Exhibit (p)(viii)

Whittier Advisors’ Code of Ethics sets out standards of conduct to help you avoid potential conflicts of interest that may arise from your actions and your personal securities transactions.

All firm personnel must read and understand the Code.

Effective Date: August 31, 2022
Last Revision: August 31, 2022

Table of Contents

CODE OF ETHICS & PERSONAL SECURITIES TRANSACTIONS

Overview and General Principles

Whittier Advisors, LLC (“Whittier”) believes it is essential not only to comply with federal securities laws and regulations but also to maintain high standards of personal and professional conduct at all times. Whittier’s Code of Ethics is designed to ensure that our conduct is at all times consistent with these standards, with our fiduciary obligations to our clients, and with industry and regulatory standards for investment managers.

The basic principles underlying Whittier’s Code of Ethics are as follows:

The Code of Ethics set forth the general principles that will apply even when the specific rules do not address a specific situation or are unclear or potentially inapplicable.

Although the Code of Ethics provides guidance with respect to many common types of situations, please remember that the Code of Ethics cannot address every possible circumstance that could give rise to a conflict of interest, a potential conflict of interest, or an appearance of impropriety. Whether or not a specific provision of the Code applies, each employee must conduct his or her activities in accordance with the general principles embodied in the Code of Ethics, and in a manner designed to avoid any actual or potential conflict of interest or any abuse of an individual’s position of trust and responsibility. Technical compliance with the procedures incorporated in the Code of Ethics will not insulate actions that contravene your duties to Whittier and its clients from scrutiny and, in some cases, liability. You should consider whether a particular action might give rise to an appearance of impropriety, even if the action itself is consistent with your duties to Whittier and its clients. Therefore, to protect yourself and Whittier, be alert for the potential for conflicts of interest, and please consult the CCO whenever questions arise concerning the application of the Code of Ethics to a particular situation.

The provisions and requirements of the Code of Ethics apply to all Whittier personnel, including those persons identified as “access persons”¹ (referred to in the Code of Ethics as “employee” or “employees”).

All of the provisions and requirements of the Code of Ethics, including the rules pertaining to pre-clearance of personal securities transactions, also apply to persons who are closely connected to Whittier employees. Examples of closely connected persons include any family member who is presently living in your household, or to whose financial support you make a significant contribution, and trusts or estates over which you have investment control. In case of any doubt, please contact the CCO.

Although persons who are not closely connected to you are not required to comply with the pre-clearance and other procedures contained in the Code of Ethics, such persons may not take improper advantage of information that they may receive from you regarding the activity or holdings of Whittier clients. In addition, it would be a violation of the Code of Ethics for any Whittier employee to arrange for a friend or relative to trade in a security in which that Whittier employee would be precluded from trading for his or her own account. It may also be a violation of the Code of Ethics for a Whittier employee to give information about the activity or holdings of Whittier clients to any person for the purpose of facilitating securities trading by that person.

Whittier and its employees owe fiduciary duties to their clients under the laws of the United States. These fiduciary duties require each of us to place the interests of our clients ahead of our own interests in all circumstances.

An integral part of our fiduciary duty is the obligation to avoid conflicts of interest. As a basic principle, you may not use your position, or information you learn at Whittier, so as to create a conflict or the appearance of a conflict between your personal interests and those of Whittier or any Whittier client. A conflict of interest (or the appearance of a conflict of interest) can arise even if there is no financial loss to Whittier or to any Whittier client, and regardless of the motivation of the employee involved.

The potential for conflicts of interest is apparent with respect to personal securities transactions, but conflicts of interest can arise in a variety of situations. Some of the more common examples are described in this Code of Ethics. The rules contained in the Code of Ethics are designed to minimize conflicts of interest and to avoid potential appearances of impropriety. As a result, all employees and members of their immediate families are required to adhere carefully to the elements of the Code of Ethics that are applicable to them. Compliance with Whittier’s Code of Ethics is a condition of employment. The sanctions that may result from violations of the Code of Ethics, which can include fines and/or dismissal, are outlined below.

Compliance with the Code of Ethics and interpretation of its requirements is the responsibility of Whittier’s CCO, subject to the oversight of Whittier’s Partners. If you have questions about whether a conflict of interest exists in a particular situation, please contact the CCO.

Industry standards pertaining to matters such as personal securities trading can change over time, and Whittier is committed to maintaining high ethical standards for itself and its employees. Therefore, Whittier reserves the right to change any or all of the requirements of the Code of Ethics from time to time, as Whittier deems necessary or appropriate. Whittier also reserves the right, when in its judgment particular circumstances warrant, to impose more stringent requirements on particular employees or on all employees generally, or to grant exceptions to the requirements of the Code of Ethics in circumstances in which it believes an exception is warranted.

As noted above, Whittier and its employees have a fiduciary responsibility to Whittier’s clients. We are required to avoid conduct that might be detrimental to their best interests, and we cannot place our own personal interests ahead of those of our clients.

In order to fulfill this duty to our clients, Whittier, as a matter of policy, requires its employees to offer all investment opportunities to Whittier’s clients first, before taking advantage of such opportunities themselves. Therefore, before trading in any security that is not covered by a Whittier portfolio manager or analyst, or engaging in a transaction of limited availability, the CCO, as part of the pre-clearance process, will ensure that a member of the Whittier Investment Team is aware that you have identified a security or transaction of limited availability that you believe would be a good investment, and will, if necessary, ask you to explain the basis for your interest in that security. If, after receiving that information, the manager does not wish to recommend that security for investment to Whittier clients, you are free to trade, after securing the other necessary pre-approvals. If the manager expresses an interest in that security or transaction, however, you must refrain from trading in that security or engaging in that transaction until a decision has been made as to whether to purchase that security for Whittier clients. In some cases, you may be required to refrain from trading for several days, until a decision is made.

We recognize that this policy may make it more difficult for Whittier employees to engage in certain personal securities transactions. Nevertheless, we believe that these rules will enhance the ability of Whittier to fulfill its fiduciary responsibilities to our clients.

As noted earlier, conflicts of interest can also arise in situations not involving personal securities transactions. Some of the situations that have been encountered in the past are set forth below:

Although gifts shall not be accepted from persons or entities doing business with Whittier, on a rare occasion it may be appropriate to send a gift on behalf of Whittier. Any gift in excess of $100 needs the approval of the CCO and also needs to be logged by the CCO or a designee prior to being sent. Meals, drinks, sporting events and concerts are considered entertainment and not gifts when accompanied by an employee of Whittier. In addition, charitable contributions made by Whittier are not considered gifts.

Entertainment must not be lavish or so excessive as to appear to unduly influence the judgment of employees or otherwise appear improper under these requirements. There is no specific dollar amount that represents “lavish or excessive entertainment.” This is a judgment call that must be determined on a case-by-case basis in advance of the entertainment event in consultation with the CCO. Typical business meals are not considered entertainment. Non-business related or luxurious meals, drinks, sporting events and concerts are considered entertainment, not gifts, when accompanied by an employee of Whittier. Entertainment valued over $300 needs the approval of the CCO and also needs to be logged by the CCO or a designee. Submit a request form for non-business-related meals and for other entertainment as described above.

In order to adhere to SEC Rule 206(4)-5 “Pay to Play”, political contributions, except for de minimis amounts, to a politician or political campaign are prohibited, unless prior written approval is obtained from the CCO.

The SEC’s “Pay-to-Play” rule prohibits a money management firm from accepting payment for managing state or local investment funds if, within the prior 2 years, certain personnel have made a contribution to an official in a position to influence the direction of those investment dollars.

A “Political Contribution” is any contribution to incumbents in or candidates for state or local office including any gift, subscription, loan, advance, deposit of money or thing of value made for the purpose of supporting a candidate or influencing any election, as well as in-kind distributions such as hosting parties or volunteering.

Political contributions may prevent the Firm and its clients from being considered for investment by public funds. Before meeting with a public fund, you must notify the CCO.

The Firm’s Political Contributions Policy:

Outside Business Activity (“OBA”), for company purposes, is defined as, but not limited to, board member, officer and/or director which results in compensation and/or profit. OBA does not include any roles at an affiliate of the Firm (i.e., Whittier Trust Company or The Whittier Trust Company of Nevada). Any OBA must be approved by the CCO.

Prompt written notice of an OBA by an affected employee is required that includes the following information:

Any employee that becomes the subject of a regulatory investigation, disciplinary enforcement action or litigation, or served with a subpoena, or becomes subject to any judgment, order or arrest, or is contacted by any regulatory authority must immediately inform the CCO of such action.

Whittier is the investment adviser to the Ambrus family of mutual funds, each of which is a registered investment company under the Investment Company Act of 1940, as amended. Whittier employees, in connection with the purchase or sale, directly or indirectly, by such person of a security held or to be acquired by a fund shall not:

Whittier regards violations of the Code of Ethics as a serious breach of firm rules. Therefore, any employee who violates any element of the Code of Ethics may be subject to appropriate disciplinary action, up to and including dismissal.

Moreover, all employees are required to promptly report any violations of the Code of Ethics to the CCO and should be aware that failure to comply with certain elements of Whittier’s Code of Ethics may constitute a violation of federal and/or state law and may subject that employee and Whittier to a wide range of criminal and/or civil liability. Violations or potential violations of the Code of Ethics may be reported to federal or state authorities, such as the SEC.

Given the seriousness of the potential consequences of violations of the Code of Ethics, all employees are urged to seek guidance with respect to issues that may arise. Resolving whether a particular situation may create a potential conflict of interest, or the appearance of such a conflict, may not always be easy, and situations inevitably will arise from time to time that will require interpretation of the Code of Ethics to particular circumstances. Please do not attempt to resolve such questions yourself. In the event that a question arises as to whether a proposed transaction is consistent with the Code of Ethics, please address that question to the CCO before the transaction is initiated.

Although the Code of Ethics addresses many possible situations, other special situations inevitably will arise from time to time. If a particular transaction or situation does not give rise to a real or potential conflict of interest, or if appropriate safeguards can be established, the CCO or the Whittier Partners may grant exceptions to provisions of the Code of Ethics. However, there can be no guarantee that an exception will be granted in any particular case.

All acknowledgements of the Code of Ethics are done via gVue, online compliance reporting software.

The CCO will provide compliance training to new employees upon hiring and to all existing employees not less than on an annual basis. The topics to be discussed include, but are not limited to, significant updates made to the Compliance Manual, a review of the Code of Ethics, and a detailed review of Whittier’s policy regarding personal securities transactions. The CCO will document this training with an employee sign-in sheet and maintain a file including the agenda and a copy of any materials distributed.

Personal Securities Transactions

Personal securities trading by investment management personnel have come under intensive scrutiny. It is important to remember that all investment opportunities (if suitable) must be offered first to clients before an employee may act on them. All Whittier employees should be careful to conduct their personal securities transactions in accordance with following policies and the Code of Ethics.

The Personal Securities Transactions Policies concerning reporting and prior approval covers all transactions in securities in which you (or persons closely connected to you) have a direct or indirect beneficial ownership. The term “beneficial interest” is defined in the federal securities laws and includes more than an ordinary ownership interest. Because beneficial interest can be interpreted very broadly, if you have any question concerning whether you have a beneficial interest in a security you should contact the CCO. A few examples of accounts that would be covered by Whittier’s Personal Securities Transactions Policy are as follows: (i) spousal accounts, and (ii) accounts of dependent children or children living in your household.

In general, you may be deemed to have beneficial ownership under any of the following circumstances:

Whittier discourages its employees from engaging short-term trading strategies for their own accounts. Any excessive or inappropriate trading that, in Whittier’s view, interferes with job performance, or compromises the duty that Whitter owes to its clients, will not be tolerated. Employees must always conduct their personal trading activities lawfully, properly and responsibly.

Except as noted below, Whittier employees shall disgorge any gains that result from executing a transaction in a financial instrument that requires pre-clearance under the Code of Ethics and then affirmatively executing an opposite way transaction (buying and then selling at a higher price, or selling and then buying at a lower price) in the same financial instrument within 30 calendar days. This applies across all brokerage accounts.

For purposes of the 30 calendar day calculation, the date of the transaction is considered day one. Please note, profits are calculated differently under this rule than they would be for tax purposes. Also, it is important to know that transaction costs and potential tax liabilities will NOT be offset against the amount that must be surrendered under this rule. Profits from such trades must be disgorged in a manner acceptable to the CCO. Any disgorgement amount shall be calculated by the CCO or their designee(s), the calculation of which shall be binding. Note, an option transaction containing an initial expiration date within the 30 calendar days, as described above, of purchase or sale is considered to be a short-term trading strategy and is subject to the 30 Calendar Day Rule.

The following transactions are excluded from the 30 Calendar Day Rule:

Prior to transacting, all employees must represent in their pre-clearance request that the transaction is not in contravention of the 30 Calendar Day Rule.

Access Persons and persons closely connected to Access Persons must conduct personal securities trading in a manner that does not give rise to either a conflict of interest, or the appearance of a conflict of interest, with the interests of any Whittier clients. Pre-clearance and approval of personal securities transactions helps Whittier prevent certain investments that may conflict with client trading activities. Please bear in mind that, if a conflict of interest arises, you may be frozen in, or prohibited from trading, securities in which you have an existing position. Any losses suffered due to compliance with the requirements of this policy are the employee’s sole responsibility. Each employee should evaluate this risk before engaging in any personal securities transaction.

Note: It is important to remember that transactions in closed-end funds and ETFs are subject to the preclearance and blackout period (see below) requirements. Cryptocurrencies are not “Personal Securities Transactions” and thus are not subject to the pre-clearance and reporting requirements, however, derivatives on Cryptocurrencies are “Personal Securities Transactions” and are subject to the pre-clearance and reporting requirements.

If you are a portfolio manager with respect to a client transaction, you are subject to the blackout periods listed below. Note that transactions that do not require pre-clearance are not subject to these blackout periods. Regardless of whether you are required to pre-clear your trade, you must not take inappropriate advantage of your position as a portfolio manager in violation of the Code.

Whittier and its employees are fiduciaries subject to the highest standards of care and must always act in our clients’ best interests. It is not appropriate to rely on mere technical compliance with the rules set out in this policy. Moreover, the SEC and other regulators closely scrutinize personal securities transactions by investment professionals to ensure that they conform to fiduciary principles. As a result, you should always remember that we all have an obligation to put our client’s interests ahead of our own in all circumstances.

The following processes are done via gVue.

The CCO will review employee personal trading. A managing member will review the CCO’s personal trading records.

The CCO shall maintain current and accurate records of all personal securities transactions of its employees via gVue.

Whittier requires that all employees acknowledge (both initially within 10 days of becoming an employee, quarterly and annually (within 30 days of receipt) that they have reviewed and understand Whittier’s Code of Ethics, including the provisions on personal securities transactions.