APPENDIX 1 CODEOFETHICS

MOONVEST, LLC

I.DEFINITIONS

“Access Person” is a Supervised Person (defined below) who has access to non-public information regarding clients' purchase or sale of securities, is involved in making securities recommendations to clients or who has access to such recommendations that are non-public. A Supervised Person who has access to non-public information regarding the portfolio holdings of affiliated mutual funds is also an Access Person.

“Beneficial Ownership” - Access Persons are considered to have beneficial ownership of securities if they have or share a direct or indirect beneficial interest in the securities. Access Persons have a beneficial interest in a security if they have the ability to profit from a transaction directly or indirectly in such security. Examples of a beneficial interest in securities include the following:

•Securities held by members of an Access Person’s 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;

•An Access Person’s interest as a general partner or limited partner in securities held by a general or limited partnership; and

•AnAccessPerson’sinterestasamanager/memberinthesecuritiesheldbyanLLC.

An Access Person does not have a beneficial interest in securities held by entities in which he or sheholdsanequityinterest(e.g.,theportfolioholdingsofamutualfundofwhichanAccessPerson owns shares) unless he or she is a controlling equity holder or shares investment control over the securities held by the entity.

“Covered Securities” shall mean any financial instrument that is known as a security and as defined in detail in Section 202(a)(18) of the Advisers Act, EXCEPT, for purposes of this Code, itdoesnotincludesecuritiesissuedbytheU.S.Government,bankcertificatesofdeposit,bankers’ acceptance, commercial paper, high quality short-term debt instruments, money market instruments, or shares of registered open end investment companies (mutual funds) as long as Moonvest is not advising such mutual funds.

“Immediatefamilymember”isanychild,stepchild,grandchild,parent,stepparent,grandparent, spouse, sibling, father-in-law, mother-in-law, son-in-law, daughter-in-law, sister-in-law, brother- in-law (including adoptive relationship). If the immediate family member resides in the same householdas theemployee,theyaresubjectto Moonvest’s personalsecurities tradingreporting requirements.

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“Limited Offering” means an offering that is exempt from registration under the Securities Act of1933pursuanttosection4(a)(2)orsection4(a)(5)(15U.S.C.77d(a)(2)or77d(a)(5))orpursuant to §§ 230.504 or 230.506 of this chapter.

“Material non-public information” (“MNPI”) is information about a company that has not yet been made public, for which there is a substantial likelihood that a reasonable investor would consider important in making his or her investment decisions, or information that is reasonably certaintohaveasubstantialeffectonthepriceofacompany'ssecuritieswereittobedisclosedin the public domain.

“Supervised Person” is defined as any partner, officer, director (or other person occupying a similar status or performing similar functions), or employee of Moonvest or other person who provides investment advice on behalf of Moonvest and is subject to the supervision and control of Moonvest.

II.GENERALPROVISIONS

AllSupervisedPersonsofMoonvestaredeemed “AccessPersons”andarethereforesubject totheCodeofEthicsanditsrelatedpolicies.

The Code of Ethics makes reference to certain Appendices which are filed through Hadrius. The Appendices included in this Code are provided for reference purposes only and may be modified for actual use in Hadrius at the discretion of the CCO. Questions about the form of reporting under this Compliance Manual and Code of Ethics should be directed to the CCO.

Moonvest has adopted the following polices and rules of conduct (“Code”) for all Supervised Persons.TheCodeisdesignedtoensurethatthehighethicalstandardsmaintainedby Moonvest areconsistentlyapplied.TheexcellentnameandreputationofMoonvestcontinuestobeadirect reflection of theconductof each Supervised Person.TheCoderequires allSupervised Persons to comply with applicable federal securities laws.

TheCodeisbasedupontheprinciplethatMoonvest,anditsSupervisedPersonsoweafiduciary duty to its Clients and that Moonvest and its Supervised Persons must conduct their affairs, including theirpersonalsecuritiestransactions, insucha manner asto avoid (i) serving their own personalinterestsaheadofClients,(ii)takinginappropriateadvantageoftheirpositionwithMoonvest, and (iii) abusing their position of trust and responsibility.In meeting its fiduciary responsibilities,MoonvestexpectseverySupervisedPersontodemonstratethehigheststandards of ethical conduct.Compliance with the provisions of the Code, the Advisers Act and all applicable federal securities laws shall be considered a basic condition of employment and association with Moonvest.

Pursuant to Section 206 of the Advisers Act, both Moonvest and its Supervised Persons are prohibitedfromengaginginfraudulent,deceptive,ormanipulativeconduct.Compliancewiththe Codeinvolvesmore than actingwithhonesty andgoodfaith alone.It meansthatMoonvest has an affirmative duty of utmost good faith to act solely in the best interest of Clients.

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Moonvest recognizes that no single policy or governance statement can address all potential scenarios whereby Supervised Persons are challenged to comport themselves in an appropriate manner.Tothisend,theprovisionsoftheCodearenotall-inclusive.Rather,theyareintendedas aguide forSupervisedPersonsin their conduct.SupervisedPersonsareurged to seek the advice of the CCO for any questions about the Code, the application of the Code to their individual circumstances,andparticularlyinanysituationwhereanySupervisedPersonmaybeuncertainas to the intent or purpose of the Code.Supervised Persons should also understand that a material breach of the provisions of the Code may constitute grounds for disciplinary action, including termination of employment and/or association with Moonvest.

AllSupervisedPersonsmustpromptlyreportanysuspectedorapparentviolationsofthisCodeto the CCO.The CCO shall consider reports made to them hereunder and shall determine whether theCodehasbeenviolatedandwhatsanctions,ifany,shouldbeimposed. TheCCOwillaggregate and report all violations of the Code of Ethics or other compliance policies in the annual compliance program review report. Supervised Persons will not be subjected to any form of retaliation for reporting legitimate suspected or actual concerns or abuses.

III.INSIDERTRADINGPREVENTION

Background

Trading securities (including equity and debt securities and derivative instruments), either personally or on behalf of others, while in possession of material, non-public information, or improperlycommunicatingthatinformationtoothers,isreferredtoas“insidertrading.”Insider trading is a violation of federal securities statutes and therefore is a prohibited activity by MoonvestandeachofitsSupervisedPersonsandagents.Moonvestabsolutelyforbidsinsider trading.

In addition to subjecting Moonvest to potential penalties, Supervised Persons may face severe penalties if trading securities while in possession of material non-public information, or if improperly communicatingnon-publicinformation toothers.Theconsequences ofillegalinsider trading include:

•Moonvestmayterminateyouremploymentand/orassociationwithMoonvest;

•Youmaybesubjecttocriminalsanctionswhichmayincludefines,penaltiesand imprisonment;

•TheSECcanrecoveryourprofitsgainedorlossesavoidedthroughillegaltradingand impose a penalty of up to three times the profit from the illegal trades;

•TheSECmayissueanorderpermanentlybarringyoufromthesecuritiesindustry;and

•Clients and theissuer’sshareholders may sueyou,seekingto recoverdamages forinsider trading violations.

Insidertradinglawsprovideforpenaltiesagainst“controllingpersons”ofindividualswhoengage in insider trading. Accordingly, under certain circumstances, asupervisor of aSupervised Person who is found liable for insider trading may also be subject to penalties.

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Supervised Persons must notify the CCO immediately if there is any reason to believe that a violation of Moonvest’s insider trading policy has occurred or may occur.

ProhibitiononInsider Trading

Buying or selling securities of an issuer, personally or on behalf of others (including Client portfoliosmanagedbyMoonvest),whileinpossessionofmaterial,non-publicinformationabout suchissuerisprohibited.SupervisedPersonsmustnotindependentlydetermineifinformation is material, non-public information without consulting with the CCO.If you believe you might be in possession of material, non-public information, you must notify the CCO immediately.

Disclosing or communicating material, non-public information to any person or entity except persons who need to know the information to perform their responsibilities for Moonvest is prohibited. All such persons are subject to obligations of confidentiality with respect to such information and have agreed or are otherwise obligated not to buy or sell securities of the applicable issuer while in possession of such information.

The CCO will review personal trading activity which occurs in Supervised Person reportable accounts,asspecifiedintheCodeofEthics.TheCCOorherdesigneewillconducte-mail surveillance (through random and keyword searches) to ascertain whether material non-public informationhasbeenobtainedwithoutauthorizationorhasbeenusedimpermissibly. Ifyouhave any questions as to whether you are permitted to disclose non-public information to any other person, you should contact the CCO.

WhatisMaterial,Non-PublicInformation?

•Information is material if there is a “substantial likelihood” that a “reasonable investor” would consider it important in making an investment decision, the disclosure of the information would be “viewed by the reasonable investor as having significantly altered the‘totalmix’ of information made available,”or theinformation is reasonably certain to have a substantial effect on the price of a company's securities were it to be disclosed in the public domain.

•Non-public information is information that is not generally available to the investing public.Information is “public”when ithas been disseminated broadly to investors in the marketplace.

KeepinmindthatMoonvest maybeparty tonon-disclosureagreements,whichwhensignedby aSupervisedPersonofMoonvest,areapplicabletoallSupervisedPersonsofMoonvest.Ifyou are uncertain whether information is non-public information or is subject to a non-disclosure agreement, you should contact the CCO.

Be Mindful of Material, Non-Public Information

On an ongoing basis, a Supervised Person should ask himself or herself the following questions regarding information in his or her possession:(i) Is the information material? Is this information that an investor would consider important in making his or her investment decisions? Is this information that would substantially affect the market price of the Securities if generally

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disclosed? (ii)Is the information nonpublic? To whom has this information been provided? Has the information been effectively communicated to the marketplace by being published in Reuters, The Wall Street Journal or other publications of general circulation?

Be Aware of Common Sources of material non-public information Common sources of material, non-public information in the financial industry include, but are not limited to: investment research and due diligence; public company executives; other investment advisers; SPACs; Supervised Persons’ outside business or personal activities; industry conferences; and “value-added investors” (e.g., those investors that due to a corporate executive, corporate insider, financial professional or public company role could be more likely than other investors to be in possession of material non-public information). Supervised Persons should treat information from these sources with particular care given the potential for the receipt of material non-public information.

What to Do with Material Non-Public Information

If any Supervised Person believes he or she has come into possession of information that constitutes material non-public information, or if a Supervised Person has questions as to whether the information constitutes material non-public information, he or she should take the following steps:

•Report the information (and any related proposed trade) immediately to the CCO or designee.

•Do not purchase or sell any securities on which the information could have an impact either on behalf of yourself or on behalf of others.

•Do not communicate the information inside or outside the Firm, other than to the CCO or her designee or other Supervised Persons with a legitimate business purpose for receiving the information.

•After the CCO or designee has reviewed the issue, the Supervised Person will be instructed either to continue the prohibitions against trading and communication because the CCO or designee has determined that the information is material non-public information or will be allowed to communicate the information (and/or proceed with any requested trading).

Information in a Supervised Person’s possession that is identified as material non-public information may not be communicated to anyone, including persons within the Firm, except as otherwise provided herein. Supervised Persons should exercise due care in discussing work matters with family members or in social settings so as to avoid divulging material non-public information or “tipping” any person who may inappropriately or illegally trade based on such material non-public information. In addition, care should be taken so that such information is secure. For example, files containing MNPI should be sealed and access to computer files containing material non-public information should be restricted, and conversations containing such information, if appropriate at all, should be conducted in private (for example, not by cellular telephone, to avoid potential interception).

IV.PERSONALINVESTMENTANDTRADINGPOLICY

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Important Note: all transactions and accounts, as described below, subject to pre-clearance and reporting under this policy must be submitted to the CCO, who in turn will submit same to the Chief Compliance Officer of ETF Architect for review and approval if and when required.

General Policy Statement

ThesepoliciesandproceduresdonotlimittheabilityofSupervisedPersonsto engageinpersonal securities transactions. However, Moonvest reserves the right to further restrict personal investment and trading at any point the CCO deems appropriate.

Moonvest has adopted the following principles to govern personal investment activities by Supervised Persons:

•SupervisedPersonswilladhere tothehigheststandardsofethicalconduct;

•The interests of Clients will always be placed above the interests of Moonvest and its Supervised Persons;

•AppropriateinvestmentopportunitiesmustbeconsideredforClientsfirst before Moonvest or any Supervised Person may act on them;

•All personal securities transactions will be conducted in such a manner as to avoid or mitigate any actual or potential conflict of interest and so as to avoid any abuse of an individual’s position of trust and responsibility;

•SupervisedPersonsshouldnottakeinappropriateadvantageoftheir positions;

•Supervised Persons will not engage in any transaction that would be in violation of any governing agreement; and

•SupervisedPersonsthatserveasdirectorsorofficersofpubliclytradedcompanies mustbe awareofsuchcompanies’owntradingpoliciesandrestrictions,includingany“black-out” periods.

All Supervised Persons are required to comply with applicable federal and state securities laws. Failure to adhere to federal and state securities laws could expose Moonvest and its Supervised Persons to sanctions imposed by the SEC or law enforcement officials. These sanctions may include, among others, suspension, or termination of employment by Moonvest, or criminal or civil penalties.

All Supervised Persons are required to report holdings and transactions in Covered Securities (definedabove)inwhichtheyhavebeneficialownership,atermdefinedabove.Youmaynotuse confidential or proprietary information, obtained during your employment or association with Moonvest, for your personal investment purposes or for your personal gain, and you may not share such information with others for their personal benefit. The following restrictions and limitationsgoverninvestmentsandpersonalsecuritiestransactionsbyallSupervisedPersons(and their respective household members).

Reportable Securities

Supervised Persons must submit duplicate account statements or otherwise provide reports for "reportable securities" in which the Supervised Person has, or acquires, any direct or indirect beneficial ownership. A Supervised Person is presumed to be a beneficial owner of securities that are held by his or her immediate family members sharing the Supervised Person's household.

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Reportable securities are those securities defined in Section 202(a)(18) of the Advisers Act, including listed and unlisted securities, and private transactions (which include private placements, non-public stock, or warrants), EXCEPT:

•Direct obligations of the United States Government.

•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. Reportable fund means: (a) any fund for which the Firm serves as an investment adviser as defined in section 2(a)(20) of the 40 Act; or (b) any fund whose investment adviser or principal underwriter controls you, is controlled by you, or is under common control with you.

•Transactions in units of UITs that are invested solely in the shares of unaffiliated open-end mutual funds (e.g., variable product sub-accounts).

RestrictionsandLimitationsonPersonalSecurities Transactions

It is the responsibility of each Supervised Person to ensure that a particular securities transaction being considered for his or her personal account is not subject to a restriction contained in this Code, including due to its inclusion on the Restricted List, as defined below, or otherwise prohibited by any applicable law. Personal securities transactions may be effected only in accordance with the provisions of this Code. Rule 17(j) under the 1940 Act requires that every investment company adopt procedures designed to prevent improper personal trading by investment company personnel. Rule 17(j) was created to prevent conflicts of interest between investment company personnel and shareholders, to promote shareholder value, and to prevent investment company personnel from profiting from their access to proprietary information.

AdditionalPersonalTradingControls

ItisthedutyofallSupervisedPersonstoactinamannerthatavoidsanyconflictofinterestorthe appearanceofaconflictofinterestwithClients.Inaddition,itistheresponsibilityofeach Supervised Person to comply with all applicable Federal Securities Laws and the guidelines set forth below.

1.30-Day Hold. To deter market timing, Supervised Persons are required to hold any sub-advised Funds they purchase for a period of 30 days. This restriction applies to accounts for which Supervised Persons have a direct or indirect beneficial interest, including household members. This hold time will be determined by tax lots that are more than 30 days old. This hold period does not include any shares purchased through an automatic investment plan.

2.3-Day Blackout Rule. Supervised Persons are prohibited from executing a transaction on behalf of themselves or another Supervised Person within three (3) days of the ETF or any Client having a pending buy or sell order in the same or an equivalent security and until such time as that order is executed or withdrawn. A Supervised Person is free to submit the trade for preclearance or execute the trade if it is exempt from preclearance per the terms below. Nevertheless, a personal trade by any Supervised Person shall not prevent a portfolio from trading in the same or an equivalent security on behalf of the ETF or other Clients. However, such a transaction shall be subject to independent review by the CCO. For clarification, the 3-

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Day Blackout Rule applies to the two business days prior to the ETF transactions and the day of trading.

3.Exemptions Related to 30-Day Hold and 3-Day Blackout Rule. Any security that is not held by the Moonvest ETF is not subject to the 30 Day Hold Period or the 3-Day Blackout Period. With respect to other 30-day holding period requirement waivers, only certain limited exceptions will be approved including, but not limited to, hardships and extended disability. Exceptions must be approved by the CCO prior to execution.

4.Preclearance of Securities. Supervised Persons must preclear all personal securitiestransactionswiththeexceptionofthoseidentifiedinthelistbelow.Allapprovedorders must be executed by the close of business on the day in which preclearance is granted; provided howeverthatapprovedordersforsecuritiestradedin foreignmarketsmaybeexecutedwithintwo businessdaysfromthedatepreclearance isgranted. Ifanyorder isnot timely executed, arequest 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.

The following are exempt from preclearance:

•Non-proprietary, open-ended mutual funds and ETFs (e.g., mutual funds and ETFs not managed, advised, or sub-advised by Moonvest).

•Broad based index and commodity options and futures.

•Fixed income securities.

•Any transactions in individual equity securities, with a market cap of $10 billion or more, are exempt from pre-trade clearance, unless such security is on the Firm’s Restricted List.

•Discretionary accounts that are managed externally by an independent third party (e.g., an external investment adviser with discretionary authority or in a blind trust) where the Supervised Person has no influence over the trading decision.

•Exceptions by prior written approval of the CCO.

•Automatic investment/withdrawal programs and automatic rebalancing as part of a model portfolio managed by Moonvest.

5.Preclearance Required for IPOs, Limited Offerings and Private Placements. Securities issued in Initial Public Offerings (“IPO”), limited offerings and private placements (including investments in limited partnerships such as buyout, venture capital, oil and gas, real estate, and hedge funds or funds of funds) may only be acquired by a Supervised Person or household member thereof with the advance written approval of the CCO. A Private Placement, also known as an unregistered offering, is the purchase of any security or offering exempt from the Securities Act of 1933. A request for approval of a private placement or limited offering should generally be submitted at least one week in advance of the proposed date of investment.A Supervised Person need notpre-clear any privateplacementinvestments in which such Supervised Person’s only “beneficial ownership” is through the general partner of a Fund

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sponsored by Moonvest or its affiliates. Certain limited partnership investments may not be securities, such as a partnership created to invest in a building. Supervised Persons are urged to consult the CCO with any questions about limited offerings. Preclearance does not preclude subsequent reporting of transactions. Forpurposesofthispolicy,anIPOdoes not include offerings of government or municipal securities.

6.Preclearance Required for Option Writing. Supervised Persons must preclear with the CCO any option writing.

7.Short Selling Restrictions. Supervised Persons and household members are prohibited from selling short any security which is owned in a Client portfolio, including the Moonvest ETF.

8.Investment Clubs are Prohibited. Supervised Persons and household members are prohibited from participating in investment clubs.

9.Prohibition on Trading Securities on the Restricted Security List. Moonvest hasestablishedaRestrictedSecurityListthatincludescertainpubliccompanyissuerswhereMoonvest has, or may receive, material non-public information about such companies because of a specialrelationshipbetweenMoonvestoranaffiliateoraSupervisedPersonandsuchcompanies or otherwise. No Supervised Persons or household member thereof can trade or invest in any securities listed on the Restricted Security List without the prior consent of the CCO. This restrictioncovers allinstruments ofthe issuer,includingequity,debt,andderivative instruments.

In addition, in the event that any Supervised Person is exposed to material non-public information regarding a public company, such information shall be communicated immediately to the CCO, and such public company will be added to the Restricted Security List.

If any Supervised Person or household member thereof already holds a security that is on the Restricted Security List and has not received consent from the CCO, such Supervised Person or household member must continue to hold and may not execute any buy or sell orders for the relevantsecurityuntilsuchsecurityisremovedfromtheRestrictedSecurityList.Thisrequirement covers all instruments of the issuer. All Supervised Persons are responsible for knowing the contents of the Restricted Security List prior to effecting or soliciting a transaction in a security. Any Supervised Person with access to the Restricted Security List is prohibited from disclosing thesecurities listed on theRestricted Security List to third parties (except household members to facilitate their compliance with this policy) without the authorization of the CCO.

The CCO is responsible to administer Restricted Security List controls to prevent the misappropriation of material non-public information, and to ensure that Supervised Persons receive appropriate training relative to this policy. 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 Supervised Persons and theirrespectivehouseholdmembersthatarereportedtotheCCOpursuanttotheCodetoascertain

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any pattern of conduct which may violate the restriction requirements or evidence front-running, scalping, or other inappropriate behavior.

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

11.Restrictions on Disclosures. You may not disclose any non-public information (whetherornotitismaterial)relatingto Moonvestorsecuritiestransactionsonbehalfof Clients toanypersonoutsideMoonvest(unlesssuchdisclosurehasbeenauthorizedbyMoonvest).You maynotcommunicatematerialnon-publicinformationtoanyone,includingpersonswithinMoonvest, except as permitted by this Code and related policies outlined in this Manual.All material non-public information must be secured.For example, access to files containing material, non- public information should be restricted, and conversations containing such information, if appropriateatall,shouldbeconductedinaprivatesettingtotheextentpracticable.Conversations inpublicplaces,suchas elevators,restaurants,and airplanes,should be limitedto mattersthatdo not pertain to information of a sensitive or confidential nature. Disclosure restrictions are not intendedtoprecludeaSupervisedPerson’srightsundertheWhistleblowerPolicy,outlinedbelow.

TheCCOwillreviewandconsideranyproperrequestforrelieforexemptionfromanyrestriction, limitation or procedurecontained in this Codewhich you believewillcauseyou ahardship.The decision of the CCO is completely within her discretion.

EachSupervisedPersonissolelyresponsibleforanyviolationofthisCodebyahouseholdmember thereof.

V.REPORTING REQUIRMENTS

TransactionsandAccountsCovered

SupervisedPersonsarerequiredtosubmittothe CCO thefollowingreports:

1.Initial Holdings Report. Each Supervised Person is required to provide an Initial Holdings Report listing all holdings in Covered Securities with the CCO (or such other person designatedbytheCCO)within10daysafterfirstbecomingaSupervisedPerson.Theinformation containedinan InitialHoldingsReportmust becurrentasofadateno morethan45daysprior to the date of becoming a Supervised Person.

2.Quarterly Trade Reports. Each Supervised Person must also file with the CCO (orsuchotherpersondesignatedbytheCCO)periodicreportsofpersonaltransactionsinCovered Securitieswithin 30daysafter the endof each calendarquarter EachSupervised Personmustfile a Quarterly Transactions Report even if no purchases or sales of securities are made during the period covered by the report.

3.Annual Holdings Report. Each Supervised Person must submit an Annual Holdings Report within 30 days after the end of each calendar year, and the information must be current as of a date no more than 45 days prior to the date such report is submitted.

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Each Supervised Person will be responsible for submitting a copy of: (i) all transaction confirmations for each account in which such Supervised Person or a household member thereof directly or indirectly holds a Covered Security, and (ii) all account statements for each such account (collectively, “Brokerage Statements”) or otherwise ensuring that the CCO has access to such BrokerageStatements. A Supervised Personis notrequired to provideinformation thatis containedinBrokerageStatementssenttotheCCOorsuchotherdesignatedpersoninaccordance with this Code, if such Brokerage Statements are provided to the CCO or such other designated person/system consistent with the required timing set forth above. Supervised Persons are still responsible to validate such reports annually and quarterly as directed by the CCO.

Cryptocurrencies

A cryptocurrency is a digital asset designed to work as a medium of exchange that uses strong cryptography to secure financial transactions, control the creation of additional units, and verify the transfer of assets. There is some debate as to whether cryptocurrencies are securities. If there is a centralized third party, along with purchasers of a cryptocurrency with an expectation of a return,thenthetransactionshouldbeconsideredasecuritiestransaction.Bitcoinisnotdeemedto be a security because it is decentralized: there is no central party whose efforts are a key determiningfactor intheenterprise. Inaddition, etherisnota security becausetheEthereum network is also decentralized. Supervised Persons are not required to pre-clear, or report transactions or holdings related to cryptocurrencies which are not deemed to be securities.

Until further notice, cryptocurrencies that are deemed to be securities and Initial Coin Offerings (“ICOs”) are included in the definition of a covered security. If a Supervised Person has any questionas towhether asecurity is“covered”under thisCode, s/heshould consultwith the CCO for clarification before entering any trade for a personal account.

Exceptionsfrom ReportingRequirement

If a Supervised Person has given up investment discretion to another unaffiliated party, s/he should submit a letter to the CCO from the broker attesting to this fact, when joining the Firm as a new employee, upon designation as a Supervised Person, or when a new non-discretionary account is opened. Upon the CCO’s affirmative determination that the Supervised Person’s account is in fact a non-discretionary account managed by a non-conflicted third party, the Supervised Person may be provided a reporting exemption for that account. Supervised Persons are required to answer certain questions about non-discretionary accounts as part of the annual holdings reporting process, to ensure that such accounts are not in violation of this policy. If the Supervised Person’s level of discretion changes with regard to a non-discretionary account, the CCO must be notified immediately. The CCO will periodically repeat independent verification. All related documentation pertaining to a personal account exemption will be maintained by the CCO pursuant to the Books and Records policy. Transactions under an automatic investment plan are not considered reportable transactions.

Accounts restricted solely to the purchase and sale of open-end mutual funds (to includeETFs),529CollegeSavingsPlans,and403b/401kplansarenotsubjecttothispolicyand do not require disclosure or quarterly reporting. However, if the accounts described above can trade reportable securities, those accounts are subject to the policy even if it holds only mutual funds.

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If theSupervised Person’s levelof discretion changes relativeto anon-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 Moonvest’s Books and Records policy.

ResponsibilitytoReport

All reports must be filed with the CCO or her named designee.The responsibility for taking the initiativetoreportisimposedoneachSupervisedPersonrequiredtomakeareport.Anyeffortby the CCO to facilitate the reporting process does not change or alter that responsibility. Any SupervisedPersonwhohasfailedtoprovidethereferencedinformationbytheprescribeddeadline will be deemed to have violated Moonvest’s Code of Ethics and may be subject to disciplinary action.

ReviewandConfidentiality

All Holdings Reports, Transactions Reports, and Preclearance requests will be reviewed by the CCO or a designee. If the Firm has more than one employee, another Supervised Person will review the CCO’s reports to avoid self-review.

SupervisedPersons mustreportpersonalsecurities accounts andholdings tothe CCO as outlined herein. It is the intent of the CCO to regard and preserve information pertaining to Supervised Persons personal trading activities as confidential in nature. However, in certain circumstances, Moonvest may be authorized to disclose such information as required by law enforcement or regulatory inquiry and under any circumstances wherein Moonvest deems disclosure to be reasonablynecessarytopreventfraud,unauthorizedtransactions,liability,ortorespondtojudicial process or subpoena.

VI.CONFLICTSANDPROHIBITEDACTIVITIES

Itisaviolationofyourdutyofloyaltyto Moonvest foryou,withoutthepriorwrittenconsentof theCCOtoaccept,directlyorindirectly,fromanyperson,firm, corporation,orassociation,other than Moonvest and its affiliates, compensation of any nature as a bonus, commission, fee, gratuity, or other consideration in connection with any transaction on behalf of Moonvest or Clients.

VII.SPREAD OFFALSE INFORMATION

Moonvest unequivocally prohibits and forbids all Supervised Persons from communicating or transmitting“falserumors”orotherinformationregardinganyFund,portfolioinvestment,orany registered security which such Supervised Person does not know or reasonably believe to be true to any person outside of Moonvest for any reason.

IftheCCO,upondueinvestigation,findsthatanySupervisedPersonhasengagedinthespreadof false rumors or information as described above, the CCO may recommend sanctions including, but not limited to, dismissal of the person or persons involved and/or reporting of any improper conduct to the SEC or other regulatory authorities.

VIII.POLITICAL CONTRIBUTIONS

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SEC Rule 206(4)-5 restricts contributions and solicitation practices of investment advisers and their affiliates beyond certain dollar amounts.Specifically, the Rule prohibits an investment adviserfromprovidingadvisoryservicestoanystateorlocalgovernmententity,fortwoyears,if that investment adviser or any “Covered Associate” has made a contribution to a public official who is in a position to influence the award of that advisory service contract.The Rule further prohibits an investment adviser, or a Covered Associate, from paying directly or indirectly any person to solicit a government entity for advisory services on behalf of the adviser unless such personis:aregisteredinvestmentadviserrepresentative,oranexecutiveofficer,generalpartner, managing member or an employee of the adviser.

A“CoveredAssociate”includes:(1)anygeneralpartner,managingmemberorexecutiveofficer oftheAdvisor,(2)anyemployeewhosolicitsagovernmentalentityonbehalfofMoonvestand anyone directly or indirectly supervising such employee, and (3) any political action committee controlled by Moonvest or one of its Covered Associates.

"Contribution" means any gift, subscription, loan, advance, or deposit of money, or anything of value made for:

•thepurposeofinfluencinganyelectionforfederal,state,orlocaloffice;

•thepaymentofdebtincurredinconnectionwithanysuchelection;

•transitionorinauguralexpensesincurredbyasuccessfulcandidateforstateorlocaloffice; or

•charitabledonationsandcontributionstoapoliticalactioncommittee(PAC).

Forpurposesofthispolicy,allSupervisedPersonsaredeemedtobeCoveredAssociates.It is Moonvest’s policy that no Covered Associate, his/her spouse, partner, or household member is permitted to make a political contribution to any candidate, officeholder, political party, or PAC.

IX.GIFTS ANDENTERTAINMENT

AcceptingGifts

On occasion, because of their position with the Firm, Supervised Persons of Moonvest may be offered or may receive without notice gifts from Clients, brokers, service providers, or other persons in relation to the business of the Firm.Acceptance of extraordinary or extravagant gifts byaSupervisedPerson(orhis/herspouse,partner,orhouseholdmember)isprohibited.Anysuch gifts mustbedeclined and returned in order to protectthereputation and integrity of Moonvest. Gifts of nominal value (i.e., a gift whose reasonable value, alone or in the aggregate, is not more than $1,000 in any twelve-month period), customary business meals, entertainment (e.g. sporting events),andpromotionalitems(i.e.,pens,mugs,T-shirts)maybe accepted.Allgiftsreceivedby aSupervisedPerson(orhis/herspouse,partner,orhouseholdmember)thatmightviolatethisCode mustbepromptlyreportedtotheCCO.Inaddition,allgiftsreceived/giftedwhosereasonablevalue exceeds $500 must be reported to the CCO.

Solicitationof Gifts

Supervised Persons (and a spouse, partner, or household member) are prohibited from soliciting gifts of any size under any circumstances.

GivingGifts

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Supervised Persons (and a spouse, partner, or household member) may not give any gift with a value in excess of $1,000 per year to a Client or persons who do businesswith, regulate, advise, or render professional service to Moonvest.

X.OUTSIDEACTIVITIESAND INTERESTS

Uponhire,ordesignationasaSupervisedPerson,allemployeesmustreportoutsideactivitiesand interests.Thereafter,SupervisedPersonsmustobtainpriorapprovalfromtheCCOforanyoutside businessactivitythatwasnotalreadyunderwayatthetimethispolicywasfirstadopted.Anoutside activity or interest may never:

•Presentasubstantialriskofconfusing Clientsorthe publicas tothecapacityinwhichthe Supervised Person is acting;

•Poseareputationalrisk forMoonvest;

•Inappropriately influence a Supervised Person’s business dealings or otherwise create a conflict of interest vis-à-vis the interests of Moonvest or Clients; and/or

•Involveuseof Moonvest’s Client,orproprietary information.

Examples of outside business activities subject to this policy include, but are not limited to:

•Outside speaking engagements, including participation in podcasts, panels, and media interviews

•Outside Board or Committee service

•Association memberships

•Part-time work, including a home-based business or family business

•Public speaking, teaching, writing, blogging

•Consulting inside or outside financial services industry

•Uber driver

Supervised Persons may not serve on the board of any company whose securities are publicly traded, or of any company in which Moonvest or Client owns securities without the consent of the CCO.

Periodically as directed by the CCO, Supervised Persons must review and certify to outside business activities. At all times, Supervised Persons should ensure that their outside business activities do not present a risk of a conflict of interest for Moonvest, and that the Supervised Person is clear that they are not acting or providing advice on behalf of Moonvest.

The CCO may require further information concerning any outside activity for which you request approval,includingthenumberofhoursinvolvedandthecompensationtobereceived.The CCO will review each reported outside business activity and decide whether such activity must be restricted, monitored, and/or disclosed by Moonvest. Supervised Persons are advised to consult the CCO with any questions as to whether an outside activity or interest is reportable under this policy.

XI.WHISTLEBLOWERS

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AllSupervisedPersonshaveadutytoobservethehigheststandardsofbusinessandpersonalethics while discharging their professional responsibilities on behalf of Moonvest and to report suspected violations of the Code of Ethics, Compliance Manual or securities laws in the manner described in this policy.Supervised Persons are advised to first share any questions, suggestions, concerns,orcomplaintswiththeCCOofMoonvestwhocanaddressthemproperly.However,if a Supervised Person is not comfortable speaking with the CCO of Moonvest, or is not satisfied with the initial response, the Supervised Person is advised to file a complaint under this policy. Supervisors are required to report suspected compliance violations to the CCO. All reports to the CCO by a supervisor will be handled per the process outlined in this policy. Any employee of Moonvest may also contact the SEC’s Office of the Whistleblower directly at (202) 551-4790.

This policy offers protection from retaliation for Supervised Persons who make any complaint related to a known or suspected compliance violation (“Reporting Person”), if the complaint is made in good faith. “Good faith” means the Reporting Person has a reasonable belief that the complaint is true and is not being conveyed for personal gain or other ulterior motive.

It is important to note that nothing in this Compliance Manual or any agreement between the Firm and a Supervised Person will restrict any person from voluntarily communicating with the SEC or other governmental authorities about possible violations of law, without notice to or approval from the Firm, or from receiving a whistleblower award.

Any acts of retaliation against a Reporting Person acting in good faith will invoke Moonvest’s disciplinary policy and any person who retaliates against a Reporting Person will be subject to sanctionsuptoandincludingterminationofemployment.MoonvestrecommendsthatReporting Persons approach Moonvest with any concerns related to possible or actual violations of securities laws butdoes notprohibitReportingPersons fromvoluntarilycommunicatingwiththe SECorotherregulatoryauthorityregardingpossibleoractualviolationsofsecuritieslaw. Furthermore, Moonvest does not prohibit Reporting Persons from recovering an SEC whistleblower award.

Reporting Persons are required to promptly report irregularities and suspected violations of the Code of Ethics and compliance policies (“compliance violations”) to the CCO.

The failure of a Supervised Person to report suspicious activity which pertains to a serious act of noncompliancemayexposetheSupervisedPersonto anenforcementactionbytheSECbasedon the legal doctrine of “willful blindness” which essentially posits that certain individuals, especiallysupervisors,whoshouldhaveknownthatnoncompliantactivitywasundertaken,cannot use the defense that they “did not know.”

The CCO will keep the identity of any Reporting Person confidential and privileged under all circumstances to the fullest extent allowed by law unless the Reporting Person has authorized Moonvest to disclose his/her identity. Following a formal investigation, the CCO will continue to protect the identity of the Reporting Person unless confidentiality is incompatible with a fair investigation, there is an overriding reason for identifying or otherwise disclosing the identity of such person, or disclosure is required by law, such as where a regulatory authority initiates an investigation of allegations contained in the complaint.

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AnycomplaintfiledunderthispolicywhichrelatestotheETFmustbereportedtotheCCO, whowillescalatethecomplainttoETFArchitectassoonasreasonablypractical.TheCCO’s abilitytoprotecttheidentityofawhistleblowerwilldependuponseveralvariables,including the terms of the Sub-Advisory Agreement and other governing legal documents and applicable regulations.

ReportingPersonsshouldsubmitcomplaintsconcerningcomplianceviolationsinaccordancewith the following procedures:

•Complaints must be submitted in writing and mailed or delivered in a sealed envelope addressed to the CCO.

•The content of the complaint must be sufficiently detailed to include a summary of the complaint,date(s)ofallegedwrongdoing,partiesinvolvedinthewrongdoing,andhowthe Reporting Person learned about the suspected violation.

•If appropriate, the Reporting Person may request an opportunity to discuss the complaint with the CCO by indicating such intent and including their identity in the complaint.

•Reporting Persons may report compliance violations on an anonymous basis. Any Supervised Person that contemplates making an anonymous complaint must realize that anonymouscomplaintsare,bytheirnature,susceptibletoabuse,lessdependable,andmore difficult to resolve. In addition, Supervised Persons considering making an anonymous complaint should be aware that there may be rights and protections available to them if they identify themselves when making a complaint, and that these rights and protections may be lost if they make the complaint on an anonymous basis.

Therefore,MoonvestencouragesSupervisedPersonstoidentifythemselveswhenmakingreports of compliance violations.

Uponreceiptofacomplaintunderthispolicy,theCCOwillconfirmthatthecomplaintinvolvesa compliance violation. An investigation will be conducted as quickly as possible, considering the nature and complexity of the complaint and the issues it raises. Prompt and appropriate remedial action willbetaken as warranted in thejudgmentof theCCO. Any actions taken in responseto a complaint will be conveyed to the Reporting Person to the extent allowed by law unless the complaint is submitted anonymously.

The CCO will maintain all complaints received, tracking their receipt, investigation, and resolution. All complaints and reports will be maintained in accordance with Moonvest’s confidentiality and record retention policies.

In the normal conduct of its business, Moonvest may use employment, severance, and non- disclosure agreements. Nothing contained in those agreements may prohibit current or former employees from voluntarily communicating with the SEC or other regulatory authorities about possible violations of law or from recovering an SEC whistleblower award. The CCO is responsibletoensurethatallsuch agreementscomplywiththisrequirement,andto makeclearto all employees who sign such agreements that Moonvest does not prohibit them from communicating with the SEC or seeking a whistleblower award.

XII.DISCIPLINARY MATTERS

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To ensure that Moonvest follows its disclosure obligations, Supervised Persons must notify the CCO immediately in the event of any “reportable event.”A reportable event occurs when a Supervised Person:

•Violatesanyprovisionofanysecuritieslaworregulationoranyagreementwithorruleor standard of any government agency, self-regulatory organization or business or professionalorganization, or haveengaged in conductwhich may bematerialto acurrent or prospective Client’s evaluation of Moonvest’s advisory business or the integrity of Moonvest’s management;

•ViolatesanyprovisionofthisManual,orgoverningagreement;

•Is the subject of any written complaint involving allegations of theft or misappropriation of funds or securities, or forgery;

•Is named as a defendant or respondent in any proceeding brought by a regulatory or self- regulatory body;

•Is denied registration, expelled, enjoined, directed to cease, and desist, suspended, or otherwise disciplined by any securities, insurance, or commodities industry regulatory or self-regulatory organization;

•Isdeniedmembershiporcontinuedmembershipinanyself-regulatoryorganization,orare barred from becoming associated with any member or member organization of any self- regulatory organization;

•Isarrested,arraigned,indicted,orconvictedoforpleadguiltytoorpleadnocontesttoany criminal offense (other than minor traffic violations);

•Is a director, controlling stockholder, partner, officer, sole proprietor or an associated personofabroker,dealerorinsurancecompanywhichwassuspended,expelled,orhadits registrationdeniedorrevokedbyanyagency,jurisdiction,ororganizationorareassociated in such a capacity with a bank, trust company or other financial institution which was convicted of or pleaded no contest to any felony or misdemeanor;

•Is a defendant or respondent in any securities or commodities-related civil litigation or arbitration which has been disposed of by judgment, award, or settlement; and/or

•Isthesubjectofanyclaimsettledfordamagesbyacustomer,broker,ordealer.

From time to time, Supervised Persons may be asked to complete a Disciplinary History Report which mandates disclosure by the individual of any financial or disciplinary event since the last written certification. SupervisedPersonsarerequired toanswerdetailed questionsrelated tosuch information candidly and on a timely basis.

The CCO will determine when any required disclosure should be made, to whom any required disclosureshould bemade, and themethod by which itwillbemade. However, wheredisclosure

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is required by the Advisers Act, the disclosure should be made promptly to the SEC, applicable state regulatory authority, and Clients.

Disciplinary action, up to and including termination, may result if you do not properly notify the CCOimmediatelyfollowingtheoccurrence ofareportable event. Moonvestwillbe responsible for making the determination of notifying ETF Architect and Clients, as well as the appropriate authoritiesoftheoccurrenceofanysuchevents.Inaddition,Moonvestmayconductathorough background check on allnew Supervised Persons todeterminewhether thereareany such events required to be disclosed.

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APPENDIX2

COMPLIANCEMANUALANDCODEOFETHICS CERTIFICATION

1.Theundersignedemployee,agentorotherperson (“SupervisedPerson”) associated with Moonvest LLC (the “Firm”), hereby acknowledges, certifies, represents, warrants, and agrees as follows:

2.SupervisedPersonhasreceivedacopyoftheFirm’sComplianceManual(the“Manual”), which includes, among other provisions:

a.TheFirm’sPrivacyPolicy;

b.TheFirm’sCodeofEthics,includinginsidertradingandconflictsofinterest policies;

c.TheFirm’sPersonalAccountTradingPolicy; and

d.TheFirm’sCybersecurityPolicy.

3.SupervisedPersonhasreadandunderstandstheinformationcontainedintheManual.

4.Supervised Person will abide by: (i) all rules, restrictions, policies, and procedures described in the Manual (as amended from time to time); and (ii) all covered laws applicabletohimorher(asamendedfromtimetotime),whetherinconnectionwithhisor her activities on behalf of the Firm or otherwise.

5.SupervisedPersonhascompliedwiththeFirm’scompliancepoliciesandproceduressince the last date on which such person signed and delivered this Acknowledgement and Agreement (or its predecessor form) to the Firm.

6.Supervised Person understands that any violation of the Firm’scompliance policies and procedures by Supervised Person, may lead to sanctions, including the termination of his or her employment with the Firm or other dismissal.

7.Supervised Person understands that nothing contained in the Firm’s compliance policies and procedures affects in any way the at-will nature of Supervised Person employment withtheFirm,whichtheFirmmayterminateatanytimeforanyreasonwithoutpenaltyor other payment except as required by law or written agreement.

______________ (print) SupervisedPerson Name    Date

______________________________________

SupervisedPerson Signature

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APPENDIX3

OUTSIDEBUSINESSACTIVITIESDISCLOSURE FORM

CheckOne:New DisclosureUpdated DisclosureRemoveDisclosure

Supervised Persons who engage in any outside business activity, with or without compensation, mustcompleteandsubmitthisformtotheCCOforreviewandapproval.Pleaserefertothe Code of Ethics for complete information.

An outsidebusiness activity includes any business activity thatis outside thescopeof the Firm’s business.Suchbusiness activityincludes actingas aproprietor,partner,officer,director,trustee, consultant,orhavinganyfinancial interestinanother businessororganization.Anoutsidebusiness activity also includes non-compensated positions for which you have a fiduciary duty (i.e. president, treasurer, trustee, power of attorney, charitableor other officepositions for anonprofit board). While an outsidebusiness activity does notincludepassiveinvestments, exception might apply by virtue of their nature, position, percentage of ownership or control or obligations with respect to that activity.

Failure to promptly disclose an outside business activity could result in disciplinary actions includingtermination.YoumustutilizethisOutsideBusinessActivityDisclosureFormtodisclose anyactivitytotheFirm.Yourdisclosuremustbebothaccurateandcompletetobeconsideredfor review.

In the event that you have any change in your outside business activity profile, you must update this form promptly and forward it to the CCO for review and final updating.

Iunderstanditismyobligationtopromptlyupdateanychangesinmyoutsidebusiness activities.

PleaseInitial,SignandDate:

I DO NOT engage in any outside business activities.     IDO engageinthefollowingoutside activities:

Descriptionofoutsideactivities(listallthatapply;attachseparatepageif needed):

___________________________________________________________________________________________

___________________________________________________________________________________________

________________________

SupervisedPerson (print)    _____Date

APPENDIX4

PERSONALACCOUNTCERTIFICATION

Tobecompletedupon employment,promptlyuponanychanges andannually thereafter

Check One:New Disclosure Updated Disclosure OR

AnnualDisclosure

SupervisedPerson Name(print):

Date of Report:

Check oneofthefollowingas applicable:

I do not have any personal accounts to disclose.

I have personal accounts to disclose which are listed below.

ListedbelowarepersonalaccountswhichIhavebeneficialinterestasdefinedintheFirm’s Personal Trading Policy.Attach additional sheets if necessary.

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

Supervised Person Signature: Date:

__________ChiefComplianceOfficerApprovalSignature     ____________________Date

APPENDIX5

PERSONALHOLDINGS CERTIFICATION

Tobecompleteduponemployment,upon anychanges andannuallythereafter

Name of Supervised Person (print):

Check One:New Disclosure UpdatedDisclosureAnnualDisclosure

Pleaselistallpersonalholdings inwhichyouhave a financialinterest oroverwhichyouexercise control that have not otherwise been disclosed to the Firm or check the box below stating you do not have any additional holdings to disclose.

NAMEOFHOLDING, AMOUNT OWNED AND DATE ACQUIRED BROKERAGEFIRM, CUSTODIAN OR SPONSOR ACCOUNT NUMBERAND NAME ON ACCOUNT STATEMENTS SENTTOCCO? (Yes/No//N/A/Will be Arranged)

Attachadditionalsheetsifnecessary.

OR

Idonothaveanypersonalholdings to disclose(checkhereonlyifthis applies).

Supervised Person Signature: Date:

__________ChiefComplianceOfficerApprovalSignature     ____________________Date

APPENDIX6

QUARTERLYPERSONALSECURITIESTRANSACTIONSREPORT

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The Code of Ethics and SEC regulations require that each Access Person (defined at Rule 204A- 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, or any account in which the Access Person or any immediate family or household member, has a direct or indirect pecuniary interest. If the Access Person has arranged for the CCO or other designee to receive copies of brokerage statementsforallcoveredaccounts,thensuchbrokeragereportswillnegatetheneedfortheAccess Persontoseparatelycompletethisquarterlytransactionreport.IftheAccessPersonhasarranged fortheFirmtoreceivecopiesofbrokeragestatementsforallcoveredaccounts,theuseofthisform would be limited to reporting transactions in private offerings which are transacted outside of brokerage accounts.

Quarter ending:

YES, Ihad reportable personal securitiestransactionswithin the past quarter asreported on (check all thatapply):

□theattachedpage/or monthlybrokeragestatements

□confirmations/statementssentdirectlybymybroker-dealer

□theattachedreport

NO,Ihadnoreportablepersonalsecuritiestransaction(s)inthepastquarter.

Thisreportistobesigned,dated,andreturnedtotheCCO(ordesignatedperson),within30daysofquarter end.

_________________________________SupervisedPersonSignature

_________________________________PrintName*    ___________________Date

__________ CCOorDesignatedOfficerSignature    ___________________Date

*ImportantNote:TheCCO hasdiscretiontorelyupone-mailattestationinlieuofsignatures.

APPENDIX6

QUARTERLYPERSONALSECURITIESTRANSACTIONSREPORT

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Transactionsdonotneed tobereported for:

•AnyaccountinwhichtheAccessPerson has nodirectorindirectinfluenceorcontrol;

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

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

•Open-end investment companies, i.e., mutual funds unless the Firm, or an affiliated companyactsasinvestmentadviser,sub-adviser,or principalunderwritertothemutual fund(s);

•529 Plans, unless the Firm or a control affiliate manages, distributes, markets, or underwrites the 529 Plan or the investments (including a fund that is defined as a reportablefundunderRule204A-1)andstrategiesunderlyingthe529Planthatisa college savings plan; and

•Unitsofunitinvestmenttrusts,solongastheunitinvestmenttrustisneithermanagedby the Firm, any affiliate of the Firm, nor invested in affiliated mutual funds.

Account Identification Information (Name/#) Trade Date and Transaction Type (Buy/Sell) Transaction Price and Number of Shares Nameof Security Ticker or CUSIP Interest Rateand Maturity Date Principal Amount Broker

The reporting or recording of any such transaction should not be construed as an admission you have any direct or indirect beneficial ownership in the security reported.

APPENDIX7

PRE-APPROVALFORM:PERSONALSECURITIES TRANSACTION

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

IRRESPECTIVE OF APPROVAL BY THE CHIEF COMPLIANCE OFFICER, NO EMPLOYEE MAY EXECUTE ANY SECURITIES TRANSACTION WHILE IN POSSESSION OF INSIDE INFORMATION.SEE THE CODE OF ETHICS FOR INFORMATION ABOUT INSIDER TRADING AND NON-PUBLIC INFORMATION.

Whetherornotan employeehas“insideinformation,”noemployeemay“tradeahead”ofaclient orexecuteanytransactionwhichmightinanyrespectdisadvantageaclientaccountorresultinan employee in 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:

Describewhetherandwhythisinvestmentwouldor wouldnotbesuitableforaclient: Transaction Type (please check):

□Purchase

□Sale

APPENDIX7

PRE-APPROVALFORM:PERSONALSECURITIESTRANSACTION

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EstimatedTradeDate:Estimated Price:

Broker/Dealer:

Istheinvestmenta limited offering?	□Yes	□No
Is theinvestmentaprivate placement?	□Yes	□No

If yes, will the private placement invest in corporate debt or equity?□ Yes    □No Ifyes,willyoutakeanactiveroleinthemanagementofinvestments?□Yes    □ No

RepresentationandSignature:

Byexecutingthisform,Irepresentthattheinformationcontainedhereinisaccurateandcomplete and that my trading in this investment is not based on any material non-public information.

______________SupervisedPerson Name    ____________________Date

_________________________________SupervisedPerson Signature

**************

Compliance Approval:Date:

Duration of preclearance approval:

APPROVAL OF A TRADE DOES NOT MEAN THAT THE FIRM IN ANY RESPECT RECOMMENDS OR ENDORSES SUCH TRANSACTION. THIS APPROVAL IS ONLY VALID UNTIL THE LAST DATE LISTED ABOVE. FURTHERMORE, THIS APPROVALISNOTVALIDSHOULDANYOFTHEINFORMATIONLISTEDABOVE CHANGE OR SHOULD THE EMPLOYEE COME INTO POSSESSION OF “INSIDE INFORMATION.”