The SEC’s Code of Ethics rules along with the FCA’s Conduct of Business rules govern TwentyFour Asset Management’s (“TwentyFourAM’s”, “the Firm’s”) Personal Account Dealing policy and procedures (PAD). The following describes the Firm’s policies and procedures pursuant to the SEC’s Code of Ethics rules. SEC Rule 204A- 1 under the Investment Advisers Act of 1940 and Rule 17j-1 under the Investment Company Act of 1940 (the Rules) requires each registered investment adviser to adopt and implement a written code of ethics that contains provisions regarding:

At all times, the Firm and its staff members must comply with the spirit and the letter of the U.S. Federal Securities Laws and the rules governing the capital markets. The CCO administers the Code of Ethics and PAD Policy (the “Code”). All questions regarding the Code should be directed to the CCO. Staff members must cooperate to the fullest extent reasonably requested by the CCO to enable (i) the Firm to comply with all applicable Federal Securities Laws and (ii) the CCO to discharge his or her duties under TwentyFourAM’s Compliance Manual (“the Manual”).

All staff members will act with competence, dignity, integrity, and in an ethical manner, when dealing with Clients, the public, prospects, third-party service providers and fellow staff members. Staff members must use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, trading, promoting the Firm’s services, and engaging in other professional activities.

The Firm expects all staff members to adhere to the highest standards with respect to any potential conflicts of interest with Clients. As a fiduciary, the Firm must act in its Clients’ best interests. Neither the Firm, nor any Employee should ever benefit at the expense of any Client. Notify the CCO promptly about any practice that creates, or gives the appearance of, a material conflict of interest.

Staff members are generally expected to discuss any perceived risks, or concerns about the Firm’s business practices, with their direct supervisor. However, if an Employee is uncomfortable discussing an issue with their supervisor, or if they believe that an issue has not been appropriately addressed, they should bring the matter to the CCO’s attention.

The Firm will describe its Code of Ethics in Part 2 of Form ADV and, upon request, furnish Clients and Investors with a copy of the Code of Ethics. All Client requests for the Firm’s Code of Ethics should be directed to the CCO.

Staff members must promptly report any suspected violations of the Code of Ethics to the CCO. To the extent practicable, the Firm will protect the identity of an Employee who reports a suspected violation. However, the Company remains responsible for satisfying the regulatory reporting, investigative and other obligations that may follow the reporting of a potential violation.

Retaliation against any Employee who reports a violation of the Code of Ethics is strictly prohibited and will be cause for corrective action, up to and including dismissal.

Violations of this Code of Ethics, or the other policies and procedures set forth in the Manual, may warrant sanctions including, without limitation, requiring that personal trades be reversed, requiring the disgorgement of profits or gifts, issuing a letter of caution or warning, suspending personal trading rights, imposing a fine, suspending employment (with or without compensation), making a civil referral to the SEC, making a criminal referral, terminating employment for cause, and/or a combination of the foregoing. Violations may also subject an Employee to civil, regulatory or criminal sanctions. No Employee will determine whether he or she committed a violation of the Code of Ethics, or impose any sanction against himself or herself. All sanctions and other actions taken will be in accordance with applicable employment laws and regulations.

Staff members must obtain pre-clearance from Compliance for, at a minimum, all transactions involving initial public offerings (IPOs) and private placements, and in line with the Firm’s PAD

Staff members must submit initial and annual reports of their securities holdings and accounts and quarterly reports of their securities transactions pursuant to the Rules.

The Code requires reporting of holdings and transactions in all accounts holding any Securities over which staff members have any beneficial ownership interest, which typically includes accounts held by immediate family members sharing the same household. Immediate family members include children, step-children, grandchildren, parents, step-parents, grandparents, spouses, domestic partners, siblings, parents-in-law, and children-in-law, as well as adoptive relationships that meet the above criteria.

It may be possible for staff members to exclude accounts held personally or by immediate family members sharing the same household if the Employee does not have any direct or indirect influence or control over the accounts, or if the Employee can rebut the presumption of beneficial ownership over family members’ accounts. Staff members should consult with the CCO before excluding any accounts held by immediate family members sharing the same household.

•	Shares issued by unit investment trusts that are invested exclusively in one or more open-end registered investment companies, none of which are advised or underwritten by the Firm or an affiliate.

Exchange-traded funds, or ETFs are somewhat similar to open-end registered investment companies. However, ETFs are Reportable Securities and are subject to the reporting requirements.

The Firm must collect information regarding the personal trading activities and holdings of all staff members. Staff members must submit quarterly reports regarding Securities transactions and newly opened accounts, as well as initial and annual reports regarding holdings and existing accounts.

Each quarter, staff members must report all Reportable Securities transactions in accounts in which they have a Beneficial Interest. Reports regarding Securities transactions must be submitted to the CCO within 30 days of the end of each calendar quarter.

The CCO must receive all such confirmations and statements within 30 days of the end of each calendar quarter. Any trades that did not occur through a broker-dealer, such as the purchase of a private fund, must be reported as well.

If an Employee did not have any transactions or account openings to report for the quarter, this should be indicated by the employee on a form as specified by the CCO. These certification forms should be submitted to the CCO within 30 days of the end of each calendar quarter.

Staff members must periodically report all Reportable Securities holdings. Reports regarding holdings must be submitted to the CCO on or before February 14^th of each year, and within 10 days of an individual first becoming an Employee. Annual reports must be current as of December 31^st; initial reports must be current as of a date no more than 45 days prior to the date that the person became an Employee.

In lieu of submitting a list of Reportable Securities, staff members may submit copies of account statements that contain all of the same information. Staff members should sign and date each such statement before submitting it to the CCO. Any Reportable Securities not appearing on an attached account statement must be reported directly to the CCO.

If an Employee does not have any holdings and/or accounts to report, this should be indicated on a form as specified by the CCO, which should be submitted to the CCO by February 14^th of each year.

Any reports with respect to Securities held in accounts over which the Employee had no direct or indirect influence or control, such as an account managed by an investment adviser on a discretionary basis.

Any investment plans or accounts that may be eligible for either of these exceptions should be brought to the attention of the CCO who will, on a case-by-case basis, determine whether the plan or account qualifies for an exception. In making this determination, the CCO may ask for supporting documentation, such as a copy of the Automatic Investment Plan, a copy of the discretionary account management agreement, and/or a written certification from an unaffiliated investment adviser.

The Firm’s Code is designed to mitigate any potential material conflicts of interest associated with staff members’ personal trading activities. Accordingly, the CCO will closely monitor staff members’ investment patterns to detect the following potentially abusive behavior:

The CCO will review all reports submitted pursuant to the Code for potentially abusive behavior, and will compare Employee trading with Clients’ trades as necessary. Any personal trading that appears abusive may result in further inquiry by the CCO and/or sanctions, up to and including dismissal.