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Policy Statement

Under Rhode Island regulations and rules, it is unlawful for an investment adviser registered to provide investment
advice unless the adviser has adopted and implemented written policies and procedures reasonably designed to
prevent violation of Rhode Island regulations and rules regulations by the adviser or any of its supervised persons.
The rule requires advisers to consider their fiduciary and regulatory obligations under Rhode Island regulations and
rules, and to formalize policies and procedures to address them. This document is provided as documentation of
those policies and procedures.

Reviews of these policies and procedures are to be conducted on an annual basis at a minimum. Interim reviews
may be conducted in response to significant compliance events, changes in business arrangements, and regulatory
developments.

Adviser will maintain copies of all policies and procedures that are in effect or were in effect at any time during the
last five years.

Chief Compliance Officer Appointment

The person herein named “Chief Compliance Officer” is stated to be competent and knowledgeable regarding the
Advisers Act or applicable state rule or regulation and is empowered with full responsibility and authority to
develop and enforce appropriate policies and procedures for the firm. The compliance officer has a position of
sufficient seniority and authority within the organization to compel others to adhere to the compliance policies
and procedures.

Chief Compliance Officer (CCO) John Riley Date Responsibility Assumed 03/31/2020
Supervisor John Riley Date Responsibility Assumed 03/31/2020

Summary
Policy
Cornerstone Investment Services, LLC (CIS) has adopted these written policies and procedures which are designed
to set standards and internal controls for the firm, its employees, and its businesses and are also reasonably
designed to detect and prevent any violations of regulatory requirements and the firm’s policies and procedures.
Every employee and manager is required to be responsible for and monitor those individuals and departments he
or she supervises to detect, prevent and report any activities inconsistent with the firm’s procedures, policies, high
professional standards, or legal/regulatory requirements.

Background
The SEC adopted the anti-fraud rule titled Compliance Procedures and Practices (Rule 206(4)-7) under the Advisers
Act requiring more formal compliance programs for all SEC registered advisers. The rule became effective
2/5/2004 and SEC advisers had until 10/5/2004 (compliance date) to be in compliance with the rule.

Rule 206(4)-7 makes it unlawful for a SEC adviser to provide investment advice to clients unless the adviser:

1. adopts and implements written policies and procedures reasonably designed to prevent violations by the firm
and its supervised persons;
2. reviews, at least annually, the adequacy and effectiveness of the policies and procedures;
3. designates a chief compliance officer who is responsible for administering the policies and procedures; and
4. maintains records of the policies and procedures and annual reviews.

Under Section 203(e)(6), the SEC is authorized to take action against an adviser or any associated person who has
failed to supervise reasonably in an effort designed to prevent violations of the securities laws, rules and
regulations. This section also provides that no person will be deemed to have failed to supervise reasonably
provided: