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CIS's policy prohibits any allocation of trades in a manner that CIS's proprietary accounts, affiliated accounts, or
any particular client(s) or group of clients receive more favorable treatment than other client accounts.

CIS has adopted a clear written policy for the fair and equitable allocation of transactions, (e.g., pro-rata allocation,
rotational allocation, or other means) which is disclosed in CIS's Disclosure Document.

IPOs
Initial public offerings (“IPOs”) or new issues are offerings of securities which frequently are of limited size and
limited availability. These offerings may trade at a premium above the initial offering price.

In the event CIS participates in any new issues, CIS's policy and practice is to allocate new issues shares fairly and
equitably among our advisory clients according to a specific and consistent basis so as not to advantage any firm,
personal or related account and so as not to favor or disfavor any client, or group of clients, over any other.

Trade Errors
As a fiduciary, CIS has the responsibility to effect orders correctly, promptly and in the best interests of our clients.
In the event any error occurs in the handling of any client transactions, due to CIS's actions, or inaction, or actions
of others, CIS's policy is to seek to identify and correct any errors as promptly as possible without disadvantaging
the client or benefiting CIS in any way.

If the error is the responsibility of CIS, any client transaction will be corrected and CIS will be responsible for any
client loss resulting from an inaccurate or erroneous order.
CIS's policy and practice is to monitor and reconcile all trading activity, identify and resolve any trade errors
promptly, document each trade error with appropriate supervisory approval and maintain a trade error file.

Responsibility
John Riley has the responsibility for the implementation and monitoring of our trading policies and
practices, disclosures and recordkeeping for the firm.

Procedure
CIS has adopted various procedures to implement the firm’s policy and
reviews to monitor and ensure the firm’s trading policies are observed, implemented properly and amended or
updated, which include the following:
• Trading reviews, reconciliations of any and all securities transactions for advisory clients. John Riley
periodic supervisory reviews of the firm’s trading practices.
• Periodic reviews of the firm’s Disclosure Document, advisory agreements, and other materials for
appropriate disclosures of the firm’s trading practices and any conflicts of interests.
• Designation of a Brokerage Committee, or other designated person, to review and monitor the firm’s
trading practices.

Research Processes
John Riley is responsible for CIS’s research. Research is obtained from a wide variety of sources including but not
limited to wire houses, mutual fund companies, government agencies, international agencies and other research
companies among other data sources. Increasingly, the Internet and new databases provide a wealth of ideas and
information to enhance CIS’s research.

CIS receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party.

Allocation of Aggregated Trades Among Clients
CIS maintains the ability to block trade purchases across accounts. While block trading may benefit clients by
purchasing larger blocks in groups, we do not feel that the clients are at a disadvantage due to the best execution
practices of our custodians.