A. |
honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
|
B. |
full, fair, accurate, timely and understandable disclosure in reports and documents that the Trust files with or submits to the Securities and Exchange Commission (the
“SEC”) and in other public communications made by the Trust;
|
C. |
compliance with applicable laws and governmental rules and regulations;
|
D. |
the prompt internal reporting of violations of the Code to an appropriate person or persons identified in the Code; and
|
E. |
accountability for adherence to the Code.
|
II. |
COVERED OFFICERS SHOULD HANDLE ETHICALLY ACTUAL AND APPARENT CONFLICTS OF INTEREST
|
A. |
not use his personal influence or personal relationships improperly to influence investment decisions or financial reporting by the Trust whereby the Covered Officer
would benefit personally to the detriment of the Trust;
|
B. |
not cause the Trust to take action, or fail to take action, for the individual personal benefit of the Covered Officer rather than the benefit the Trust; and
|
C. |
not use material nonpublic knowledge of portfolio transactions made or contemplated for the Trust to trade personally or cause others to trade personally in
contemplation of the market effect of such transactions.
|
A. |
service as a director on the board of any public or private company;
|
B. |
the receipt of any non-nominal gifts;
|
C. |
the receipt of any entertainment from any company with which the Trust has current or prospective business dealings unless such entertainment is business-related,
reasonable in cost, appropriate as to time and place, and not so frequent as to raise any question of impropriety;
|
D. |
any ownership interest in, or any consulting or employment relationship with, any of the Trust’s service providers, other than its investment adviser, principal
underwriter, administrator or any affiliated persons thereof; and
|
E. |
a direct or indirect financial interest in commissions, transaction charges or spreads paid by the Trust for effecting portfolio transactions or for selling or
redeeming shares other than an interest arising from the Covered Officer’s employment, such as compensation or equity ownership.
|
A. |
Each Covered Officer should familiarize himself with the disclosure requirements generally applicable to the Trust;
|
B. |
each Covered Officer should not knowingly misrepresent, or cause others to misrepresent, facts about the Trust to others, whether within or outside the Trust, including
to the Trust’s Trustees and auditors, governmental regulators, and self-regulatory organizations;
|
C. |
each Covered Officer should, to the extent appropriate within his area of responsibility, consult with other officers and employees of the Trust and the adviser with
the goal of promoting full, fair, accurate, timely and understandable disclosure in the reports and documents the Trust files with or submit to the SEC and in other public communications made by the Trust; and
|
D. |
it is the responsibility of each Covered Officer to promote compliance with the standards and restrictions imposed by applicable laws rules and regulations.
|
A. |
upon adoption of the Code (or thereafter as applicable, upon becoming a Covered Officer), affirm in writing to the Board that he has received, read, and understands the
Code (See Exhibit B);
|
B. |
annually thereafter affirm to the Board that he has complied with the requirements of the Code (See Exhibit B);
|
C. |
not retaliate against any other Covered Officer or any employee of the Trust or their affiliated persons for reports of potential violations that are made in good
faith; and
|
D. |
notify the Trust’s compliance officer promptly if he knows of any violation of this Code. Failure to do so is itself a violation of this Code.
|
A. |
The compliance officer will take all appropriate action to investigate any potential violations reported to him.
|
B. |
If, after such investigation, the compliance officer believes that no violation has occurred, the compliance officer is not required to take any further action.
|
C. |
Any matter that the compliance officer believes is a violation will be reported to the Board.
|
D. |
If the Board concurs that a violation has occurred, it will consider appropriate action, which may include review of and appropriate modifications to applicable
policies and procedures; notification to appropriate personnel of the investment adviser or its board; or a recommendation to dismiss the Covered Officer.
|
E. |
The Board will be responsible for granting waivers, as appropriate.
|
F. |
Any changes to or waivers of this Code will, to the extent required, be disclosed as provided by SEC rules.
|