5. ACM Code of Ethics 01.02.2025 FINAL

APPENDIX H - CODE OF ETHICS

Adopted Under Rule 17j-1 and Rule 204A-1

Adopted August 1, 2009 - Revised January 2, 2025

I.STATEMENT OF POLICY

Akre Capital Management, LLC (the “Adviser”) is confident that its supervised persons (e.g.

officers, directors, and employees) act with integrity and good faith. The Adviser recognizes,

however, that personal interests may conflict with client interests, including those of the Akre

Focus Fund (the “Mutual Fund”) and the Akre Focus ETF (the “ETF”) (both a “Fund”, collectively,

the “Funds”), when its supervised persons:

oKnow about the client’s and Fund’s present or future portfolio transactions; or

oHave the power to influence client and Fund portfolio transactions; and

oEngage in Securities transactions for their personal account(s).

In an effort to prevent any conflicts from arising and in accordance with Rule 17j-1(c)(1) under the

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

Investment Advisers Act of 1940, as amended (the “Advisers Act”), the Adviser has adopted this

Code of Ethics (the “Code”) to address transactions that may create or appear to create conflicts

of interest and to establish reporting requirements and enforcement procedures.

II.ABOUT THE CODE

A.Who is covered by the Code?

All of the Adviser’s supervised persons, which includes:

•All of the Adviser’s officers

•All of the Adviser’s managing members or directors (or persons occupying

a similar status)

•All of the Adviser’s employees

•Any other person who provides investment advice on behalf of the

Adviser and is subject to the supervision and control of the Adviser (e.g.,

consultants)

B.What rules apply?

This Code sets forth specific prohibitions regarding Securities transactions. All of

the Adviser’s supervised persons are considered access persons, as defined in the

Appendix H Definitions attached hereto. As such, the prohibitions and

restrictions contained in this Code are universally applicable. The Code also sets

out certain reporting requirements applicable to access persons.

III.GENERAL PRINCIPLES

In recognition of the trust and confidence placed in the Adviser by the Adviser’s clients, including

the Funds, and because the Adviser believes that its operations should benefit all clients and the

Funds’ shareholders, the Adviser has adopted the following universally applicable principles:

•The interests of the Adviser’s clients and the Funds’ shareholders are

paramount. Client and shareholder interests must be placed before

personal interest.

•All personal Securities transactions must be accomplished in a manner

that avoids conflict between a supervised person’s interest and those of

the Adviser’s clients and the Funds and their shareholders.

•Supervised persons must avoid actions or activities that allow (or appear

to allow) their family to benefit from their position with the Adviser or

that bring into question their independence or judgment.

•Supervised persons must comply with applicable federal securities laws.

IV.PROHIBITIONS AGAINST FRAUD, DECEIT, AND MANIPULATION

A supervised person cannot, in connection with the purchase or sale, directly or indirectly, of a

Security held or to be acquired by a client or the Funds:

•Employ any device, scheme, or artifice to defraud clients or the Funds.

•Make to clients or the Funds any untrue statement of a material fact or

omit to state to a client or the Funds a material fact necessary in order to

make the statements made, in light of the circumstances under which

they are made, not misleading.

•Engage in any act, practice, or course of business which would operate as

a fraud or deceit upon clients or the Funds.

•Engage in any manipulative practice with respect to clients or the Funds.

V.LIMITS ON ACCEPTING OR RECEIVING GIFTS

A supervised person may not accept or receive any gift of more than de minimis value from any

person or entity in connection with a client’s or the Funds’ entry into a contract, development of

an economic relationship, or other course of dealing by or on behalf of a client or the Funds.

For purposes of this Code the term “de minimus” means a gift with a value of less than $100.

VI.INSIDER TRADING PROCEDURES

The Adviser’s Policy and Procedures to Detect and Prevent Insider Trading apply to all supervised

persons of the Adviser. To access this policy, please refer to Appendix G.

VII.RESTRICTIONS ON PERSONAL SECURITIES TRANSACTIONS

A.Except as provided below, an access person may not conduct a transaction with

respect to any Security in which such person has (or by reason of such transaction

acquires) beneficial ownership without obtaining the prior written or electronic

approval of the Adviser’s Managing Member, Compliance Officer, or designated

Adviser personnel. A sample Approval Request Form is on Attachment A of this

Appendix H.

Note: Prior approval is not required for:

1.Transactions in direct obligations of the Government of the United

States; bankers’ acceptances, bank certificates of deposit, commercial

paper, and high-quality short-term debt instruments, including

repurchase agreements; or shares issued by registered open-end funds

(other than reportable funds and exchange traded funds);

2.Purchases or sales that are non-volitional on the part of the access person

such as purchases or acquisitions arising from stock dividends, dividend

reinvestments, stock splits, mergers, consolidations, tender offers, or

exercise of rights;

3.Purchases or sales pursuant to an automatic investment plan; and

4.Transactions effected in any account over which the access person has

no direct or indirect influence or control (e.g., blind trust, discretionary

account, or trust managed by a third party) provided that (a) the access

person obtains approval of the Compliance Officer that the account

qualifies as a non-control account and (b) the access person provides a

certification that the access person has no direct or indirect influence or

control over the account at time of the initial request for approval and

quarterly thereafter (each such account, a “Non-Control Account”).

Upon approval, an executed copy of an Approval Request Form or equivalent

must be provided by the access person to the Adviser’s trader. In all instances,

the Adviser’s Portfolio Manager must be notified of the pre-clearance request

and approval and the Securities to which such request relates. Approvals for

transactions are valid only for the trading day on which they are granted.

B.An access person cannot purchase or sell, directly or indirectly, any Security in

which such person has (or by reason of such transaction acquires) any beneficial

ownership on the same day as the same (or a related) Security is being purchased

or sold or is being considered for purchase or sale by a client or the Funds. The

Adviser’s trader must notify the Compliance Officer when a client order for a

Security in which an access person has been pre-cleared to trade on that day is

submitted to the trader.

Notwithstanding the above, it shall not be a violation of the Code if an

access person purchases or sells shares of the Funds after obtaining pre-clearance

for the transaction, as required under section VII (A) above of the Code, on the

same day as a Security for the Funds is being purchased or sold or is being

considered for purchase or sale by a client of the Adviser.

C.Pre-Approval of Investments in IPOs and Limited Offerings:

Notwithstanding any other provision of this Code, an access person must

obtain written or electronic approval from the Managing Member, CEO,

Compliance Officer, or designated Adviser personnel before acquiring beneficial

ownership of any Securities in an initial public offering or a limited offering. (For

such transactions by the Managing Member or CEO, the Compliance Officer must

pre-approve the transaction. For such transactions by the Compliance Officer,

the CEO or Managing Member must pre-approve the transaction.)

VIII.REPORTING REQUIREMENTS

All access persons must comply with the reporting requirements set forth in this Code.

IX.REVIEW AND ENFORCEMENT OF THE ADVISER’S CODE

A.Appointment of a Review Officer

The Chief Compliance Officer shall be the Review Officer and shall perform the

duties described in Section B below. The CCO will provide the name of the Review

Officer to each access person at the time each such person becomes an access

person.

B.The Review Officer’s Duties and Responsibilities

•The Review Officer shall notify each person who becomes an access

person of the reporting obligations under this Code at the time such

person becomes an access person.

•The Review Officer will, on a quarterly basis, compare all approved pre-

clearance requests and personal Securities transactions reported

pursuant to this Code with the completed Securities transactions of the

Adviser’s clients and a list of Securities being considered for purchase or

sale by the Adviser, to determine whether a Code violation may have

occurred. Before determining that an access person has violated the

Code, the Review Officer must give the access person an opportunity to

supply explanatory material.

•If the Review Officer determines that a Code violation has or may have

occurred, the Review Officer must submit the determination, together

with the confidential quarterly report and any explanatory material

provided by the person, to the Managing Member or CEO. The Managing

Member or CEO and Review Officer will determine whether the access

person violated the Code.

•No access person is required to participate in a determination of whether

he or she has committed a Code violation or discuss the imposition of any

sanction against himself or herself.

•The Review Officer will request pre-clearance for Securities transactions

and report on a quarterly basis his or her own Securities transactions to

an Alternate Review Officer, which Alternate Review Officer shall

otherwise fulfill the duties of the Review Officer with respect to such

activities.

C.Resolutions; Sanction(s)

If an access person has violated the Code, the Review Officer will approve a

proposed resolution of the situation or, if appropriate and in consultation with

the Managing Member or CEO, impose upon the person sanctions that the

Review Officer deems appropriate and will report the violation and the resolution

and/or sanction imposed to the Funds’ Board of Trustees at the next regularly

scheduled board meeting unless, in the sole discretion of the Managing Member

or CEO, circumstances warrant an earlier report. If the Review Officer believes

that the Managing Member or CEO has violated the Code, the Review Officer shall

confer with the Adviser’s legal counsel.

X.ANNUAL WRITTEN REPORT TO THE BOARD

At least once a year, the Adviser will provide to the Funds’ Board of Trustees a written report that

includes the following.

•Issues Arising Under the Code: The report will describe any issue(s) that

arose during the previous year under the Code or procedures thereto,

including any material Code or procedural violation(s) and any resulting

sanction(s); and

•Certification and Adoption: The report will certify to the Board that the

Adviser has adopted measures reasonably necessary to prevent its access

persons from violating the Code.

XI.INTERRELATIONSHIP WITH THE FUNDS’ CODE OF ETHICS

A.General Principle

A person, who is both an Officer and/or Trustee of the Funds and an access person

of the Adviser, is only required to report under this Code of Ethics.

B.Procedures

The Adviser shall:

•Submit to the Board of Trustees of the Funds a copy of this Code of Ethics.

•Promptly furnish to the Funds, upon request, copies of any reports made

under this Code of Ethics by any person who is also covered by the Funds’

code of ethics.

•Promptly report to the Funds in writing any material amendments to this

Code of Ethics.

•Immediately furnish to the Funds, without request, all material

information regarding any violation of this Code of Ethics by any person.

XII.RECORDKEEPING

The Adviser will maintain records as set forth below. These records will be maintained in

accordance with Rule 31a-2 under the 1940 Act, Rule 204-2 under the Advisers Act, and the

following requirements. They will be available for examination by representatives of the Securities

and Exchange Commission. For the complete Policy and Procedures relating to Record Keeping,

please refer to Appendix P.

A.A copy of this Code and any other code which is, or at any time within the past

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

B.A record of any Code violation and of any sanctions taken will be preserved in an

easily accessible place for a period of not less than five years following the end of

the fiscal year in which the violation occurred.

C.A copy of each report made by an access person under this Code will be preserved

for a period of not less than five years from the end of the fiscal year in which it

is made, the first two years in an easily accessible place.

D.A record of all persons who are, or within the past five years have been, required

to submit reports under this Code, or who are or were responsible for reviewing

these reports, will be maintained in an easily accessible place.

E.A copy of each annual written report to the Board, required by Section X of this

Code, must be maintained for at least five years from the end of the fiscal year in

which it is made, the first two years in an easily accessible place.

F.The Adviser must maintain a record of any decision, and the reasons supporting

the decision, to approve the acquisition by access persons of securities acquired

in an IPO or limited offering, for at least five years after the end of the fiscal year

in which the approval is granted.

XIII.MISCELLANEOUS

A.Confidentiality

Except as otherwise provided herein, all personal securities transactions reports

and any other information filed under this Code of Ethics will be treated as

confidential, provided that such reports and related information may be

produced to the Securities and Exchange Commission and other regulatory

agencies.

B.Reporting Responsibility

The Adviser’s supervised persons shall report any violations of this Code promptly

to the Compliance Officer.

C.Interpretation of Provisions

The Managing Member or CEO may from time to time adopt written

interpretations or waivers of this Code as he deems appropriate. The Managing

Member or CEO may not, however, grant a waiver of any provision required by

SEC regulations.

D.Compliance Certification

The Adviser shall provide each of its supervised persons with a copy of this Code

of Ethics and any amendments thereto. Every year, each of the Adviser’s

supervised persons must certify that he or she has read, understood, and

complied with this Code and the reporting requirements of this Code of Ethics.

An Annual Compliance Certification is attached as Attachment D to this Appendix

H, and the certification may also be completed electronically. The Compliance

Officer or his designee shall certify that the Annual Compliance Certifications

were received in accordance with the dates defined.

XIV.PART A - OFFICERS, DIRECTORS AND EMPLOYEES

A.Initial Holdings Report

Each access person must submit to the Review Officer a listing of all Securities

beneficially owned by such person within 10 days of the date such person first

becomes an access person of the Adviser. The information contained in the report

must be current as of a date no more than 45 days prior to the date the person

becomes an access person. A sample Initial Holdings Report is attached as

Attachment B1 to this Appendix H, and the report may also be completed

electronically.

The report must contain the following information:

•The title, number of shares, and principal amount of each Security;

•The name of any broker, dealer, or bank with whom such person

maintains an account in which Securities are held; and

•The date the report is submitted.

B.Annual Holdings Report

By February 10th of each year, each access person must submit to the Review

Officer a report disclosing the Securities such person beneficially owned as of

December 31st of the previous calendar year. The report must contain the same

information as the Initial Holdings Report. A sample Annual Holdings Report Form is

attached as Attachment B2 to this Appendix H, and the report may also be completed

electronically.

Note: The Adviser will, on behalf of each access person, maintain information

with respect to such person’s beneficial ownership of any interest or limited

partnerships or similar entities managed by the Adviser.

C.Required Transaction Reports

•Quarterly Transaction Reports and Accounts Established

oOn a quarterly basis, each access person must report transactions in

Securities as well as any Security accounts established during the

quarter. Such person must submit his or her report to the Review

Officer no later than 10 days after the end of the calendar quarter in

which the transaction to which the report relates was effected or an

account was established. A Sample Quarterly Personal Securities

Transactions Report Form is included as Attachment C to this

Appendix H, and the report may also be completed electronically.

oIf an access person had no reportable transactions or did not open

any Security accounts during the quarter, such person is still required

to submit a report. Please note on the report that there were no

reportable transactions during the quarter, and return it, signed and

dated.

oRemember: Access persons of the Adviser are not required to report

their transactions under the Funds’ code of ethics if they are required

to file reports under this Code.

•What Securities Transactions and Accounts are Covered Under the

Quarterly Reporting Obligations?

Each access person must report all transactions in Securities in which

such person had or acquired any direct or indirect beneficial ownership.

The report must contain the following information:

oThe date of the transaction, the title, the interest rate, maturity date

(if applicable), the number of shares, and the principal amount of

each Security;

oThe nature of the transaction (i.e., purchase, sale, or any other type

of acquisition or disposition);

oThe price of the Security at which the transaction was effected;

oThe name of the broker, dealer, or bank with or through which the

transaction was effected; and

oThe date the report is submitted.

Each access person must also report any account such person established in

which Securities were held for such person’s direct or indirect benefit (i.e.,

beneficial ownership) during the quarter. The report must contain the

following information:

oThe name of the broker, dealer, or bank with whom such person

established the account;

oThe date the account was established; and

oThe date the report is submitted.

•What Securities Transactions May Be Excluded from the Report?

An access person is not required to detail or list the following Securities or

transactions on such person’s report:

oPurchases or sales effected for any Non-Control Account.

oPurchases such person made solely with the dividend proceeds

received in a dividend reinvestment plan or that are part of an

automatic payroll deduction plan, where such person purchases

Securities issued by his or her employer.

oPurchases arising from the exercise of rights issued by an issuer pro

rata to all holders of a class of its Securities, as long as such person

acquired these rights from the issuer, and sales of such rights so

acquired.

oPurchases or sales which are non-volitional on the part of the person,

including purchases or sales upon exercise of puts or calls written by

the person and sales from a margin account to a bona fide margin

call.

An access person may include a statement in such person’s report that

the report shall not be construed as his or her admission that he or she

has any direct or indirect beneficial ownership in the Security included in

the report.

•Alternate Transaction Reporting

In lieu of providing the transaction reports set forth above, access

persons may direct their brokers to supply the Review Officer on a timely

basis (i.e., so that the Adviser receives the information no later than 10

days after the end of the applicable calendar quarter), duplicate copies

of confirmations and monthly/quarterly brokerage statements for all

Securities transactions; provided that such confirmation and statements

contain the information required to be reported in the transaction

reports. If an access person elects to comply with the transaction

reporting requirements of the Code using this alternate transaction

reporting method, the access person must certify quarterly in writing that

the duplicate confirmations and statements reflect all reportable

transaction activity by the access person during the period and that any

new brokerage accounts have been disclosed.

Definitions

Access person means any supervised person of the Adviser who (a) has access to

nonpublic information regarding any client’s purchase or sale of securities or nonpublic

information regarding the portfolio holdings of any reportable fund, or (b) is involved in

making securities recommendations to clients, or who has access to such

recommendations that are nonpublic.

Automatic investment plan means a program in which regular periodic purchases (or

withdrawals) are made automatically in (or from) investment accounts in accordance with

a predetermined schedule and allocation, including a dividend reinvestment plan.

Beneficial ownership means ownership by any person who, directly or indirectly, through

any contract, arrangement, understanding, relationship, or otherwise, has or shares a

direct or indirect financial interest, other than the receipt of an advisory fee. Beneficial

ownership of an account or Security by an access person includes ownership of an

account or Security by:

oThe access person’s spouse (other than a legally separated or divorced spouse of

the person) and minor children;

oAny immediate family member who lives in the access person’s household,

including stepchildren, grandchildren, parents, stepparents, grandparents,

brothers, sisters, parents-in-law, sons-in-laws, daughters-in-law, brothers-in-law,

sisters-in-law, and adoptive relationships;

oAny 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; and

oAny partnership, corporation, or other entity of which the access person has a

25% or greater interest or exercises effective control (provided, however, that

the following entities are not deemed to be beneficially owned by an access

person: Braddock Partners, LP; Braddock Partners Offshore, Ltd.; and Braddock

Partners Offshore, LP).

Control means the same as it does under in Section 2(a)(9) of the 1940 Act. Section 2(a)(9)

provides that "control" means the power to exercise a controlling influence over the

management or policies of a company, unless such power is solely the result of an official

position with such company. Ownership of more than 25% of a company's outstanding

voting securities is presumed to give the holder of such securities control over the

company. This presumption may be countered by the facts and circumstances of a given

situation.

Federal securities laws mean the Securities Act of 1933, the Securities Exchange Act of

1934, the Sarbanes-Oxley Act of 2002, the Investment Company Act of 1940, the

Investment Advisers Act of 1940, Title V of the Gramm-Leach-Bliley Act, any rules adopted

by the Securities and Exchange Commission under any of these statutes, the Bank Secrecy

Act as it applies to funds and investment advisers, and any rules adopted thereunder.

Initial public offering (IPO) means an offering of securities registered under the Securities

Act of 1933, the issuer of which, immediately before registration, was not subject to the

reporting requirements of section 13 or section 15(d) of the Securities Exchange Act of

1934.

Limited offering means an offering that is exempt from registration under the Securities

Act of 1933 pursuant to section 4(2) or section 4(6) in the Securities Act of 1933 or

pursuant to Rule 504, Rule 505 or Rule 506 there under.

Managing Member means the managing member of Akre Capital Management, LLC.

Purchase or sale of a Security includes, among other things, the writing of an option to

purchase or sell a Security.

Reportable funds means any investment company registered under the Investment

Company Act of 1940 for which the Adviser serves as investment adviser or any fund

whose investment adviser or principal underwriter controls the Adviser, is controlled by

the Adviser, or is under common control with the Adviser.

Security means the same as it does under Section 2(a)(36) of the 1940 Act, except that it

does not include direct obligations of the U.S. Government or its agencies, bankers'

acceptances, bank certificates of deposit, commercial paper, high quality short-term debt

instruments, including repurchase agreements, and shares issued by open-end funds,

other than reportable funds and exchange traded funds. This is a very broad definition of

security. It includes most kinds of investment instruments, including things that you might

not ordinarily think of as “securities,” such as:

oCryptocurrency;

oShares issued by reportable funds and exchange-traded funds;

oFutures contracts and options on securities, indexes, and currencies;

oInvestments in all kinds of limited partnerships;

oInvestments in foreign unit trusts and foreign mutual funds; and

oInvestments in private investment funds and hedge funds.

If you have any question or doubt about whether an investment is considered a

Security under this Code, ask the Compliance Officer.

A Security held or to be acquired by a client or the Funds means:

oAny Security that, within the most recent 15 days, is or has been held by a client

or the Funds, or is being or has been considered by the Adviser for purchase by a

client or the Funds; and

oAny option to purchase or sell, and any Security convertible into or exchangeable

for any Security described above in the first bullet above.

A Security is being purchased or sold by a client or the Funds from the time a

purchase or sale program has been communicated to the person who places buy and sell

orders for the Funds until the program has been fully completed or terminated.

A Security is being considered for purchase or sale by a Fund when a Security is

identified as such by the Adviser.

A supervised person means any managing member, partner, officer, director (or other

person occupying a similar status or performing similar functions), or employee of the

Adviser, or other person who provides investment advice on behalf of the Adviser and is

subject to the supervision and control of the Adviser. The Adviser may deem other

individuals or entities, including temporary workers, independent contractors, and

consultants, as supervised persons and require those persons to comply with this Code.

Any such person with access to confidential or non-public information or who may have

access to the Adviser’s systems that contain information about current portfolio holdings

or transactions will be deemed an access person hereunder.

APPENDIX H – ATTACHMENT A – SAMPLE EMPLOYEE TRADING

REQUEST FORM

Account Information:

1.Name of Employee:

2.Name of Employee/Related Account:

3.Financial Institution:

Transaction Information:

4.Name of Security & Symbol:

5.Quantity / Dollar Amount for Mutual Funds: Buy: □or Sell: □or Short Sale: □

6.Common Stock □Put □Call □Convertible Bond □Maturity:Other:

Employees are required to give pre-clearance forms signed by the Adviser’s Managing Member, Chief

Compliance Officer, or designated Adviser personnel to the trader. In all instances, the Portfolio Manager will

be notified of pre-clearance requests and the securities to which such requests relate. Our trader has been

instructed to notify the Compliance Officer when a client order is given to the trader for a security in which an

employee has been pre-cleared to trade on that day.

I HEREBY CERTIFY THE FOLLOWING:

In making this application for approval for a transaction in an employee or employee related account, I hereby

represent that the investment decision regarding the transaction is not in any way based on material, non-

public information relating to the financial instrument that is the subject of the proposed transaction or the

issuer or obligor of such institution, advance knowledge of a research report to be published by the Company

or another financial institution, advance knowledge of a client order, or any other form or type of confidential

or proprietary information.

•THIS TRANSACTION DOES NOT INVOLVE THE ACQUISITION OF SECURITIES IN AN INITIAL PUBLIC

OFFERING OR A PRIVATE PLACEMENT.

•I AM NOT AWARE OF ANY CONFLICT OF INTEREST WITH ANY CLIENT ACCOUNT THAT WOULD EXIST AS

A RESULT OF THE PROPOSED TRADE.

I understand that if approval is granted, it only pertains to this proposed transaction and that such approval

is valid only on the date granted.


Date/Time:	Employee Signature:
Date/Time:	Authorized Signatory:

APPENDIX H – ATTACHMENT B1 - SAMPLE INITIAL HOLDINGS REPORT


To:	Compliance Officer
From:	[Covered Person]
Subject:	Personal Securities Transactions

Pursuant to the Code, Covered Persons must submit an initial holdings report and an updated annual

holdings report that lists all Reportable Securities (as defined in the Code) in which one has a direct or

indirect Beneficial Ownership (as defined in the Code).

An Initial Holdings Report must be submitted no later than 10 days after the date on which the

undersigned became a Covered Person. The information set forth in an Initial Holdings Report must be

current as of a date no more than 45 days prior to the date on which the report is submitted.


Date	Title of Security (including exchange ticker symbol or CUSIP #)	# of Shares	Principal Amount	Name of Broker, Dealer, or Bank Maintaining Account of Any Securities

# of additional pages that are attached, if applicable

I certify that the names of any brokerage firms or banks where I have an account in which any

securities are held are disclosed above, except for the following:


DATE:	SIGNATURE:
	PRINTED NAME:

APPENDIX H – ATTACHMENT B2 - SAMPLE ANNUAL HOLDINGS

REPORT

Name of Reporting Person:

Date Report Submitted:

Calendar Year Ended:

All information in this Report should be as of December 31st of the previous calendar year.


Title of Security (including exchange ticker symbol or CUSIP #)	# of Shares	Principal Amount

If you to disclaim beneficial ownership of one or more Securities reported above, please describe below

and indicate which Securities are at issue.

You may use separate pages for reporting transactions. Please indicate the number of attached pages

with further information: .


DATE:	SIGNATURE:
	PRINTED NAME:

Please return this form to the Compliance Officer not later than February 10th after the end of the previous

calendar year.

APPENDIX H – ATTACHMENT C - SAMPLE QUARTERLY TRANSACTION

REPORT

Please return this form to the Compliance Officer no later than 10 calendar days after the end of the

quarter.

Name of Reporting Person:

Date Report Submitted:

Calendar Quarter Ended:


Name of Issuer	Date of Transaction	Title of Security	# of Shares	Principal Amount	Type of Transaction (Purchase, Sale, or Short Sale	Price	Name of Broker, Dealer, or Bank Effecting Transaction

If you had no reportable transactions during the quarter, please check here.

If you established an account within the last quarter, please provide the following information:


Name of Broker, Dealer or Bank	Date Account was Established	Date Report Submitted by Access Person

If you did not establish a Securities account within the last quarter, please check here.

If you to disclaim beneficial ownership of one or more Securities reported above, please describe below

and indicate which Securities are at issue.

This report covers all transactions, except transactions in securities of ACM or the private funds sponsored

or managed by ACM. ACM maintains separate records corresponding to those transactions.

APPENDIX H – ATTACHMENT C - SAMPLE QUARTERLY TRANSACTION

REPORT


DATE:	SIGNATURE:
	PRINTED NAME:

APPENDIX H – ATTACHMENT D - CODE OF ETHICS - ANNUAL

CERTIFICATION

I certify that I have recently received, read, and reviewed the Akre Capital Management, LLC Code of

Ethics. I understand such policies and procedures and recognize that I am subject to them. I further certify

that I understand the Code of Ethics and agree to abide by it. I hereby represent that all my personal

securities transactions will be effected in compliance with the Code.

I certify that I am in full compliance with the firm’s Code of Ethics and understand the penalties for non-

compliance.


DATE:	SIGNATURE:
	PRINTED NAME: