We adopt and embrace the CFA Institute’s Code of Ethics, Standards of Professional Conduct and Asset Manager Code of Professional Conduct in their entirety, of which the Code of Ethics is as follows:

"Act with integrity, competence, diligence, respect, and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets.

Place the integrity of the investment profession and the interests of clients above their own interests.

Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities.

Practice and encourage others to practice in a professional and ethical manner that will reflect credit on themselves and the profession.

Promote the integrity of, and uphold the rules governing, capital markets.

Maintain and improve their professional competence and strive to maintain and improve the competence of other investment professionals."

The full text of the CFA Institute’s Standards of Professional Conduct and Asset Manager Code of Professional Conduct can be found at www.cfainstitute.org.