledge about pending or currently considered securities transactions for clients to profit personally, directly, or indirectly, as a result of such transactions, including by purchasing or selling such securities.

●Access Persons are prohibited from recommending, implementing, or considering any securities transaction for a clientwithouthavingdisclosedanymaterialbeneficialownership,businessorpersonal relationship, or other material interest in the issuer or its affiliates, to the CCO. If the CCO deems the disclosedinteresttopresentamaterialconflict,theAccessPersonmaynotparticipateinany decision-making process regarding the securities of that issuer.

SpreadofFalseInformation

JLens unequivocally prohibits and forbids all Access Persons from communicating or transmitting “false rumors” or other information regarding any Fund, portfolio investment, or any registered security which such Access Person does not know or reasonably believe to be true to any person outside of JLens for any reason.

If the CCO, upon due investigation, finds that any Access Person has engaged in the spread of false rumorsor information as described above, the CCO may recommend sanctions including, but not limited to, dismissalof the person or persons involved and/or reporting of any improper conduct to the SEC or other regulatory authorities.

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GiftsandEntertainment

Access Persons should not accept inappropriate gifts, favors, entertainment, special accommodations, or other things of material value that could influence their decision-making or make them feel beholden to a person or firm. Similarly, Access Persons should not offer gifts, favors, entertainment, or other things ofvaluethatcould be viewed as overly generous or aimed at influencing decision-making or making a client feel beholden to the Firm or the Access Person.

NoAccessPersonmay receive any gift, service, or other thing of more than de minimis value of from any person or entitythatdoesbusinesswithoronbehalfoftheFirm.NoAccessPersonmaygiveorofferanygiftof more than de minimis value to existing clients, prospective clients, or any entity that does business with or on behalf of the Firm without written pre-approval by the CCO. Gifts received from or given to the same source valuedat $100.00 or less will be considered de minimis. Additionally, the receipt of an occasional dinner, a ticket to a sporting event or thetheater,orcomparableentertainmentalsowillbeconsideredtobeofdeminimis value.

NoAccessPersonmaygiveoracceptcashgiftsorcashequivalentstoorfromaclient,prospectiveclient,orany entity that does business with or on behalf of the Firm.

Bribes and kickbacks arecriminalacts,strictlyprohibitedbylaw.AccessPersonsmustnotoffer,give,solicit,or receive any form of bribe or kickback.

PoliticalContributions

SEC Rule 206(4)-5 restricts contributions and solicitation practices of investment advisers and their affiliates. Specifically, the Rule prohibits an investment adviser from providing advisory services to any state or local government entity, for two years,ifthatinvestmentadviserorany“CoveredAssociate”hasmadeacontribution to apublicofficialwhoisinapositiontoinfluencetheawardofthatadvisoryservicecontract.TheRulefurther prohibitsaninvestmentadviser,oraCoveredAssociate,frompayingdirectlyorindirectlyanypersontosolicit a government entity for advisory services onbehalfoftheadviserunlesssuchpersonis:aregisteredinvestment adviserrepresentative,oranexecutiveofficer,generalpartner,managingmemberoranemployeeoftheadviser.

A “Covered Associate”includes:(1)anygeneralpartner,managingmemberorexecutiveofficeroftheFirm,(2) any employee who solicits a governmental entity on behalf of JLens and anyone directly or indirectly supervising such employee, and (3) any political action committee controlled by JLens or one of its Covered Associates.

A “Government Entity”includesallstateandlocalgovernments,agenciesandinstrumentalitiesandgovernment sponsored plans, including public pension plans, 403(b), 457 and 529 plans.

A “Government Official”, for purposes of this Rule, includes an incumbent, candidate or successful candidate for office if the office is directly or indirectly responsible for, or can influence the outcome of, thehiringofan adviser or has the authority to appoint such a person. Theruledoesnotspecifyparticulartypesofofficialswho could influence the hiring of an adviser. Instead, the scope of authority associated with a particular office determines whether such official can ultimately influence the hiring decision.

"Contribution"meansanygift,subscription,loan,advance,ordepositofmoney,oranythingofvaluemadefor:

●thepurposeofinfluencinganyelectionforfederal,state,orlocaloffice;

●thepaymentofdebtincurredinconnectionwithanysuchelection;

●transitionorinauguralexpensesincurredbyasuccessfulcandidateforstateorlocaloffice;or

●charitabledonationsandcontributionstoapoliticalactioncommittee(PAC).

Forpurposesofthispolicy,allAccessPersonsaredeemedtobeCoveredAssociates.

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The Rule does not impose a ban on political contributions made by Covered Associates and/or Promoters/Consultants of an adviser. It is a ban on the adviser’s ability to receive compensation (fees) from a government client who selected the adviser because of direct or indirect payments to an official or other individual or entity that can influence the selection of advisers. The Rule covers individual contributions andalso prohibits a practice known as “bundling,” which is the coordination of contributions or solicitations to officials/candidates who can exert influence over the adviser selection process.

It is the policy of JLens to avoid conflicts of interest or appearances of impropriety in connection with the provision of advisory services for compensation to any government client and to identify risk exposures for JLens and its clients.

In general, the Rule prohibits JLens from receiving compensation for advisory services provided to a state or local government client for a period of two years after any Covered Associates or other employees of JLens make a politicalcontributiontocandidatesorofficialsinapositiontoinfluencethehiringofJLensasanadviser by the state or local government client.Specifically, contributions made by a Covered Associate will be attributed to an adviser if those contributions were made within (i) two years prior to the date the individual became a Covered Associate, in the case of Covered Associates who solicit clients for the adviser or (ii) six months prior to the date the individual became a Covered Associate, in the caseofCoveredAssociateswhodo not solicit clients for the adviser. The Rule also prohibits any Covered Associates or other employees ofJLens from “bundling” (soliciting or coordinating) contributions to elected officials, candidates, or politicalpartiesof state/locality having the ability to exert influence over the selection of investment advisers. Rule 206(4)-5 contains certain “deminimis”exceptionswhichallowCoveredAssociatestomakepoliticalcontributions,inthe aggregate, that do not exceed $350.00 to anyoneofficial,perelection,wheresuchindividualisentitledtovote, and contributions that do not exceed $150.00 to any one official, per election, where such individual is not entitled to vote. The de minimis exceptions are available only for contributions by individual Covered Associates, not the adviser (i.e., JLens).

JLens’ policy requires that all Access Persons, Covered Associates, and Promoters/Consultants obtain prior approval before making any Contributions to a Government Entity or Government Official (as each is defined above) that exceed $50.00 in aggregate in one election cycle by submitting the proposed contribution to theCCO on the Firm’s Political Contribution Pre-approval Form (Appendix 2). The CCO will then determine the corresponding recordkeeping requirements, and whether such political contribution could potentially result in JLens or its sub-advised ETF being disqualified from any current or anticipated advisory engagement.

The CCO shall also monitor political contributions relative to the hiring and termination of Access Persons. Under the Rule, a new Access Person’s political contributions at a previous firm, or a terminated Access Person’s political contributions occurringpriortotermination,mayresultinJLensbeing“banned”fortwoyears from receiving advisory compensation. In certain circumstances, JLens’fiduciarydutytothegovernmentclient could require the Firm to continue providing advisory services without receiving compensation.

Confidentiality

Access Persons mustrespecttheconfidentialityofinformationacquiredinthecourseoftheirworkandmustnot disclose such information, except when they believe they are authorized or legally obliged to disclose the information. They may not use confidential information acquired in the course of their work for their personal advantage. Access Persons must keep all information about clients (including former clients) in strictconfidence, including the client’s identity (unless the client consents), the client’s financial circumstances, the client’s security holdings, and advice furnished to the client by the Firm.

ServiceonaPublicly-TradedCompany’sBoardofDirectorsandOtherOutsideInterests

Access Persons must not serve on the board of directors of publicly traded companies without the prior authorization of the CCO. Any such approval may only be made ifitisdeterminedthatsuchboardservicewill be consistent with

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the interests of the clients and of the Firm, and that such personservingasadirectorwillbe isolated from those making investment decisions with respect to such company by appropriate procedures. A director of a private company may be required to resign, either immediately orattheendofthecurrentterm,if the company goes public during his or her term as director.

Access Persons must obtain prior approval from the CCO for anyoutsidebusinessactivitythatwasnotalready underway at the time this policy was first adopted.Pre-approvalshouldberequestedbysubmittingane-mailto the CCO detailing the contemplated outside activity, anticipated time commitment, compensation, anddisclosure of any potential conflicts of interest associated with the activity.

Anoutsideactivityorinterestmaynever:

●Present a substantialriskofconfusingclientsorthepublicastothecapacityinwhichtheAccessPerson is acting;

●PoseareputationalriskforJLens;

●Inappropriately influence an Access Person’s business dealings orotherwisecreateaconflictofinterest vis-à-vis the interests of JLens or clients; and/or

●InvolveuseofJLens’client,orproprietaryinformation.

On an annual basis, Access Persons must review and certify to outside business activities. SeeAppendix3for the Outside Business Activities Disclosure Form. At all times, the Access Person should ensure that his/her outside business activities do not present a risk of a conflict of interest for JLens, and that the Access Person make it known that, while serving an outside entity, s/he is not acting or providing advice on behalf of JLens. The CCO may require further information concerning any outside activityforwhichanAccessPersonrequests approval, including the number of hours involved and the compensation to be received. The CCO will review each reported outside business activity and decide whether such activity must be restricted, monitored, and/or disclosed by JLens. Access Persons are advised to consulttheCCOwithanyquestionsastowhetheranoutside activity or interest is reportable under this policy.

Case-by-CaseExemptions

Because no written policy can provide for every possible contingency, the CCO may consider granting additional exemptions from certain Prohibitions on a case-by-case basis. Any request for such consideration must be submitted to the CCO in writing. Exceptions will only be granted in those cases in which the CCO determines that granting the request will not create any potential, apparent, or actual conflicts of interest.

PersonalSecuritiesTransactionsProceduresandReporting

1.90-DayHold.Todetermarkettiming,AccessPersonsarerequiredtoholdanyJLenssub-advised ETFs they purchase for a period of 90 days. This restriction applies to accounts for which Access Persons have a direct or indirect beneficial interest, including household members.

2.7-Day Blackout Rule. Access Persons are prohibited fromexecutingatransactiononbehalfof themselves or another Access Person within seven days of any client having a pending buy or sell order/recommendation in the same or an equivalent security and until such time as that order is executed or withdrawn. Individual securities within a client portfolio may not be availablesevendayspriortoexecution.In this case, the Access Person is freetosubmitthetradeforpre-clearanceorexecutethetradeifitisexemptfrom pre-clearance per the terms below. Nevertheless, a personal trade by any Access Person shall not prevent a portfolio from trading in the same or an equivalent security on behalf of clients. However, such a transaction shall be subject to independent reviewbytheCCO.Forexample,ifJLensisrebalancingtheFundandidentifies Apple (AAPL) as a target for the following day’s execution, that security is now under the 7-Day Rule and cannot be purchased until the AAPL trade settles.

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3.Exemptions Related to 90-Day Hold and 7-Day BlackoutRule.Anysecuritythatisnotheld by the Fundisnotsubjecttothe90DayHoldPeriodorthe7-DayBlackoutPeriod.Withrespecttoother90-day holding period requirement waivers, only certain limited exceptions will beapprovedincluding,butnotlimited to, hardships and extended disability. Exceptions must be approved by the CCO prior to execution.

4.Preclearance of Securities. Access Persons must preclear all personal securities transactions with the exception of those identifiedinthelistbelow.Allapprovedordersmustbeexecutedwithin48hoursof preclearanceapproval,unlesstheCCOinstructsotherwise.Ifanyorderisnottimelyexecuted,a request for pre-clearance must be resubmitted. Exceptions to the requirement to resubmit preclearance requests may be granted in advance by the CCO for unusual circumstances.

Thefollowingareexemptfrompreclearance:

●Non-proprietary,open-endedmutualfundsandETFs(e.g.,mutualfundsandETFsnotmanaged, advised, or sub-advised by JLens).

●Broadbasedindexandcommodityoptionsandfutures.

●Fixedincomesecuritieslessthan$100,000overa30-dayperiod.

●Anytransactionsinindividualequitysecurities,withamarketcapof$1billionormore,areexemptfrom pre-trade clearance up to 500 shares.

●Discretionaryaccountsmanagedexternallybyanindependentthirdparty(e.g.,anexternalinvestment adviser with discretionary authority).

●Exceptionsbypriorwrittenapproval.

●Automaticinvestment/withdrawalprogramsandautomaticrebalancingaspartofamodelportfolio managed by JLens.

5.IPOs.Neither Access Persons nor their household members are permitted to purchase or sell Initial Public Offerings (“IPOs”) without prior written approval. Requests may be submitted to the CCO for consideration and must be granted in writing prior to transacting. In such cases, a log of who requested such approval, when it was requested, and whether it was granted or denied is maintained by the CCO.

6.Preclearance Required for Limited Offerings and Private Placements. Securities issued in limited offerings and private placements2 (including investmentsinlimitedpartnershipssuchasbuyout,venture capital, oil and gas,realestate,andhedgefundsorfundsoffunds)mayonlybeacquiredbyanAccessPersonor household member thereof with the advance written approval of the CCO. A request for approval of a private placementorlimitedofferingshouldgenerallybesubmittedatleastoneweekinadvanceoftheproposeddateof investment. An Access Person need not pre-clear any private placement investments in which such Access Person’s only “beneficial ownership” is through the general partner of a Fund sponsored by JLens or its affiliates.Certainlimitedpartnershipinvestmentsmaynotbesecurities,suchasapartnershipcreatedtoinvestin a building. Access Persons are urged to consult the CCO with any questions about limited offerings. Preclearance does not preclude subsequent reporting of transactions.

7.Cryptocurrencies. A cryptocurrency is a digital asset designed to work as a medium of exchange that uses strong cryptography to secure financial transactions, control thecreationofadditionalunits, and verify the transfer of assets. There is some debate astowhethercryptocurrenciesaresecurities.Ifthereisa centralized third party, along with purchasers of a cryptocurrency with an expectation of a return, then the transaction should be considered a securities transaction.Bitcoin is not deemed to be a security because it is decentralized: there is no central party whose efforts are a key determining factor intheenterprise.Inaddition, ether is also not a security because the Ethereumnetworkisalsodecentralized.AccessPersonsarenotrequired to pre-clear, or report transactions or holdings related to cryptocurrencies which are not deemed to be securities.

2APrivatePlacement,alsoknownasanunregisteredoffering,isthepurchaseofanysecurityorofferingexemptfromthe Securities Act of 1933.

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Cryptocurrencies that are deemed to be securities and Initial Coin Offerings (ICOs) are included in thedefinition of a covered security. If there is any question by an Access Person as to whether a security is “covered” under this Code, s/he should consult with the CCO for clarification on the issue before enteringany trade for his/her personal account.

8.Preclearance Required for Option Writing. Access Persons mustpreclearanyoptionwriting with the CCO.

9.Short Selling Restrictions.AccessPersonsandhouseholdmembersareprohibitedfromselling short any security which is owned in a client portfolio.

10.InvestmentClubsareProhibited.AccessPersonsandhouseholdmembersareprohibitedfrom participating in investment clubs.

11.Trustee Arrangements. Access Persons must receive pre-approval from the CCO before accepting a trustee position for any person or entity.

12.Prohibition on Trading Securities on the Restricted Security List. JLens may from time to time establish a Restricted Security List that includes certain securities where JLens has, or may receive,material nonpublic information about such companies because of a special relationship between JLens or an Access Person and such companies or otherwise. No Access Personsorhouseholdmemberthereofcantradeor invest in any securities listed on the Restricted Security List without the prior consent of the CCO. This restriction covers all instruments of the issuer, including equity, debt, and derivative instruments.

IfanyAccessPersonorhouseholdmemberthereofalready holds a security that is on the Restricted Security List and has not received consent from the CCO, such Access Person or household member must continue to hold and may not executeanybuyorsellordersfortherelevantsecurityuntilsuchsecurityisremovedfromthe Restricted Security List. This requirement covers all instruments of the issuer. All Access Persons are responsible for knowing the contents of the Restricted Security List prior toeffectingorsolicitingatransaction in a security. Any Access Person with access to the Restricted Security List is prohibited from disclosing the securities listed on the Restricted Security List to third parties (except household members to facilitate their compliance with this policy) without the authorization of the CCO.

The CCO will determine whether a security should be placed on the Restricted Security List and maintain and update the Restricted Security List, as necessary. The CCO will periodically monitor transactions by Access Persons and their respective household members that are reported to theCCOpursuanttotheCodetoascertain any pattern of conduct which may violate the restriction requirements or evidence front-running, scalping, or other inappropriate behavior.

13.Restrictions on Disclosures. You may not disclose any nonpublic information (whetherornotit is material) relating to JLens orsecuritiestransactionsonbehalfofclientstoanypersonoutsideJLens(unless such disclosure has been authorized by JLens). You may not communicate material, nonpublic information to anyone, including persons within JLens, except as permitted by this Code and related policies outlined in this Manual.All material nonpublic information must be secured. For example, access tofilescontainingmaterial, nonpublic information should be restricted, and conversations containingsuchinformation,ifappropriateatall, should be conducted in a private setting to the extent practicable.Conversations in public places, such as elevators, restaurants, and airplanes,shouldbelimitedtomattersthatdonotpertaintoinformationofasensitive or confidential nature. Disclosure restrictions are not intended to preclude an Access Person’s rights under the Whistleblower Policy, outlined below.

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The CCO will review and consider any properrequestforrelieforexemptionfromanyrestriction,limitationor procedure contained in this Code which you believe will cause you a hardship. The decision of the CCO is completely within his discretion.

EachAccessPersonissolelyresponsibleforanyviolationofthisCodebyahouseholdmemberthereof.

Pre-ClearanceProcedure

For any activity where it is indicated in the Code of Ethics that pre-clearance is required, the followingprocedure must be followed:

●Pre-clearance requests must be submitted by the requesting Access Person to the CCO in writing (see Appendix 4 for the Pre-Approval Form: Personal Securities Transaction).Therequestmustdescribein detail what is being requested and any relevant information about the proposed activity.

●The CCO will respond in writing to the request as quickly as is practical, either giving an approval or declination of the request, or requesting additional information for clarification.

●Pre-clearance authorizations expire 48 hours after the approval, unless otherwise noted by the CCOon the written authorization response.

●Records of all pre-clearance requests and responses will be maintained by the CCO for monitoring purposes and ensuring the Code of Ethics is followed.

ReportingRequirements

InitialPersonalSecuritiesAccountReport

No later than ten (10) days after the person becomes an Access Person and annually thereafter, every Access Person must file a personal securities account report containing the information specified in Appendix 5, the Personal Securities Account Certification.

InitialandAnnualHoldingsReports

No later than ten (10) days after the person becomes an Access Person and annually thereafter, every Access Person must file a holdings report containing the following information:

●The title, exchange ticker symbol or CUSIP number, type of security, number of shares and principal amount of each Reportable Security in which the Access Person had any direct or indirect beneficial ownership when the person becomes an Access Person;

●The name of any broker, dealer, or bank with whom the Access Person maintainedanaccountin which any securities were held for the direct or indirect benefit of the Access Person; and

●ThedatethatthereportissubmittedbytheAccessPerson.

See Appendix 6 for thePersonalHoldingsCertification.Theholdingsreportsmustbecurrentasofadate notmorethan45dayspriortotheindividualbecominganaccessperson(inthecaseofaninitialreport)or the date the report is submitted (in the case of an annual report).

QuarterlyReports

Nolaterthanthirty(30)daysaftertheendofcalendarquarter,everyAccessPersonmustfiletransaction reports containing the following information:

●Foreachtransactioninvolving a Reportable Security in which the Access Person had, or as a result of the transaction acquired, any direct or indirect beneficial ownership, the Access Person must provide the date of the transaction,thetitle,exchangetickersymbolorCUSIPnumber,type of security, the interest rate and maturity date (if applicable), number of shares and principal amount of each involved in the transaction;

●Thenatureofthetransaction(e.g.,purchase,sale)

●Thepriceofthesecurityatwhichthetransactionwaseffected;

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●Thenameofanybroker,dealer,orbankwithorthroughthetransactionwaseffected;and

●ThedatethatthereportissubmittedbytheAccessPerson.

See Appendix 7 for the Quarterly Personal Securities Transactions Report. Access Persons may use duplicate brokerage confirmations and account statements, providedthatalloftherequiredinformationis contained in those confirmations and statements, and the Access Person submits Appendix 6 confirming that JLens is in receipt of all confirmations and statements.

ExceptionsfromReportingRequirement

Initial, annual, and quarterly reporting is not required for any account over which an Access Person or a household member has no direct or indirect influence orcontrol.However,eachAccessPersonmustreportthe existence of such an account to the CCO. The CCO has the authority to request further information and documentation from you regarding any accountoverwhichyouclaimtohavenoinfluenceorcontrol,including to direct the adviser or broker to the account to provide an affirmative certification that the Access Person or household member has no direct orindirectinfluenceorcontrol.EachAccessPersonmustcertifyannuallythat he or she, or a householdmemberwhenapplicable,doesnothavedirectorindirectinfluenceorcontroloverthe account.If the Access Person’s level of discretion changes relative to a non-discretionary account, the CCO must be notified immediately. All related documentation pertaining to a personal account exemption will be maintained by the CCO pursuant to JLens’ Books and Records policy.

The reporting requirements of this sectionofthisCodeofEthicsdonotapplytotransactionreportswithrespect to transactions effected pursuant to an automatic investment plan, including dividend reinvestment plans.

The reporting requirements of this section of thisCodeofEthicsdonotapplytotransactionreportsifthereport would contain duplicate informationcontainedinbrokertradeconfirmationsoraccountstatementsthattheFirm holds in its records so long as the Firm receives the confirmations or statements no later than 30daysafterthe end of the applicable calendar quarter.

Furthermore, accounts restricted solely to the purchase andsaleofmutualfunds(toincludeETFs),529College SavingsPlans,and403b/401kplansarenotsubjecttothispolicyanddonotrequiredisclosureorquarterly reporting. However, if the accounts described above can trade othersecurities,(e.g.,individualequitynamesor the Fund), those accounts are subject to the policy even if they hold only mutual funds.

ResponsibilitytoReport

All reports must be filed with the CCO or her named designee. The responsibility for taking the initiative to report is imposed on each Access Person required to make a report. Any effort by the CCO to facilitate the reporting process does not change or alter that responsibility. Any Access Person who hasfailedtoprovidethe referenced information by the prescribed deadline will be deemed to have violated JLens’ Code of Ethics and may be subject to disciplinary action.

MonitoringofPersonalSecuritiesTransactions

The Firm is required by the Advisers ActtoreviewAccessPersons’personalsecuritiestransactionsandreports periodically.TheCCOisresponsibleforreviewingthese.Toavoidself-reviewiftheCCOisnottheonlyAccess Person, another officer of the Firm is responsible to review transactions and reports and approve pre-clearance requests submitted by the CCO.

Confidentiality

Access Persons must report personal securities accounts and holdings to the CCO as outlined herein. It is the intent of the CCO to regard and preserve information pertaining to Access Personpersonaltradingactivitiesas confidential in nature. However, incertaincircumstances,JLensmaybeauthorizedtodisclosesuchinformation as required by law

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enforcement or regulatory inquiry and under any circumstances wherein JLens deems disclosure to be reasonably necessary to prevent fraud, unauthorized transactions, liability, or to respond to judicial process or subpoena.

CertificationofCompliance Initial Certification

The Firm is required to provide all AccessPersonswithacopyoftheCode.AllAccessPersonsaretocertifyin writingthattheyhave:(a)receivedacopyoftheCode;(b)readandunderstandallprovisionsoftheCode;and

(c)agreedtocomplywithitsterms.

AcknowledgementofAmendments

TheFirmmustprovideAccessPersonswith any amendments to the Code and Access Persons must submit a written acknowledgement that they have received, read, and understood the amendments to the Code.

AnnualCertification

All Access Persons must annually certifythattheyhaveread,understood,andcompliedwiththeCodeofEthics and that the Access Persons has made all of the reports required by the Code and has not engaged in any prohibited conduct.

TheCCOwillmaintainrecordsofthesecertificationsofcompliance.

ReportingViolations

All Access Persons must report violations of the Firm’s Code of Ethics promptly to the CCO. If the CCO is involvedintheviolationorisunreachable,AccessPersonsmayreportdirectlytoaFirmPrincipal.Allreportsof violations will be treated confidentially to the extent permitted by law and investigated promptly and appropriately. Persons may report violations of the Code of Ethics on an anonymous basis. Examples of violations that must be reported are (but are not limited to):

●noncompliancewithapplicablelaws,rules,andregulations;

●fraudorillegalactsinvolvinganyaspectoftheFirm’sbusiness;

●materialmisstatementsinregulatoryfilings,internalbooksandrecords,clientsrecordsorreports;

●activitythatisharmfultoclients;and/or

●deviationsfromrequiredcontrolsandproceduresthatsafeguardclientsandtheFirm.

Noretributionwillbetakenagainst a person for reporting, in good faith, a violation or suspected violation of this Code of Ethics. Retaliation against an individual who reports a violation is prohibited and constitutes a further violation of the Code. (See also the JLens Whistleblower Policy maintained in the Compliance Manual.)

ComplianceOfficerDuties Training and Education

The CCO is responsible for training and educating Access Persons regarding the Code. Training will occur as needed and all Access Persons are required to attend any training sessions or read any applicable materials in accordance with CCO direction.

Recordkeeping

TheCCOwillensurethattheFirmmaintainsthefollowingrecordsinareadilyaccessibleplace:

●AcopyofeachCodeofEthicsthathasbeenineffectatanytimeduringthepastsixyears3;

●ArecordofanyviolationoftheCodeandany action taken as a result of such violation for six years from the end of the fiscal year in which the violation occurred;

3Althoughtherecordretentionperiodforinvestmentadvisersisgenerallyfiveyears,theperiodisextendedtosixyearsto accommodate record retention requirements for the Fund under the 1940 Act.

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●A record of all written acknowledgements of receipt of the Codeandamendmentsforeachpersonwhois currently, or within thepastsixyearswas,anAccessPerson.Theserecordsmustbekeptforsixyears after the individual ceases to be an Access Person of the Firm;

●Holdings and transactions reportsmadepursuanttotheCode,includinganybrokerageconfirmationand account statements made in lieu of these reports;

●Alistofthenamesofpersonswhoarecurrently,orwithinthepastsixyearswere,AccessPersons;

●A record of any decision and supporting reasons for approving the acquisition of securities by Access Persons in initial public offerings and limited offerings for at least six years after the end of the fiscal year in which approval was granted;

●A record of any decisions that grant employees or Access Persons a waiver from or exception to the Code.

AnnualReview

TheCCOwillreviewatleastannuallytheadequacyoftheCodeofEthicsandtheeffectivenessofits implementation.

Sanctions

Any violationsdiscoveredbyorreportedtotheCCOwillbereviewedandinvestigatedpromptly.Suchreport will include the corrective action taken and any recommendation for disciplinary actiondeemedappropriate by the CCO. Such recommendation will be based on, among other things, the severity of the infraction, whether it is afirstorrepeatoffense,andwhetheritispartofapatternofdisregardfortheletterandintentof this Code of Ethics. The CCO may impose such sanctions for violation of this Code of Ethics, as hedeems appropriate, including, but not limited to:

●Letterofcensure;

●Suspensionorterminationoftheemployment;

●Reversalofasecuritiestradeattheviolator’sexpenseandrisk,includingdisgorgementofanyprofit; and/or

●Referraltolawenforcementorregulatoryauthoritiesinseriouscases.

InsiderTrading

It is the policy of JLens that noAccessPersonmayengageinwhatiscommonlyknownas“insidertrading.” Specifically, the Firm prohibits:

●Trading, either in a Reportable Account or on behalfofanyotherperson(includingclientaccounts), on the basis of material nonpublic information; or

●Communicatingmaterialnonpublicinformationtoothersinviolationofthelaw.

InsiderTradingPolicy

Section 204A of the Advisers Act requires every Investment Adviser to establish, maintain, and enforce written policies andproceduresreasonablydesignedtopreventthemisuseofmaterial,nonpublicinformation by such Investment Adviser or any AccessPersonwithsuchInvestmentAdviser.InaccordancewithSection 204A of the Act, the Firm has instituted procedures to prevent the misuse of nonpublic information.

Inthepast,securitieslawshavebeeninterpretedtoprohibitthefollowingactivities:

●Tradingbyaninsiderwhileinpossessionofmaterialnonpublicinformation;or

●Trading by a non-insider while in possession of material nonpublic information, where the information was disclosed to the non-insider in violation of an insider’s dutytokeepitconfidential; or

●Communicatingmaterialnonpublicinformationtoothersinbreachofafiduciaryduty.

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WhoIsCoveredbythePolicy

This policy covers all oftheFirm’sAccessPersonsaswellasalltransactionsinanysecuritiesparticipatedin by family members, trusts, or corporations directly or indirectly controlled by such persons. Inaddition,the policy applies to transactions engagedinbycorporationsinwhichtheAccessPersonisanofficer,directoror 10% or greater stockholder and a partnership of which theAccessPersonisapartnerunlesssuchpersonhas no direct or indirect control over the partnership.

MaterialInformation

Individualsmaynotbeheldliablefortradingoninsideinformationunlesstheinformationismaterial. Advance knowledge of the following types of information is generally regarded as material:

●Dividendorearningsannouncements

●Write-downsorwrite-offsofassets

●Additionstoreservesforbaddebtsorcontingentliabilities

●Expansionorcurtailmentofcompanyormajordivisionoperations

●Merger,jointventureannouncements

●Newproduct/serviceannouncements

●Discoveryorresearchdevelopments

●Criminal,civilandgovernmentinvestigations,andindictments

●Pendinglabordisputes

●Debtserviceorliquidityproblems

●Bankruptcyorinsolvencyproblems

●Tenderoffers,stockrepurchaseplans,etc.

●Recapitalization

Information provided by a companycouldbematerialbecauseofitsexpectedeffectonaparticularclassofa company’s securities, all of the company’s securities, the securities of another company, or the securities of several companies. The misuse of material nonpublic information appliestoalltypesofsecurities,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.

NonpublicInformation

In order for issues concerning insider trading to arise, information must not only be material, but also nonpublic as well.

Once material, nonpublic information has been effectively distributed to the investing public, it isnolonger classified as material, nonpublic information. However, thedistributionofnonpublicinformationmustoccur through commonly recognizedchannelsfortheclassificationtochange.Inaddition,theinformationmustnot only be publicly disclosed, but there must also be adequate time for the public to receive and digest the information. Lastly, nonpublic information does not change to public information solely by selective dissemination.

Access Persons must be aware that even when there is no expectation of confidentiality, a person may become an insider upon receiving material, nonpublic information. Whether the “tip” made to the Access Person makes such person a “tipee” depends on whether the corporate insider expects to benefit personally, either directly or indirectly, from the disclosure.

“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. Access Persons may also become insiders or

17

“tipees” if they obtain material, nonpublic information by happenstance, at social gatherings, by overhearing conversations, etc.

FairDealingvs.Self-Dealing

Access Persons must act in a mannerconsistentwiththeobligationtodealfairlywithallclientswhentaking investment action. The Firmwillnottolerateself-dealingforpersonalbenefitorthebenefitoftheFirmatthe expense of clients.

FrontRunning

“Front running” and “scalping” refer to the buying or selling of securities in a Reportable Account, priorto clients, in order to benefit from any price movement that may be caused by clienttransactionsortheFirm’s recommendations regarding the security. It also includes buying or selling options, rights, warrants, futures contracts, convertible securities, or other securities that are related to a security in which clients may affect transactions or which the Firm may make recommendations. The Firm strictly prohibits front running andany other form of market manipulation.

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APPENDIX1

CODEOFETHICSCERTIFICATION

1.The undersigned Access Person with JLens hereby acknowledges, certifies, represents, warrants, and agrees as follows:

2.He or she hasreceivedacopyoftheJLensCodeofEthicsandhasreadandunderstandstheinformation contained therein.

3.Heorshewill abide by: (i) all rules, restrictions, policies, and procedures described in the Code of Ethics (as amended from time to time); and (ii) all covered laws applicable to him or her (as amended from time to time), whether in connection with his or her activities on behalf of JLens or otherwise.

4.Ifapplicable,heorshe has complied with JLens’ Code of Ethics since the last date on which such person signed and delivered this Certification (or its predecessor form) to JLens.

5.He or she understands that any violation of JLens’ Code of Ethicsbyhimorhermayleadtosanctions, including the termination of his or her employment with JLens or other dismissal.

6.He or she understands that nothing contained in JLens’ Code of Ethics affects in any way the at-will nature of his or her employment with JLens, which JLens may terminate at any time for any reason without penalty or other payment except as required by law or written agreement.

Access Person Name (print)	Date
Access Person Signature

*ImportantNote:TheCCOhasdiscretiontorelyupone-mailorDocuSignattestationinlieuofsignatures.

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APPENDIX2

POLITICALCONTRIBUTIONPRE-APPROVALFORM

Name:

Title/Position:

HomeAddress:

City, County, State, Zip Code: Checkatleastoneofthefollowing:

IamrequestingapprovaltomakeaPoliticalContribution.

(CompletePart1)

IamrequestingapprovaltovolunteerforaCampaign. (Complete Part 2)

IamrequestingapprovaltoCoordinateorSolicitContributions,includingFundraising (Complete Part 2)

By signing below, Icertifythatthepoliticalcontributionoractivitydescribedintheattachedisaccurate,andthe proposed contribution or activity is not made to influence or induce the obtaining/retaining of investment advisory services business for JLens or its affiliates.

Signature:Date:

Part1orPart2mustaccompanythisform

[ChiefComplianceOfficerApproval/Disapproval]

Approval:Date:

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Part1

DescriptionofPoliticalContribution

ProposedAmountofContribution:$

Payableto:

IfContributionIsIn-KindorOtherThanCashorCheckIndicateItsNature:

ListPreviousContributionstothisCandidate/PoliticalOrganization(DatesAndAmounts):

IstheContributiontobemadetoaPAC?

Ifyes,providename/type/jurisdictionofPAC

IfContributionistoaCandidate,Officeholder,orCampaign,ProvidetheInformationBelow: Name of Candidate/Officeholder:

AreYouEntitledToVoteforThisCandidate/Officeholder:    Yes No

DateofElection:

TypeofElection(Primary,General,SpecialorRun-off):

OfficeCandidate/OfficeholderSeeks:

JurisdictionofOfficeSought(City,County,State,Federal):

OfficeCandidate/OfficeholderCurrentlyHolds,ifany:

JurisdictionofOfficeCandidate/OfficeholderCurrentlyHolds(City,County,State,Federal):

IfContributionistoaPoliticalOrganization(suchasaPoliticalPartyorPAC),ProvidetheInformationBelow: Name of Organization:

TypeofOrganization:PoliticalParty:    PAC:     Other:

Jurisdiction Covered by Organization (City, County, State, Federal):

IfRecipientisaPoliticalParty,AreYouEntitledtoVoteintheAboveJurisdiction: Yes No

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Part2

DescriptionofVolunteerActivity/SolicitationorCoordinationofContributions,orFundraising

NameofBeneficiary(Officeholder,Candidate,Campaign,PoliticalParty,PoliticalOrganizationBenefiting from Volunteer Activity, or Solicitating or Coordinating Contributions or Fundraising):

Type of Beneficiary (Check One): Candidate/Officeholder/Campaign

Political Party

PAC

Other

OfficeCandidateSeeksandJurisdiction,ifapplicable:

OfficeCandidateCurrentlyHolds,ifany,andJurisdiction:

(1)DescribeNatureofActivity:

(2)HowManyHoursDoYouExpecttoDevotetoActivity?

(3)WillYouEngageInVolunteerActivityDuringWorkingHours?    Yes No

IfYes,howmanyhours?

(4)WillYouUseCompanyResources(SuchAsOfficeSpace,Personnel,Secretary,Equipment,Phones, Copiers or Computer)?Yes     No

IfYes,describeindetail:

(5)WillYouMakeExpendituresFromPersonalFundsinConnectionWithActivity?Yes No

IfYes,describeindetail:

(PleasenotethatsuchpersonalexpendituresmaybeapoliticalcontributionrequiringaseparatePre-Approval request to be submitted on Part 1)

(6)WillActivityInvolveSolicitingorCoordinatingContributions,orFundraising?    Yes No

IfYes,describeindetail:

(7)IfRecipientisaCandidate'sCampaign,ProvideAdditionalInformationBelow:

TypeofElection(Primary,General,SpecialorRun-off): Date of Election:

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APPENDIX3

OUTSIDEBUSINESSACTIVITIESDISCLOSUREFORM

CheckOne:NewDisclosureUpdatedDisclosureRemoveDisclosure

Access Persons who engage in any outside business activity, with orwithoutcompensation,mustcompleteand submit this form to the CCO for review and approval.See the Code of Ethics for complete information.

An outside business activity includes any business activity that is outside the scope of JLens’ business. Such business activity includes acting as a proprietor,partner,officer,director,trustee,consultant,landlord,orhaving anyfinancialinterestinanotherbusinessororganization.Anoutsidebusinessactivityalsoincludes non-compensated positions for which you have a fiduciary duty (i.e. president, treasurer, trustee, power of attorney, charitable or other office positions for a nonprofit board). While an outside business activitydoesnot include passive investments, exception might apply by virtue of their nature, position,percentageofownership or control or obligations with respect to that activity.

Failure to promptly disclose an outside business activity could result in disciplinary actions including termination.You must utilize this Outside Business Activity DisclosureFormtodiscloseanyactivitytoJLens. Your disclosure must be both accurate and complete to be considered for review.

Intheeventthatyouhaveanychangeinyouroutsidebusinessactivityprofile,youmustupdatethisform promptly and forward it to the CCO for review and final updating.

Iunderstanditismyobligationtopromptlyupdateanychangesinmyoutsidebusiness activities. Please Initial, Sign and Date:

IDONOTengageinanyoutsidebusinessactivities.

IDOengageinthefollowingoutsideactivities:

Descriptionofoutsideactivities,includingdetailsrelatedtotimespentandcompensationreceived(listall that apply; attach separate page(s) if needed):

Access Person Name (print) Date Signature

ChiefComplianceOfficerApprovalSignatureDate

*ImportantNote:TheCCOhasdiscretiontorelyupone-mailorDocuSignattestationinlieuofsignatures.

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APPENDIX4

PRE-APPROVALFORM:PERSONALSECURITIESTRANSACTION

Page1of2

This form must be submitted prior to executing a transaction in personal securities (with some exceptions), a private placement, limited offering, sub-advised ETF, or any othertransactiontheAccessPersonbelievescould cause a conflict or compliance violation. IPOs are prohibited. See the Code of Ethics for details.

IRRESPECTIVE OF APPROVAL BY THE CHIEF COMPLIANCE OFFICER,NOEMPLOYEEMAY EXECUTE ANY SECURITIES TRANSACTION WHILE IN POSSESSION OF INSIDE INFORMATION.SEETHEADVISER’SCODEOFETHICSFORINFORMATIONABOUTINSIDER TRADING AND NON-PUBLIC INFORMATION.

Whether or not an Access Person has “inside information”, no employee may “trade ahead” of a client or execute any transaction which might in any respect disadvantage a client account or resultinanAccessPersonin any respect profiting from a transaction executed or positions held for a client.

Name as it appears on the Account:

AccountNumber:

Issuer:

Equity Investments:    □ Common    □Preferred Number of shares:    

Debt Investments:        □ Public        □Private Interest rate:    

Maturitydate:

LimitedOffering:

Pleaseprovidedetails:

Describewhetherandwhythisinvestmentwouldorwouldnotbesuitableforaclient: Transaction Type (please check):

□Purchase

□Sale

Estimated Trade Date:Estimated Price:

Broker/Dealer:

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APPENDIX4

PRE-APPROVALFORM:PERSONALSECURITIESTRANSACTION

Page2of2

Istheinvestmentalimitedoffering?	□Yes	□No
Istheinvestmentaprivateplacement?	□Yes	□No
Ifyes,willtheprivateplacementinvestincorporatedebtorequity?		□Yes	□No
Ifyes,willyoutakeanactiveroleinthemanagementofinvestments?		□Yes	□No

RepresentationandSignature:

Byexecutingthisform,Irepresentthattheinformationcontainedhereinisaccurateandcompleteandthatmy trading in this investment is not based on any material nonpublic information.

Access Person Name	Date
Access Person Signature

Compliance Approval:Date:

Duration of preclearance approval:

APPROVAL OF A TRADEDOESNOTMEANTHATJLENSINANYRESPECTRECOMMENDSOR ENDORSES SUCH TRANSACTION. THIS APPROVAL IS ONLY VALID UNTIL THE LAST DATE LISTED ABOVE. FURTHERMORE, THIS APPROVAL IS NOT VALID IF ANY OF THE INFORMATION LISTED ABOVE CHANGES OR SHOULD THE ASSOCIATED PERSON COME INTO POSSESSION OF “INSIDE INFORMATION”.

*ImportantNote:TheCCOhasdiscretiontorelyupone-mailorDocuSignattestationinlieuofsignatures.

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APPENDIX5

PERSONALSECURITIESACCOUNTCERTIFICATION

Tobecompleteduponemployment,promptlyuponanychangesandannuallythereafter

CheckOne:NewDisclosureUpdated Disclosure Annual Disclosure

AccessPersonName(print):

Date of Report:

Checkoneofthefollowingasapplicable:

    Idonothaveanypersonalsecuritiesaccountstodisclose.

    Ihavepersonalsecuritiesaccountstodisclosewhicharelistedbelow.

Listed below are personal securitiesaccountswhichIorahouseholdmemberhavebeneficialinterestasdefined in the JLens Personal Trading Policy.Attach additional sheets if necessary.

Type of Account (e.g. brokerage, IRA) Name of Account Relationship to me (e.g. self, spouse) Financial Institution (e.g. Schwab, E-Trade) Account Number

Access Person Signature:     Date:

ChiefComplianceOfficerApprovalSignatureDate

*ImportantNote:TheCCOhasdiscretiontorelyupone-mailorDocuSignattestationinlieuofsignatures.

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APPENDIX6

PERSONALHOLDINGSCERTIFICATION

Tobecompleteduponemployment,uponanychangesandannuallythereafter

Name of Access Person (print):

CheckOne:NewDisclosure Updated Disclosure Annual Disclosure

Please list all other personal holdings in which you have a financial interestoroverwhichyouexercisecontrol that have not otherwise been disclosed to JLens or check the box below stating you donothaveanyadditional holdings to disclose.

NAMEOFHOLDING,	BROKERAGEFIRMOR	ACCOUNTNUMBER	STATEMENTS
AMOUNTOWNED AND	CUSTODIAN	ANDNAMEON	SENTTOCCO?
DATE ACQUIRED		ACCOUNT(If	(Yes/No//N/A/Will
		applicable)	be Arranged)

Attachadditionalsheetsifnecessary.

OR

 I do not have any additional personal holdings to disclose (check here only if this applies).

Access Person Signature:	Date:
Chief Compliance Officer Approval Signature	Date

*ImportantNote:TheCCOhasdiscretiontorelyupone-mailorDocuSignattestationinlieuofsignatures.

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APPENDIX7

QUARTERLYPERSONALSECURITIESTRANSACTIONSREPORT

Page1of2

The Code of Ethics and SEC regulations requirethateachAccessPerson(definedatRule204A-1(e)(1))report, within 30 days of the end of each calendar quarter, any personal securities transactions in any account of the Access Person, oranyaccountinwhichtheAccessPersonoranyimmediatefamilyorhouseholdmember,hasa direct or indirect pecuniary interest. If the Access Person hasarrangedfortheCCOorotherdesigneetoreceive copies of brokerage statementsforallcoveredaccounts,thensuchbrokeragereportswillnegatetheneedforthe Access Person to separately complete this quarterly transaction report. If the Access Person has arranged for JLens to receive copies of brokerage statements for all covered accounts, the use of thisformwouldbelimitedto reporting transactions in private offerings which are transacted outside of brokerage accounts.

Quarter ending:

YES, I had reportable personal securities transactionswithinthepastquarterasreportedon(checkallthat apply):

theattachedpage/ormonthlybrokeragestatements

confirmations/statementssentdirectlybymybroker-dealertotheFirm

the attached report

NO,Ihadnoreportablepersonalsecuritiestransaction(s)inthepastquarter.

Thisreportistobesigned,dated,andreturnedtotheCCO,within30daysofquarter end.

Access Person Signature
Print Name*	Date
Chief Compliance Officer Signature	Date

*ImportantNote:TheCCOhasdiscretiontorelyupone-mailorDocuSignattestationinlieuofsignatures.

28

APPENDIX7

QUARTERLYPERSONALSECURITIESTRANSACTIONSREPORT

Page2of2

Transactionsdonotneedtobereportedfor:

●AnyaccountinwhichtheAccessPersonhasnodirectorindirectinfluenceorcontrol;

●DirectobligationsoftheU.S.Government,e.g.,U.S.Treasurybills,notes,andbonds;

●Highqualityshort-terminstruments,e.g.,U.S.bankcertificatesofdeposit,bankers’acceptances,and commercial paper;

●Open-endinvestmentcompanies,i.e.,mutualfundsunlessJLens,oranaffiliatedcompanyactsas investment adviser, sub-adviser, or principal underwriter to the mutual fund(s);

●529Plans,unlessJLensoracontrolaffiliatemanages,distributes,markets,orunderwritesthe529Plan or the investments (including a fund that is defined as a reportable fund under Rule 204A-1) and strategies underlying the 529 Plan that is a college savings plan; and

●Unitsofunitinvestmenttrusts,solongastheunitinvestmenttrustisneithermanagedbyJLens,any affiliate of JLens, nor invested in affiliated mutual funds.

Account	TradeDateand	Transaction	Nameof	Ticker	Interest	Principal	Broker
Identification	Transaction	Price and	Security	or	Rate	Amount
Information	Type	Numberof		CUSIP	and
(Name/#)	(Buy/Sell)	Shares			Maturity
					Date

The reporting or recording of any such transaction shouldnotbeconstruedasanadmissionyouhaveanydirect or indirect beneficial ownership in the security reported.

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