Code of Ethics Future Fund

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The Future Fund LLC

I.INTRODUCTION

Rule 204A-1 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) requires

every investment adviser to establish, maintain and enforce a code of ethics that at a minimum

addresses personal trading by its access persons. High ethical standards are essential for the

success of The Future Fund LLC (the “Firm”) to maintain the confidence of its Clients, including

any fund advised by the Firm, (collectively, the “Clients” and each an “Client”). This Code of Ethics

establishes rules of conduct for each partner, member, officer and employee of the Firm (each a

“Supervised Persons”) who (i) has access to nonpublic information regarding any Clients'

purchase or sale of securities, or (ii) who is involved in making securities recommendations to

Clients or who has access to such recommendations that are nonpublic (each an “Access Person”

and collectively, “Access Persons”). For purposes of this Code, all Supervised Persons are deemed

to be Access Persons. Access Persons may also include certain persons who are employed by the

Firm, such as interns, temporary workers and consultants, and are subject to the Firm’s

supervision and control. Access Persons generally do not include vendors or service providers that

are engaged by the Firm.

The objective of this Code of Ethics is to subject all business dealings and securities transactions

undertaken by Supervised Persons, whether for Clients or for personal purposes, to the highest

ethical standards. The Firm expects its personnel to premise their conduct on fundamental

principles of openness, integrity, honesty, and trust.

Any terms that are not predefined here have the meaning ascribed to them in the Firm’s current

version of the Compliance Manual, as amended from time to time.

Compliance with the provisions of the Code of Ethics shall be considered an important condition

of employment with the Firm. Access Persons should understand that a material breach of the

provisions of the Code of Ethics may constitute grounds for disciplinary action, including

termination of employment or relationship with the Firm.

I.FIDUCIARY DUTY AND STATEMENT OF POLICIES

A.Confidentiality

Supervised Persons are expected to honor the confidential nature of company, Client, and

Investor affairs. Information designated as confidential shall not be communicated

outside the Firm, other than to advisors consulted on a confidential basis and will only be

communicated within the Firm on a “need to know” basis. Access Persons must avoid

making unnecessary disclosure of any material nonpublic information about issuers of

securities or internal information concerning the Firm and its business relationships and

must use such information in a prudent and proper manner in the best interests of the

Firm and its Clients. The Firm has adopted a separate Privacy Policy, with which all Access

Persons are expected to be familiar.

B.Level of Care

Access Persons are expected to represent the interests of the Firm, its Clients and

Investors in an ethical manner and to exercise due skill, care, prudence, and diligence in

all business dealings, including, but not limited to, compliance with all applicable federal

securities and other applicable laws and regulations and to avoid illegal activities and

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other conduct specifically prohibited to its Access Persons. Accordingly, Access Persons

are not permitted, in connection with the purchase or sale, directly or indirectly, of a

security held or to be acquired by a Client (a) to defraud or mislead a Client or Investor,

(b) to engage in any act, practice or course of conduct that operates or could operate as

a fraud or deceit upon a Client or Investor, or (c) to engage in any manipulative practice

with respect to a Client or Investor or securities (such as price manipulation). The Firm

places a high value on ethical conduct and challenges its Access Persons to live up to its

ethical ideal, not merely obey the letter of the law.

C.Fiduciary Duties

The Firm and its affiliates are fiduciaries with respect to its Clients. As such, all personnel

have the following fiduciary duties:

•At all times, to place the interests of Clients before their own and not to take

inappropriate advantage of their positions, and

•To conduct themselves in a manner that will avoid any actual or potential conflict

of interest or any abuse of a position of trust and responsibility. Conflicts of

interest can arise in many ways. However, one factor that is common to many

conflict of interest situations is the possibility that an Access Person’s actions or

decisions may be affected because of an actual or potential divergence between

or among the interests of the Firm and its affiliates, the Firm’s Clients and an

Access Person’s own personal interests. A particular activity or situation may be

found to involve a conflict of interest even though it does not result in any

financial loss to the Firm or its Clients, irrespective of the motivations of the

Access Person involved.

(a)An Access Person may not rebate, directly or indirectly, to any person or

entity any compensation received from the Firm, or accept, directly or

indirectly, from any person or entity, other than the Firm, compensation

of any nature as a bonus, commission, fee, gratuity or other consideration

in connection with any transaction on behalf of the Firm or a Client (for

example, directing a particular transaction in exchange for any such

compensation), other than permissible gifts and entertainment as

discussed in the Firm’s Compliance Manual.

(b)An Access Person may not serve as an officer, director, partner, manager,

consultant, trustee, member of an advisory board or employee of, or

have a substantial interest in or business relationship with, a competitor

of the Firm.

(c)An Access Person must disclose to the CCO any personal or family interest

in any transaction being considered by the Firm on behalf of a Client

(apart from your interest in the transaction as an Investor in a Fund).

(d)An Access Person may not knowingly borrow from, or become indebted

to, any person, business or company having business dealings or a

relationship with the Firm, except with respect to customary personal

loans (e.g., home mortgage loans, automobile loans, lines of credit) on

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the same terms as are available generally, unless the arrangement is

approved by the CCO.

(e)An Access Person may not acquire, or derive personal gain or profit from,

any business or investment opportunity that comes to his or her

attention as a result of his or her association with the Firm, and in which

the Access Person knows the Firm or one of its Clients might reasonably

be expected to participate or have an interest, without first disclosing in

writing all relevant facts to the Firm, offering the opportunity to the Firm,

and receiving specific authorization from the CCO.

II.PERSONAL TRADING POLICIES AND PROCEDURES

In recognition of the Firm’s fiduciary obligations to its Clients and desire to maintain its high ethical

standards, the Firm has adopted the personal trading restrictions and requirements described

below to: (i) prevent improper personal trading by Access Persons; (ii) prevent improper use of

material, non-public information about securities recommendations made by the Firm or

securities holdings of Clients; (iii) identify conflicts of interest; and (iv) provide a means to resolve

any actual or potential conflict in favor of the Client.

The Firm’s goal is to allow its Access Persons to engage a moderate number of personal securities

transactions while protecting its Clients, the Firm, and its Access Persons from the conflicts that

could result from a violation of the securities laws or from real or apparent conflicts of interests.

While it is impossible to define all situations that might pose such a risk, this Code of Ethics is

designed to address those circumstances where such risks have been identified and may be likely

to arise.

Adherence to the Code of Ethics and the related restrictions on personal investing is considered

a basic condition of employment for Access Persons. If there is any doubt as to the propriety of

any activity, Access Persons should consult with the CCO or the CCO’s designee, who is charged

with the administration of this Code of Ethics, has general compliance responsibility for the Firm

and may offer guidance on securities laws and acceptable practices, as they may change from

time to time. The CCO may rely upon the advice of outside legal counsel or third-party compliance

consultants, as deemed necessary.

D.Accounts Covered by Policies and Procedures

This Code of Ethics applies to all “Personal Accounts” which includes any account in which

an Access Person has any Beneficial Ownership29 and to all accounts maintained by or for:

29 Beneficial ownership includes ownership by any person who, directly or indirectly, through any contract, agreement

understanding, relationship or otherwise, (i) has or shares a direct or indirect financial interest in other than the receipt of an

advisory fee, or (ii) possesses voting or investment power over securities or other investments.

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1.An Access Person’s spouse (other than a legally separated or divorced spouse of the

Access Person) and minor children;

2.Any family member living in the same household as the Access Person;

3.Any accounts over whose purchases, sales, or other trading activities the Access

Person exercises control or investment discretion;

4.Any persons to whom the Access Person provides primary financial support, and

either (i) whose financial affairs the Access Person controls, or (ii) for whom the Access

Person provides discretionary advisory services;

5.Any trust or other arrangement of which the Access Person or any member of the

Access Person’s immediate family sharing the same household as the Access Person is a

beneficiary; and

6.Any partnership, corporation, or other entity of which the Access Person is a director,

officer or partner or in which the Access Person has a 25% or greater beneficial interest,

or in which the Access Person owns a controlling interest or exercises effective control.

Notwithstanding the above, a Personal Account shall not include:

1.Any account that can invest only in open-end investment companies (mutual funds);

2.A 401(k) or Section 529 account or plan that is limited to investments in open-end

investment companies (mutual funds);

3.Any account for which the Access Person serves as trustee of a trust for the benefit

of a person to whom the Access Person does not provide primary financial support or that

of an independent third party; and

4.A Client account that is managed by the Firm.

E.Restrictions on Personal Trading

It is the responsibility of each Access 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 of Ethics or otherwise prohibited by any applicable laws. Personal

securities transactions for Access Persons may be affected only in accordance with the

provisions of this Code of Ethics. Generally:

1.No Access Person may knowingly purchase or sell for any Personal Account any security,

directly or indirectly, in such a way as to adversely affect a Client’s transactions.

2.The CCO will maintain a “Restricted List” that will apply to the Clients as well as Access

Persons. A security may be added to the Restricted List for a variety of reasons, including,

but not limited to: the Firm is in possession of material, non-public information about an

issuer; the Firm has executed a non-disclosure agreement or other agreement with a

specific issuer that restricts trading in the issuer’s securities; an Access Person’s trading in

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such Reportable Position may present the appearance of a conflict of interest or an actual

conflict of interest; and the CCO has determined it is necessary to do so.

3.No Access Person may directly or indirectly purchase or sell (long or short) for any

Personal Account any shares of a security listed on the Restricted List. Whenever an

issuer’s security is on the Restricted List, all securities of such issuer should be considered

and treated as being on the Restricted List (including common stock, preferred stock,

convertible debt, debt and options).

4.No Access Person may directly or indirectly purchase or sell (long or short) for any

Personal Account any shares of a security held in a Client account.

5.No Access Person may use his or her knowledge of Client transactions to cause any

Personal Account to profit from the market effect of such transactions (or give such

information to a third person who may so profit from such transactions).

6.Investments in ETFs managed by the Firm must be held for a minimum of 30 days.

Roundtrip transactions are measured from the time of purchase or exchange purchase

followed by a sell or exchange sell. Covered person may NOT be short in any ETF managed

by the Firm.

F.Pre-Clearance

An Access Person must obtain the prior written approval of the CCO before engaging in

any transaction in a “Reportable Security” in any of his or her Personal Accounts, except

no pre-clearance is required for transactions in exchange traded funds (“ETFs”) not

managed by the Firm. Access Person’s investment in ETF’s managed by the Firm must

obtain prior written approval of the CCO before transaction in the security. For avoidance

of doubt, transactions in ETFs must be reported in accordance with the procedures in this

Code of Ethics.

A “Reportable Security”30 is any type of security except (i) a direct obligation of the U.S.

Government (i.e. treasury obligations); (ii) a bankers’ acceptance, bank certificate of

deposit, commercial paper and high quality short-term debt instrument, including a

repurchase agreement; (iii) shares issued by money market funds; (iv) shares issued by a

registered, open-end investment company (mutual funds) for which the Firm does not act

as investment adviser or sub-adviser; and (v) shares issued by unit investment trusts that

are invested exclusively in mutual funds for which the Firm does not act as investment

adviser or sub-adviser.

30 Under the Advisers Act, a “security” means any note, stock, treasury stock, security future, bond, debenture, evidence of

indebtedness, certificate of interest or participation in any profit-sharing agreement, collateral-trust certificate, preorganization

certificate or 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 on any security

(including a certificate of deposit) or on any group or index of securities (including any 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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Pre-clearance is also required for purchase of any security in an initial public offering

(“IPO”) or in a private offering conducted pursuant to Section 4(2) or 4(5) of the Securities

Act of 1933, as amended, or Regulation D thereunder for any Personal Account. When

investing in a private offering, an Access Person must identify and report any potential

conflicts of interest to the CCO as they arise.

A request for pre-clearance may be made by submitting a request in advance of the

contemplated transaction. A sample Pre-Clearance Form is also attached hereto as

Exhibit 2. Any approval given under this paragraph will remain in effect only for that same

trading day in which the request was submitted; good-until-cancel trade orders are not

permitted. The CCO is responsible for maintaining a record of all pre-clearance requests.

In all cases, the CCO will determine whether approval should be given by comparing to

Client transactions and monitoring the Firm’s trade recommendations. Additionally, the

CCO will have the authority to grant exceptions or waivers if deemed appropriate; these

will be granted on a case-by-case basis if the Access Person’s trading does not

disadvantage any Client.

III.REPORTING REQUIREMENTS

All Access Persons are required to submit to the CCO the following reports:

A.Initial Holdings Report

Access Persons are required to provide the CCO with an Initial Holdings Report within ten

(10) days of the date that such person is hired, or became an Access Person, that discloses

details of all of the Access Person’s current Reportable Securities holdings in his or her

Personal Accounts. A sample reporting form is attached hereto as Exhibit 3. Information

contained in Initial Holding Reports must be current as of a date no more than forty-five

(45) days prior to the date of submission.

B.Annual Holdings Report

Access Persons must provide the CCO with an Annual Holdings Report of details of all

current Reportable Securities holdings in their Personal Accounts at year-end, December

31. A sample reporting form is attached hereto as Exhibit 3. Access Persons are expected

to report holdings to the CCO by January 30.

C.Quarterly Transactions Reports

Access Persons must provide the CCO with a Quarterly Transactions Report including

details of each transaction in a Reportable Security in their Personal Accounts for the most

recent quarter ended. A sample reporting form is attached hereto as Exhibit 3. Access

Persons must submit Quarterly Transactions Reports within thirty (30) days of the end of

each calendar quarter. Any trades of Reportable Securities that did not occur through a

broker-dealer, such as the purchase of a private fund, must be pre-cleared (as described

in this Code of Ethics) and affirmed through the Access Person’s quarterly transaction

affirmation. Any provided quarterly transaction reports must meet the following

requirements:

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Content Requirements – Quarterly transaction report must include:

•date of transaction;

•title of Reportable Security;

•ticker symbol or CUSIP number of Reportable Security (as applicable);

•interest rate or maturity rate (if applicable);

•number of shares;

•principal amount of Reportable Security;

•nature of transaction (i.e., purchase or sale);

•price of reportable security at which the transaction was effected;

•the name of broker, dealer or bank through which the transaction was effected;

•the date upon which the Access Person submitted the report.

If an Access Person opens a personal account with a brokerage firm after submitting his

or her initial or annual holdings report (as applicable), such Access Person must inform

the CCO to ensure that the holdings and transactions in such account are properly

reported in accordance with the reporting requirements above. Access Persons must

provide duplicate copies of trade confirmations and/or brokerage account statements

within thirty (30) days of the end of the applicable calendar quarter. A request letter to

broker for duplicate statements, attached hereto as Exhibit 4, is used for this purpose.

IV.EXCEPTIONS FROM PRECLEARANCE AND TRANSACTION REPORTING REQUIREMENTS

The following transactions are exempt from the preclearance and quarterly transaction reporting

requirements discussed above.

A.Purchases or sales that are non-volitional on the part of the Access Person such as

purchases that are made pursuant to a merger, tender offer or exercise of rights,

dividends, or reinvestment of dividends (except holdings need to be included on Initial

and Annual Holdings Reports);

B.Purchases or sales with respect to securities held in any Personal Account over which the

Access Person has no discretion over (i.e., a financial advisor traded account, an

investment club, etc.) (“Non-Discretionary Account”). The CCO has authority under this

Code of Ethics to determine at any time whether a particular account qualifies or

continues to qualify as a Non-Discretionary Account, whether additional information

should be provided by the relevant Access Person or whether additional steps must be

taken by the relevant Access Person in order to maintain Non-Discretionary Account

status for the relevant account. Access Persons with a Non-Discretionary Account must

annually certify to the CCO in the form contained in Exhibit 1 to this Code of Ethics;

C.Quarterly Transaction Reports are not required if the report would duplicate information

contained in broker trade confirm or account statements that an Access Person has

already provided to the CCO; provided, that such broker trade confirm or account

statements are provided to the CCO within 30 days of the end of the applicable calendar

quarter. A sample letter for requesting duplicate account statements and trade

confirmations be provided directly to the CCO by the broker is attached as Exhibit 4 to

this Code of Ethics; and

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D.Transactions in securities that are not Reportable Securities (i.e. treasury obligations and

shares in mutual funds), as defined above.

V.OVERSIGHT OF CODE OF ETHICS

A.Reporting

Any situation that may involve a conflict of interest or other possible violation of this Code

of Ethics must be promptly reported to the CCO who must report it to executive

management. All Access Persons are required to promptly report any violation of this

Code of Ethics they become aware of to the CCO or, in the event the violation involves

the CCO, to the Managing Partner. The Firm expects Access Persons who violate this

Code of Ethics to report their own violations, especially if a violation is inadvertent or

of a technical nature

B.Review of Transactions

Each Access Person’s transactions in his/her Personal Accounts may be reviewed on a

regular basis and compared to transactions entered into by the Firm on behalf of Clients.

Any transactions that are believed to be a violation of this Code of Ethics will be reported

promptly to the CCO who must report them to the executive management.

Notwithstanding any prior receipt of approval of a transaction in a Personal Account, the

CCO and/or the Firm’s principal(s) will review all such transactions(s) at a suitable time,

and they reserve the right to cancel any transaction(s) upon review. For example, after

reviewing any transaction where a Client and an Access Person have effectively traded

the same security in close proximity to each other, the CCO may determine that in order

to avoid even the appearance of impropriety, the Access Person’s transaction must be

cancelled or any profits gained or losses avoided may be owed to the Client(s) or to the

charity of the Access Person’s choice even though all compliance requirements had been

met.

C.Approval of CCO’s Requests and Reports

The Managing Partner or the Managing Partner’s designee is responsible for reviewing

and approving any requests or reports submitted by the CCO under this Code of Ethics.

VI.CONFIDENTIALITY

All reports of securities transactions and any other information filed pursuant to this Code of

Ethics shall be treated as confidential to the extent permitted by law.

VII.ACKNOWLEDGMENT

All Access Persons are required to provide the Firm with a written acknowledgment of his or her

receipt of this Code of Ethics and any amendments thereto. Attached hereto as Exhibit 1 is a form

of acknowledgement.

VIII.EXHIBITS

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See next page for Code Exhibits.

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