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Prohibited Purchases and Sales
Insider Trading
Illegal insider trading refers generally to buying or selling a security, in breach of a fiduciary duty or other
relationship of trust and confidence, while in possession of material, nonpublic information about the security. The
SEC defines material by saying “Information is material if ‘there is a substantial likelihood that a reasonable
shareholder would consider it important’ in making an investment decision.” Information is nonpublic if it has not
been disseminated in a manner making it available to investors generally.

CIS strictly prohibits trading personally or on the behalf of others, directly or indirectly, based on the use of
material, non-public or confidential information. CIS additionally prohibits the communicating of material non-
public information to others in violation of the law. Employees who are aware of the misuse of material nonpublic
information should report such to the Chief Compliance Officer (CCO). This policy applies to all of CIS’s employees
and associated persons without exception.

Please note that SEC’s position that the term “material nonpublic information” relates not only to issuers but also
to the adviser’s securities recommendations and client securities holdings and transactions.

Personal Securities Transactions
Initial Public Offerings (IPO’s)
Except in a transaction exempted by the “Exempted Transactions” section of this Code of Ethics, no access person
or other employee may acquire, directly or indirectly, beneficial ownership in any securities in an Initial Public
Offering (“IPO”) without first obtaining approval from the CCO. Any acquisition by an access person or employee in
an IPO following CCO approval shall be recorded on the appropriate firm personal trading log or other designated
reporting document and placed in employees file or CCO designated compliance file.

Limited or Private Offerings
Except in a transaction exempted by the “Exempted Transactions” section of this Code of Ethics, no access person
or other employee may acquire, directly or indirectly, beneficial ownership in any securities in a Limited or Private
Offering.

Blackout Periods
There is currently no blackout policy regarding the timing of access personal trading before or after client trades
are made. The CCO will follow the review procedures outlined in this manual to ensure that access persons are not
front-running or profiting off of the timing of client trades.

Some of the representatives of CIS are also management clients of CIS, so there is no Blackout Period for the
purchase and sale of securities for their accounts. CIS does not believe that a representative should be penalized
for doing business with CIS.

From time to time, representatives of CIS may buy or sell securities for themselves at or around the same time as
clients. This may provide an opportunity for representatives of CIS to buy or sell securities before or after
recommending securities to clients resulting in representatives profiting off the recommendations they provide to
clients. Such transactions may create a conflict of interest. Unless directly involved in the decision making process
of managing client portfolios, Reps are rarely involved in the decision making process of security selection for
client portfolios and do not make recommendations to clients, this conflict of interest is minimized. Reps that are
involved in the decision making process of managing portfolios are allowed to buy and sell securities at the same
time as the clients, usually in a block trade. From time to time a rep involved in the decision making process will
need to sell a security or want to buy a security for their personal portfolio. This can be done with CCO permission.

When CIS trades for representatives’ portfolios we try to group representatives’ trades in a block trade with client
trades so that there is no advantage or penalty given to the representative.

When representatives are trading for their own accounts, they are required to pass the trade by CCO for approval
to ensure that it is not a trade the portfolio manager is anticipating making for managed clients.

Short-Term Trading
Securities held in client accounts should not be purchased and sold, or sold and repurchased, within 30 calendar
days by investment personnel. The CCO may, for good cause shown, permit a short-term trade, but shall record
the reasons and grant of permission with the records of the Code.