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Anti-Insider Trading Policy

Background
An investment adviser should establish, maintain and enforce written policies and procedures reasonably
designed, taking into consideration the nature of such investment adviser’s business, to prevent the misuse of
material, non-public information by such investment adviser or any person associated with such investment
adviser. 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.

Firm Policy
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.

In addition, this firm has instituted procedures as described in its Anti-Insider Trading Policy, as amended from
time to time, to prevent the misuse of material nonpublic information.

Compliance Requirements
The CCO is responsible for:
• Ensuring all employees and associated persons sign a statement acknowledging and agreeing to abide by
the firm’s anti-insider trading policy;
• Maintaining a list for each firm and associated person listing all securities owned;
• Copies of all transaction confirmations or monthly or quarterly securities account statement summaries
from each of these persons;
• Reviewing these confirmations and summaries for inappropriate transactions and reporting them to
Supervisor for action; and
• Maintaining record of Supervisor reviews and results.

The employee acknowledgement statement and list of securities owned should be provided to the CCO on the
date of association and annually thereafter. All other record-keeping requirements should be done on a quarterly
basis, no more than 10 days after the end of the calendar quarter. Reviews of this policy are to be conducted by
the CCO on an annual basis at a minimum.