Page 2 - P&P11-05-2020-with-FAQ-JR

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Contents

Policy Statement 6

Chief Compliance Officer Appointment 6
Summary 6
Record-Keeping Policy 7

Fiduciary Statement 9

Code of Ethics 10
Code of Ethics Statement 11

Prohibited Purchases and Sales 12

Personal Securities Transactions 12
Initial Public Offerings (IPO’s) 12
Limited or Private Offerings 12
Blackout Periods 12

Miscellaneous Restrictions 13
Margin Accounts 13
Short Sales 13
Exempted Transactions 13

Prohibited Activities 13
Conflicts of Interest 13
Gifts and Entertainment 13
Political and Charitable Contributions 14
Confidentiality 14
Service on Board of Directors 14

Compliance Procedures 15
Portfolio Management Processes 15
Allocation of Investment Opportunities Among Clients 15
Consistency of Portfolios with Clients’ Investment Objective 15
Disclosures By the Adviser 15
Valuation of Securities 15
Account Statements 15
Sub-Adviser / Money Manager Review 15
Applicable Regulatory Restrictions 15
Compliance with Laws and Regulations 16
Personal Securities Transactions Procedures and Reporting 16

Certification of Compliance 18
Initial Certification 18
Acknowledgement of Amendments 18
Annual Certification 18
Reporting Violations 18
Compliance Officer Duties 19
Training and Education 19
Recordkeeping 19
Annual Review 19
Sanctions 19

Definitions 20

Privacy Policy & Information Security 21

Advertising 22
Procedure 23
Awards, Nominations and Honors 23

Soft Dollar Arrangements Statement 23
Firm Statement 23

Social Networking Policy 25

Email and Other Electronic Communications 27
Procedure 27