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• As part of CIS's brokerage and best execution practices, CIS has adopted and implemented written best
execution practices and established a Brokerage Committee (or designated an individual or officer).
• The Brokerage Committee (or designated officer) has responsibility for monitoring our firm’s trading
practices, gathering relevant information, periodically reviewing and evaluating the services provided by
broker-dealers, the quality of executions, research, commission rates, and overall brokerage relationships,
among other things.
• A Best Execution file is maintained for the information obtained and used in CIS's periodic best execution
reviews and analysis and to document the firm’s best execution practices.

Principal Trading

Policy
CIS's policy and practice is to NOT engage in any principal transactions, and our firm’s policy is appropriately
disclosed in Form ADV/Disclosure Document.

Background
Principal transactions are generally defined as transactions where an adviser, acting as principal for its own
account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. As a
fiduciary and under the anti-fraud section of the Advisers Act, principal transactions by advisers are prohibited
unless the adviser 1) discloses its principal capacity in writing to the client in the transaction and 2) obtains the
client’s consent to each principal transaction before the settlement of the transaction.

Responsibility
The CCO has the responsibility for the implementation and monitoring of our principal trading policy and
disclosures that the firm/affiliated firm does not engage in any principal transactions with advisory clients.

Procedure
CIS has adopted various procedures to implement the firm's policy and reviews to monitor and ensure the firm's
policy is observed, implemented properly, and amended or updated, as appropriate, which include the following:
• CIS's policy of prohibiting any principal trades with advisory clients has been communicated to relevant
individuals, including management, traders and portfolio managers, among others.
• The firm's policy is appropriately disclosed in the firm's Form ADV/Disclosure Document.
• The CCO periodically monitors the firm's advisory services and trading practices to help ensure no
Principal trades occur for advisory clients.
• In the event of any change in the firm's policy, any such change must be approved by management, and
any principal transactions would only be allowed after appropriate reviews and approvals, disclosures,
meeting strict regulatory requirements and maintaining proper records.