Appendix B

BARROW, HANLEY, MEWHINNEY & STRAUSS, INC. 

CODE OF ETHICS

INTRODUCTION 

Barrow, Hanley, Mewhinney & Strauss, Inc. (the “Firm”) has adopted this Code of Ethics ("Code") in 

compliance with the requirements of Sections 204A-1 of the Investment Advisers Act of 1940 (the 

"Advisers Act") and Section 17j of the Investment Company Act of 1940. This Code was adopted on 

November 28, 1983 and last amended on December 31, 2009. This Code of Ethics requires the Firm’s 

supervised Persons to comply with the federal securities laws, sets forth standards of conduct expected of 

the Firm’s supervised Persons and addresses conflicts that arise from personal trading by Access 

Persons. The policies and procedures outlined in the Code of Ethics are intended to promote compliance 

with fiduciary standards by the Firm and its supervised Persons. As a fiduciary, the Firm has the 

responsibility to render professional, continuous and unbiased investment advice, owes its clients a duty of 

honesty, good faith and fair dealing, must act at all times in the best interests of clients and must avoid or 

disclose conflicts of interest. 

This code of ethics is designed to: 

nProtect the Firm’s clients by deterring misconduct; 

nEducate our employees regarding the Firm’s expectations and the laws governing their 

  conduct; 

nRemind employees that they are in a position of trust and must act with complete 

   propriety at all times; 

n Protect the reputation of the Firm; 

n Guard against violations of the securities laws; and 

n Establish procedures for employees to follow so that the Firm may determine whether 

   employees are complying with its ethical principals. 

This Code of Ethics is based upon the principle that the directors, officers and employees of the Firm owe 

a fiduciary duty to, among others, the clients of the Firm to conduct their affairs, including their personal 

securities transactions, in such a manner as to avoid: 

n Serving their own personal interests ahead of clients; 

n Taking inappropriate advantage of their position with the Firm; and 

n Any actual or potential conflicts of interest or any abuse of their position of trust and 

   responsibility. 

This fiduciary duty includes the duty of the Chief Compliance Officer of the Firm to periodically review and 

amend this Code of Ethics, report material violations of this Code to the Firm’s Board of Directors and any 

U.S. registered investment company client for which the Firm acts as adviser or sub-adviser. 

This Code contains provisions reasonably necessary to prevent supervised persons from engaging in acts 

in violation of the above standards, and procedures reasonably necessary to prevent violations of the 

Code. Each employee at the commencement of their employment and as an Access Person must certify, 

by their signature on Exhibit A, they have read and understand the Code’s requirements and their 

acknowledgement to abide by all of the Code’s provisions. Each employee must re-certify understanding 

and acknowledgement of the Code any time the Code is amended and/or annually. 

A.	DEFINITIONS
(1)	"Access Person” means any director, officer, general partner, advisory person,
investment personnel, portfolio manager, or employee of the firm.
(2)	"Advisory Person” means any natural person in a control relationship to the
	Firm who obtains information concerning recommendations made to the Firm
	with regard to the purchase or sale of a Security by the Firm

(3)	“Affiliated Company” means a company which is an affiliate of the Firm through
	the Old Mutual U.S. Holdings, Inc. relationship.
(4)	A security is "Being Considered for Purchase or Sale" or is "Being Purchased
	or Sold" when a recommendation to purchase or sell the security has been made
	and communicated, which includes when the Firm has a pending "buy" or "sell"
	order with respect to a Security, and, with respect to the person making the
	recommendation, when such person seriously considers making such a
	recommendation.
(5)	"Beneficial Ownership" shall be as defined in, and interpreted in the same
	manner as it would be in determining whether a person is subject to the
	provisions of, Section 16 of the Securities Exchange Act of 1934 and the rules
	and regulations hereunder which, generally speaking, encompasses those
	situations where the beneficial owner has the right to enjoy some economic
	benefit from the ownership of the Security. An Access Person is presumed to be
	the beneficial owner of an account where he/she has direct or indirect beneficial
	interest, and Securities held by his/her immediate family member sharing the
	same household.
(6)	"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. Any Person who owns beneficially, either
	directly or through one or more controlled companies, more than 25 per centum
	of the voting securities of a company shall be presumed to control such company.
	Any Person who does not so own more than 25 per centum of the voting
	securities of any company shall be presumed not to control such company. A
	natural Person shall be presumed not to be a control Person.
(7)	"Investment Personnel" means: (a) any Portfolio Manager of the Firm as
	defined in (10) below; and (b) securities analysts, traders and other personnel
	who provide information and advice to the Portfolio Manager or who help execute
	the Portfolio Manager's decisions.
(8)	“Nonresident Director” means any director of the Firm who: (a) is not an
	officer, employee or shareholder of the Firm; (b) does not maintain a business
	address at the Firm and (c) who does not, in the ordinary course of his business,
	receive or have access to current information regarding the purchase or sale of
	Securities by the Firm, information regarding recommendations concerning the
	purchase or sale of Securities by the Firm or information regarding Securities
	being considered for purchase or sale by the Firm.
(9)	“Person” means any natural Person or a company.
(10)	"Portfolio Manager" means an employee of the Firm entrusted with the direct
	responsibility and authority to make investment decisions.

(11)	“Reportable Fund” means any Fund for which the Firm serves as an Investment
	Adviser or Sub-Adviser.
(12)	"Security" means any note, stock, treasury stock, bond, debenture, unit trust-
	ETFs, evidence of indebtedness, certificate of interest or participation in any
	profit-sharing agreement, collateral-trust certificate, pre-organization 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 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, guarantee of, or
	warrant or right to subscribe to or purchase, any of the foregoing. Security shall
	not include: direct obligations of the Government of the United States, high quality
	short-term debt instruments, bankers' acceptances, bank certificates of deposit,
	commercial paper, repurchase agreements, and shares of registered open-end
	investment companies, other than shares of Reportable Funds, open-end ETFs,
	and UITs that are invested exclusively in one or more open-end fund (none of
	which are Reportable Funds.)
B.	POLICY STATEMENT ON INSIDER TRADING
	In compliance with Section 204A of the Advisers Act the Firm forbids any officer, director
	or employee from trading, either personally or on behalf of others, including accounts
	managed by the Firm, on material nonpublic information or communicating material
	nonpublic information to others in violation of the law, frequently referred to as "insider
	trading." The Firm's insider trading policy applies to every officer, director and employee
	and extends to activities within and outside their duties at the Firm, and any questions
	regarding this policy and procedures should be referred to the Firm’s Chief Compliance
	Officer.
	The term "insider trading" is not defined in the federal securities laws, but generally is
	used to refer to the use of material nonpublic information to trade in Securities (whether or
	not one is an "insider") or to communications of material nonpublic information to others.
	While the law concerning insider trading is not static, it is generally understood that the
	law prohibits:
	(1)	Trading by an insider, while in possession of material nonpublic information; or
	(2)	Trading by a non-insider, while in possession of material nonpublic information,
		where the information either was disclosed to the non-insider in violation of an
		insider's duty to keep it confidential or was misappropriated; or
	(3)	Communicating material nonpublic information to others in a breach of fiduciary
		duty.
	Trading on inside information is not a basis for liability unless the information is material.
	"Material information" generally is defined as information for which there is a substantial
	likelihood that a reasonable investor would consider it important in making his or her
	investment decisions, or information that is reasonably certain to have a substantial effect
	on the price of a company's Securities whether it is determined factual or spreading a
	rumor. Information that officers, directors and employees should consider material
	includes, but is not limited to: dividend changes, earnings estimates, changes in
	previously released earnings estimates, significant merger or acquisition proposals or
	agreements, major litigation, debt service and liquidation problems, extraordinary
	management developments, write-downs or write-offs of assets, additions to reserves for
	bad debts, new product/services announcements, criminal, civil and government

investigations and indictments. Material information does not have to relate to a 

company’s business. For example, material information about the contents of any 

upcoming newspaper column may affect the price of a Security, and therefore be 

considered material. Disclosure of a registered investment company client’s holdings or 

any client’s holdings that are not publicly available may be considered material 

information and therefore must be kept confidential. All employees of BHMS are subject 

to the Duty of Confidentiality, Item C of this Code. 

Information is nonpublic until it has been effectively communicated to the marketplace. 

One must be able to point to some fact to show that the information is generally public. 

For example, information found in a report filed with the SEC, or appearing in the media 

or other publications of general circulation would be considered public. One should be 

particularly careful with information received from client contacts at public companies. 

Each Person must consider the following before trading for themselves or others in the 

Securities of a company about which one has potential inside information: 

¨	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 disclosed?
¨	Is the information nonpublic? To whom has this information been
	provided? Has the information been effectively communicated to the
	marketplace?

The role of the Firm’s Chief Compliance Officer is critical to the implementation and 

maintenance of the Firm's policy and procedures against insider trading. If, after 

consideration of the above, a Person believes that the information is material and 

nonpublic, or if a Person has questions as to whether the information is material and 

nonpublic, he/she should take the following steps: 

¨	Report the matter immediately to the Firm’s Chief Compliance Officer.
¨	Do not purchase or sell the Securities on behalf of oneself or others.
¨	Do not communicate the information inside or outside the Firm, other
	than to the Firm’s Chief Compliance Officer.
¨	The Firm may determine to restrict trading in the securities personally or
	for clients’ portfolios.
¨	After the Firm’s Chief Compliance Officer has reviewed the issue, he/she
	will be instructed to continue the prohibitions against trading and
	communication, or he/she will be allowed to trade and communicate the
	information.

“Insider information” may not be communicated to anyone, including persons within the 

Firm, except as provided above. In addition, care should be taken so that such 

information is secure. For example, files containing material nonpublic information should 

be sealed; access to computer files containing material nonpublic information should be 

restricted. 

C.	DUTY OF CONFIDENTIALITY
	Employees of the Firm shall keep confidential at all times any nonpublic information they
	may obtain in the course of their employment at the Firm. This information includes but is
	not limited to:
	(1)	Information on the clients accounts, including account holdings, recent or
		impending Securities transactions by the clients and recommendations or
		activities of the Portfolio Managers for the clients’ accounts;

(2)	Information on the Firm’s clients and prospective clients investments and account
	transactions;
(3)	Information on other Firm personnel, including their pay, benefits, position level
	and performance rating; and
(4)	Information on the Firm’s business activities, including new services, products,
	technologies and business initiatives.
The Firm’s personnel have the highest fiduciary obligation not to reveal confidential
company information to any party that does not have a clear and compelling need to know
such information and to safeguard all client information. Our Privacy Policy for
safeguarding clients’ personal information is detailed in its entirety in our Compliance
Policies and Procedures, item 14, and is disclosed in our Form ADV Part II Schedule F.

D.	RESTRICTIONS FOR ACCESS PERSONS
	(1)	General Restrictions for Access Persons. As defined by this Code, all
		employees of the Firm are identified as Access Persons and are subject to the
		following restrictions with respect to their personal transactions:
		(a)	Prohibition on accepting gifts of more than de minimis value.
			Access Persons are prohibited from accepting any gift or other items of
			more than de minimis value from any Person or entity that does business
			with or on behalf of the Firm; for the purpose of this Code, de minimis
			shall be considered to be the annual receipt of gifts from the same
			source valued at up to $100 per individual recipient, when the gifts are in
			relation to the conduct of the Firm’s business. A gift does not include
			participation in lunches, dinners, cocktail parties, sporting activities or
			similar gatherings conducted for business purposes.
		(b)	Prohibition on service as a director or public official. Investment
			Personnel are prohibited from serving on the board of directors of any
			publicly traded company without prior authorization of the President or
			other duly authorized officer of the Firm. Any such authorization shall be
			based upon a determination that the board service would be consistent
			with the interests of the Firm's clients. Authorization of board service
			shall be subject to the implementation by the Firm of a "Chinese Wall" or
			other procedures to isolate such Investment Personnel from making
			decisions about trading in that company's securities.
		(c)	Prohibition on initial public offerings. Access Persons, who are not
			Nonresident Directors, are prohibited from acquiring Securities in an
			initial public offering. Nonresident Directors must receive pre-clearance
to purchase Securities in an initial public offering.
		(d)	Prohibition on private placements. Access Persons are prohibited
			from acquiring Securities in a private placement without prior approval
			from the Firm’s Chief Compliance Officer. In the event an Access
			Person receives approval to purchase Securities in a private placement,
			the Access Person must disclose that investment if he or she plays any
			part in the Firm’s later consideration of an investment in the issuer.
		(e)	Prohibition on options. Access Persons, who are not Nonresident
			Directors, are prohibited from acquiring or selling any option on any
			Security.

(f)	Prohibition on short-selling. Access Persons, who are not Nonresident
	Directors, are prohibited from selling any Security that the Access Person
	does not own, or otherwise engaging in “short-selling” activities.
(g)	Prohibition on short-term trading profits. Access Persons, who are
	not Nonresident Directors, are prohibited from profiting in the purchase
	and sale, or sale and purchase, of the same (or related) securities within
	sixty (60) calendar days. Trades made in violation of this prohibition
	should be unwound, if possible. Otherwise, any profits realized on such
	short-term trades shall be subject to disgorgement.
(h)	Prohibition on short-term trading of Reportable funds. Access
	Persons, who are not Nonresident Directors, are prohibited from short-
	term trading of any Reportable Fund shares. “Short-term trading” defined
	as a purchase and redemption/sell of a fund’s shares within a thirty-day
	period. This prohibition does not cover purchases and
	redemptions/sales: (i) into or out of money market funds or short term
	bond funds; (ii) purchases effected on a regular periodic basis by
	automated means, such as 401(k) purchases and Voluntary Deferral
	Plan “VDP” contributions.
(i)	Prohibition on certain political contributions. Access Person and
	their family members may not make political contributions in the name of
	the firm or personally for the purpose of obtaining or retaining advisory
	contracts with government entities or for any other business purpose.
	One also may not consider any of the firm’s current or anticipated
	business relationships as a factor in soliciting or making political or
	charitable donations. One may not make charitable contributions in the
	name of the firm or personally for the purpose of obtaining or retaining
	advisory contracts or for any other business purpose. An exception to this
	policy is that charitable contributions made as part of the firm’s formal
	charitable efforts may be made in the name of the firm payable directly to
	the tax-exempt charitable organization.

(2)	Blackout Restrictions for Access Persons. All Access Persons, who are not
	Nonresident Directors, are subject to the following restrictions when their purchases
	and sales of Securities coincide with trades by any client of the Firm:
	(a)	Purchases and sales within three days following a trade by a client.
		Access Persons are prohibited from purchasing or selling any Security
		within three calendar days after any client has traded in the same (or a
		related) Security. In the event that an Access Person makes a prohibited
		purchase or sale within the three-day period, the access Person must
		unwind the transaction and relinquish to the Firm any gain from the
		transaction.
	(b)	Purchases within seven days before a purchase by a client. Any
		Access Person who purchases a Security within seven calendar days
		before any client purchases the same (or a related) Security is prohibited
		from selling the Security for a period of six months following the client’s
		trade. In the event that an Access Person makes a prohibited sale within
		the six-month period, the Access Person must relinquish to the Firm any
		gain from the transaction.
	(c)	Sales within seven days before a sale by a client. Any Access Person
		who sells a Security within seven days before any client sells the same
		(or a related) Security must relinquish to the Firm the difference between

	the Access Person’s sale price and the client portfolio(s) sale price
	(assuming the Access Person’s sale price is higher).
(d)	Disgorgement. A charity shall be selected by the Firm to receive any
	disgorged or relinquished amounts due to personal trading violations.

E.	EXEMPTED TRANSACTIONS
	The prohibitions of Sections D (1)(f) and (g) and D (2)(a),(b), and (c) shall not apply to:
	(1)	Purchases or sales effected in any account over which the Access Person has no
		direct or indirect influence or control; an Access Person is presumed to be a
		beneficial owner of Securities that are held by his/her immediate family
		member(s) sharing the Access Person’s household;
	(2)	Purchases or sales which are non-volitional on the part of either the Access
		Person or the Firm;
	(3)	Purchases which are part of an automatic dividend reinvestment plan or an
		automatic investment plan, such as 401(k) purchases; and
	(4)	Purchases effected upon the exercise of rights issued by an issuer pro rata to all
		holders of a class of its Securities, to the extent such rights were acquired from
		such issuer, and sales of such rights so acquired.
F.	COMPLIANCE PROCEDURES
	(1)	Use of Sungard Protegent PTA system. All Access Persons should use the
		Sungard Protegent PTA (“PTA”) system for general reporting requirements under
		this Code, certain transactions may require written reporting on Code Exhibits A,
		B, C, or D, and these forms may be obtained from the Chief Compliance Officer.
	(2)	Records of Securities transactions. All Access Persons must notify the Firm’s
		Chief Compliance Officer if they have opened or intend to open a brokerage or
		Securities account. Access Persons must direct their brokers to supply the
		Firm’s Chief Compliance Officer with duplicate brokerage confirmations of their
		Securities transactions and duplicate statements of their Securities account(s).
	(3)	Pre-clearance of Securities transactions. All Access Persons, who are not
		Nonresident Directors, shall receive prior written approval from the Firm’s Chief
		Compliance Officer, or other officer designated by the Board of Directors, before
		purchasing or selling Securities or any Reportable Fund. Pre-clearance for
		Securities owned or traded by the Firm is valid for that trading day. Pre-clearance
		for Securities not owned or traded by the Firm and any Reportable Fund is valid
		for five concurrent trading sessions. Personal Securities transactions should be
		pre-cleared using the PTA system, for certain reportable funds or other
		investment employees should use form attached, Exhibit D.
	(4)	Pre-clearance of any transaction in a Reportable fund. All Access Persons,
		who are not Nonresident Directors, shall receive prior written approval from the
		Firm’s Chief Compliance Officer, or other officer designated by the Board of
		Directors, before purchasing or selling any Reportable Fund. Pre-clearance for
		Reportable Funds is valid for that trading day. This prohibition does not cover
		purchases and redemptions/sales: (a) into or out of money market funds or short
		term bond funds; or (b) effected on a regular periodic basis by automated means,
		such as 401(k) purchases.

(5)	Disclosure of Personal Holdings, and Certification of Compliance with the
	Code of Ethics. All Access Persons shall disclose to the Firm’s Chief
	Compliance Officer all personal Securities holdings and all Reportable Funds
	holdings upon the later of commencement of employment or adoption of this
	Code and thereafter on an annual basis as of December 31. Every Access
	Person shall certify on the designated forms on the PTA system:
	(a)	They have read and understand the Code and recognize that they are
		subject to all provisions of the Code and they have reported all personal
		Securities and Reportable Funds holdings;
	(b)	They have complied with the requirements of the Code and reported all
		personal Securities and Reportable Funds holdings;
	(c)	They have reported all personal Securities and Reportable Funds
		transactions, and any Securities account(s) opened during the quarter;
	(d)	Initial holdings report shall be made within ten days of hire, and annual
		holdings reports and quarterly transaction reports shall be made within
		ten business days of quarter-end and year-end, as identified above.

(6)	Reporting Requirements
	(a)	The Chief Compliance Officer of the Firm shall notify each Access
		Person that he or she is subject to these reporting requirements, shall
		deliver a copy of this Code to each such person upon their date of
		employment and upon such time as any amendment is made to this
		Code, and shall train each person on appropriate compliance matters
		and usage of the PTA system for personal reporting and shall.
	(b)	Reports, personal trades and holdings, and other information, submitted
		to the Chief Compliance Officer of the Firm pursuant to this Code shall be
		reviewed by the Chief Compliance Officer, be kept confidential, and shall
		be provided only to the officers and directors of the Firm, Firm counsel or
		regulatory authorities upon appropriate request.
	(c)	Every Access Person shall report to the Chief Compliance Officer of the
		Firm all brokerage/investment account(s) currently open at the time of
		their initial employment, and any new brokerage/investment account
		opened, including the name of the bank or brokerage, the account
		number and date the account was opened, and must disclose the new
		account with their quarterly transaction report. Chief Compliance Officer
		will direct the brokerage or bank to send duplicate statements and
		confirms to BHMS pursuant to this Code and NYSE Rule 407.
	(d)	Every Access Person shall report to the Chief Compliance Officer of the
		Firm any/all personal securities/investment account(s) and any/all
		personal Securities holdings at the time of their initial employment with
		the Firm. A report shall be made on the PTA system or designated form,
		Exhibit A with account statements attached containing the following
		information:
		(i)	Name of the Security and ticker or cusip, number of shares, and
principal amount of each personal holding.
		(ii)	Name and account number of the brokerage or bank account
			where the Security is held.

(e)	Every Access Person shall report to the Chief Compliance Officer of the
	Firm the information described in sub-paragraph (5)(d) of this Section
	with respect to transactions in any Security or Reportable Fund in which
	such person has, or by reason of such transaction acquires, any direct or
	indirect beneficial ownership in the Security; an Access Person is
	presumed to be a beneficial owner of Securities that are held by his/her
	immediate family member(s) sharing the Access Person’s household.
(f)	Reports required to be made under this Paragraph (5) shall be made no
	later than 10 business days after the end of the calendar quarter in which
	the transaction to which the report relates was effected. Every Access
	Person and Nonresident Director shall be required to submit a report for
	all periods, including those periods in which no Securities transactions
	were effected. A report shall be made on the PTA system or designated
	form, Exhibit C or on any other form containing the following information:
	(i)	The date of the transaction, the Security name and/or cusip, the
		number of shares, and the principal amount of each Security
		transacted;
	(ii)	The nature of the transaction (i.e., purchase or sale);
	(iii)	The price at which the transaction was effected; and
	(iv)	The name of the broker, dealer or bank with or through whom the
		transaction was effected. Duplicate copies of the Securities
		transaction confirmation of all personal transactions and copies
		of periodic statements for all Securities accounts may be
		appended to Exhibit C to fulfill the reporting requirement.
	(v)	Any such report may contain a statement that the report shall not
		be construed as an admission by the Person making such report
		that he or she has any direct or indirect beneficial ownership in
		the Security to which the report relates.
(g)	Chief Compliance Officer shall periodically review the reports provided by
	the Firm’s Access Persons. Review shall include personal transactions
	and brokerage activity, personal brokerage statements and holdings,
	among other things.

	(7)	Conflict of Interest
		Every Access Person shall notify the Chief Compliance Officer of the Firm of any
		personal conflict of interest relationship which may involve the Firm's clients, such
		as the existence of any economic relationship between their transactions and
		Securities held or to be acquired by any portfolio of the Firm. Such notification
		shall occur in the pre-clearance process.
G.	REPORTING OF VIOLATIONS
	(1)	Any employee of the Firm who becomes aware of a violation of the Code must
		promptly report such violation to the Chief Compliance Officer.
	(2)	The Firm’s Chief Compliance Officer shall promptly report to the Board of
		Directors all material violations of this Code and the reporting requirements there-
		under. Material violations shall be reported to the Chief Compliance Officer of
		any Investment Company client.
	(3)	When the Firm’s Chief Compliance Officer finds that a transaction otherwise
		reportable to the Board of Directors under Paragraph (2) of this Section could not

		reasonably be found to have resulted in a fraud, deceit or manipulative practice in
		violation of Section 206 of the Advisers Act or Rule 17j-1 of the Investment
		Company Act, she may, in her discretion, write a memorandum of such finding
		and the reasons therefore with the reports made pursuant to this Code, in lieu of
		reporting the transaction to the Board of Directors.
	(4)	The Board of Directors or Chief Compliance Officer shall consider reports made
		to the Board of Directors hereunder and shall determine whether or not this Code
has been violated and what sanctions, if any, should be imposed.
H.	ANNUAL REPORTING TO THE BOARD OF DIRECTORS
	The Firm’s Chief Compliance Officer shall prepare an annual report relating to this Code
	to the Board of Directors. Such annual report shall:
	(1)	Summarize existing procedures concerning personal investing and any changes
		in the procedures made during the past year;
	(2)	Identify any violations requiring significant remedial action during the past year;
		and
	(3)	Identify any recommended changes in the existing restrictions or procedures
		based upon the Firm's experience under its Code, evolving industry practices or
		developments in applicable laws or regulations.
I.	SANCTIONS
	Upon discovering a violation of this Code, the Board of Directors may impose such
	sanctions as they deem appropriate, including, among other things, a letter of censure or
	suspension or termination of the employment of the violator.
J.	RETENTION OF RECORDS
	This Code, a list of all Persons subject to its provisions and prohibitions, a copy of each
	report made by each Access Person hereunder, each memorandum made by the Firm’s
	Chief Compliance Officer hereunder, and a record of any violation hereof and any action
	taken as a result of such violation, shall be maintained by the Firm.