Exhibit (p1)

TIFF Advisory Services, LLC
TIFF Endowment Asset Management, LLC

TIFF Investment Program

Code of Ethics

June 2004

Revised March 6, 2006, October 1, 2009, March 1, 2011, March 30, 2012, June 28, 2012,
January 1, 2013, April 1, 2014, April 1, 2016, July 1, 2017, October 1, 2019, October 1, 2020, October 1,
2021, October 1, 2022, October 2, 2023 and October 31, 2024

I.            Introduction (Applies to All Supervised Persons)

Purpose of the Code. This Code of Ethics (“Code”) sets forth the policies and procedures of TIFF Advisory Services, LLC (“TAS”) and TIFF Endowment Asset Management, LLC (“TEAM”), each an SEC-registered investment adviser, and TIFF Investment Program (“TIP”), a registered investment company, regarding business ethics and the use of non-public information by their respective Supervised Persons and personal trading in securities by their respective Access Persons, as these terms are defined below. The policies and procedures in this Code are mandatory. They are designed to ensure that Supervised Persons act in accordance with their fiduciary obligations and comply with applicable Federal Securities Laws. This Code has been adopted by each of TAS and TEAM under Section 204A of the Investment Advisers Act of 1940 (“Advisers Act”) and by TIP under Rule 17j-1 of the Investment Company Act of 1940 (“1940 Act”).

Overriding Principles. Each Supervised Person must recognize that the interests of advisory clients of TAS and TEAM, including the TIFF Investment Vehicles, should take precedence and that he or she must avoid any abuse of their positions of trust and responsibility. Each Supervised Person is expected to accept the obligations that apply to fiduciaries, to place the interests of clients ahead of their own, and to be aware of and avoid any situation that may give rise to any actual, perceived or potential conflict of interest with a client’s interests. Notwithstanding the foregoing, Supervised Persons (as defined herein) are permitted to participate in Overlapping Private Investments (as defined herein), subject to the terms and conditions set forth herein. While Supervised Persons technically owe a fiduciary duty to TAS and TEAM clients, rather than Members, Supervised Persons generally should also consider the interests of Members, provided that such Members’ interests are not inconsistent with the interests of clients of TAS and TEAM. Supervised Persons are required to comply with all Federal Securities Laws. Supervised Persons also are strongly encouraged to act in accordance with the TIFF Credo, which articulates certain ethical ideals applicable to Supervised Persons.

Applicability of the Code. The Code is applicable to directors, officers, and employees of TAS and TEAM, the operating committee members of TEAM and trustees and officers of TIP, all of whom (other than the TIP Independent Trustees) are referred to as “Supervised Persons.” The TIP Independent Trustees are subject only to the requirements listed in Section VII of the Code. Supervised Consultants (as defined herein) are subject only to the requirements listed in Section VIII of the Code. TAS Advisory Board members are subject only to the requirements listed in Section IX of the Code.

Failure to Comply with the Code. Each Supervised Person shall be provided a copy of the Code and all amendments and each Supervised Person is required to read and understand these policies and procedures and sign an initial compliance certification and periodic compliance certifications. Failure to comply with these policies and procedures may result in disciplinary action by TAS, TIP or TEAM, up to and including dismissal, as well as civil and criminal liability, including legal prohibition against further employment in the securities industry.

Questions about the Code. All questions about the interpretation or application of the Code should be addressed to the CCO. All Supervised Persons are encouraged to seek guidance from the CCO with respect to any action or transaction that a Supervised Person believes may be subject to one or more provisions of this Code and to refrain from any action or transaction that might lead to the appearance of a violation of this Code.

Reporting of Violations and Whistleblower Procedures. Any Supervised Person or Supervised Consultant who believes that a violation of this Code has taken place must promptly report that violation to the CCO. Supervised Persons and Supervised Consultants may make these reports anonymously and no adverse action shall be taken against a Supervised Person or Supervised Consultant making such a report in good faith. In addition, Supervised Persons and Supervised Consultants are encouraged to internally report information concerning alleged violations of the Federal Securities Laws or instances of illegal bribery by TAS, TEAM, a TIFF Investment Vehicle, or a Supervised Person or a Supervised Consultant. In that regard, Supervised Persons are subject to the specific terms and conditions of TAS and TEAM’s written Policies and Procedures for Handling Certain Complaints, or “whistleblower” procedures. Those procedures cover in detail the submission and treatment of such internal reports and also provide certain anti-retaliatory protections for TAS employees.

Prevention of Misuse of Material Non-Public Information and Treatment of Confidential Information [Section IV]

Business Ethics and Conflicts of Interest [Section V]

Personal Trading and Reporting Requirements [Section VI]

Obligations of TIP Independent Trustees [Section VII]

Obligations of Supervised Consultants [Section VIII]

Obligations of TAS Advisory Board Members [Section IX]

Access Person, when used with respect to each of TAS and TEAM, means any officer, director, or employee¹ of TAS or TEAM, as applicable, any operating committee member of TEAM, or any other person who provides advice on behalf of TAS or TEAM, as applicable, and who is subject to the supervision and control of TAS or TEAM, as applicable.

The CCO may from time to time determine that other persons who provide services to TAS, TEAM or the TIFF Investment Vehicles in a temporary or ongoing capacity should be considered Access Persons, and therefore subject to the Code, if, as part of their regular duties for TAS, TEAM or the TIFF Investment Vehicles, they:

(i) are involved in the selection of portfolio securities,

(ii) may have access to material, non-public information regarding future purchases or sales of portfolio securities for the account of, or non-public information regarding the portfolio holdings of, any TIFF Investment Vehicle, or

(iii) make any recommendation regarding the purchase or sale of securities for the TIFF Investment Vehicles or have access to such recommendations that are non-public.

All TAS and TEAM officers, directors and employees are Access Persons.

Beneficial Ownership means ownership by any person who, directly or indirectly, through any contract, arrangement, understanding, relationship, or otherwise, has or shares a direct or indirect financial interest other than the receipt of an advisory fee. Beneficial Ownership includes accounts of a spouse, minor child, a relative sharing the same house, and any account over which the person has discretionary authority (e.g., trustee, executor, power of attorney, etc.).

Securities owned or acquired by an institution that employs a TAS director are not deemed to be beneficially owned by that director.

Brokerage Account means any securities account maintained with a broker or bank that includes a brokerage function that permits the account holder to transact in Reportable Securities, even if the only holdings currently in the account are mutual funds or other non-Reportable Securities.  Accounts with mutual fund companies that do not have a brokerage function and that hold only shares of mutual funds offered by the particular mutual fund company are not considered Brokerage Accounts.

¹ Regardless of a person’s particular title, the terms “officer,” “director,” or “employee” include any person who occupies a similar status or who performs similar functions within the organization, including operating committee members of TEAM.

Brokerage Accounts include Supervised Persons’ Schwab IRA accounts and any retirement (401(k), 403(b), IRA, etc.) and pension plan accounts that currently hold Reportable Securities or have a brokerage function that permits the account holder to transact in Reportable Securities. Brokerage Accounts also include third-party discretionary accounts of the type discussed in Section VI of the Code.

CCO means the Chief Compliance Officer of TAS, TEAM and TIP or their designee.

Federal Securities Laws means the Securities Act of 1933, the Securities Exchange Act of 1934, the Sarbanes-Oxley Act of 2002, the Investment Company Act of 1940, the Investment Advisers Act of 1940, Title V of the Gramm-Leach Bliley Act, any rules adopted by the Securities and Exchange Commission under any of these statutes, the Bank Secrecy Act as it applies to funds, and any rules adopted thereunder by the Securities and Exchange Commission or the Department of the Treasury.

Immediate Family Member of a person includes any spouse, child, stepchild, grandchild, parent, stepparent, grandparent, sibling, mother-in-law, father-in-law, daughter-in-law, brother-in-law, or sister-in-law of such person, including adoptive relationships, who lives in the same house with such person.

Initial Public Offering (IPO) means an offering of securities registered under the Securities Act of 1933, the issuer of which immediately before the registration was not subject to the reporting requirements of sections 13 or 15(d) of the Securities Exchange Act of 1934.

Limited Offering means a private offering of securities that is exempt from registration under section 4(2) or section 4(6) of the Securities Act of 1933, or under Rule 504, 505, or 506 (Regulation D) under that statute.

Limited Offering includes any offering of interests in a private investment fund or a private equity fund, including the TIFF Investment Vehicles (other than TIP).

Member means an investor in a TIFF Investment Vehicle.

Money Manager means an investment management firm other than TAS or TEAM which makes and implements investment decisions for one or more of the TIFF Investment Vehicles. For purposes of this Code, Money Managers include separate account managers for the TIFF Investment Vehicles and managers of acquired funds in which one or more of the TIFF Investment Vehicles invest.

Overlapping Personal Investment means an initial or subsequent investment by a Supervised Person for their personal account or Beneficial Ownership in a security that is the subject of a Limited Offering and such security presently is either (i) held by one or more TIFF Investment Vehicles or (ii) being considered for investment by one or more TIFF Investment Vehicles; provided, however, that an investment by a Supervised Person in a TIFF Investment Vehicle shall not be considered an Overlapping Personal Investment. Generally, an Overlapping Personal Investment would exist only if a Supervised Person and a TIFF Investment Vehicle hold or intend to invest in securities of the same class or series in the same legal entity. However, the CCO may determine there to be an Overlapping Personal Investment in other situations, including but not limited to Limited Offering securities that are part of a a “master-feeder” or “hub-and-spoke” structure.

Reportable Security means, for purposes of the reporting requirements of Section VI of the Code, any financial instrument that is known as a security and as defined in detail in Section 202(a)(18) of the Advisers Act, except that it does not include:

Reportable Securities include exchange-traded funds (ETFs), whether organized as a unit investment trust or an open-end fund, the TIP mutual funds and the other TIFF Investment Vehicles.

Reportable Securities also include stock options obtained via purchase or grant, security-based swaps, and stock and narrow-based stock index futures. See Section VI of the Code for further details.

Reportable Securities do not include money market funds, mutual funds not advised by TAS or TEAM, or interests in Section 529 college savings plans. Reportable Securities also do not include Bitcoin and other digital currencies or “commodity interests,” including physical commodities, futures (excluding single stock and narrow-based stock index futures), options on commodities and futures, swaps (excluding security-based swaps), and currency transactions and forward contracts.

Restricted List means the list maintained by TAS and TEAM which identifies those issuers, if any, (i) in whose securities trading by TAS, TEAM and/or Supervised Persons is prohibited, either permanently or from time to time.

Supervised Person means any:

(i) Access Person (as defined above), or

(ii) Officer or trustee of TIP, other than a TIP Independent Trustee.

Supervised Consultant means a paid consultant of TAS who has entered into a consulting services agreement with TAS (and who is an independent contractor of TAS rather than a TAS officer or employee), as determined by the CCO, provided that such consultant (i) is not involved in the selection of portfolio securities, (ii) does not have access to material, non-public information regarding future purchases or sales of portfolio securities for the account of, or non-public information regarding the portfolio holdings of, any TIFF Investment Vehicle, and (iii) does not make any recommendation regarding the purchase or sale of securities for the TIFF Investment Vehicles or have access to such recommendations that are non-public.

TIFF Investment Vehicles means the investment vehicles for which either TAS or TEAM serves as investment adviser, managing member, general partner, or equivalent.

TIFF Investment Vehicles include TIP and the non-registered investment vehicles managed by TAS or TEAM.

TIP means the TIFF Investment Program registered mutual funds.

TIP Independent Trustee means a trustee of TIP who is not an “interested person” of TIP as defined in Section 2(a)(19) of the 1940 Act.

Statement of Policy. Each of TIP, TAS and TEAM prohibits any Supervised Person from trading, either personally or on behalf of others, including client accounts, while in possession of material non-public information in violation of the law. This conduct is commonly referred to as insider trading. Supervised Persons that gain access to any material non-public information shall not make impermissible use of such information for any direct or indirect personal benefit. This restriction applies regardless of the source of such information and includes trading securities on the basis of such material, non-public information, advising others to trade on such basis, or transmitting such information to others who may trade on such information.

Prohibition on Trading. Generally, it is illegal to trade in securities while in possession of material non-public information that might affect the value of those securities or to transmit that information to others who may trade in those securities. Supervised Persons should be aware that illegal insider trading can result in significant civil and criminal penalties. Supervised Persons generally should not trade while in possession of material non-public information or transmit such information to others who may trade on such information. There are certain limited circumstances when it may be legally permissible to trade while in possession of material non-public information, but Supervised Persons are required to consult with the CCO prior to entering into any securities transaction involving material non-public information, including transactions in securities issued by the TIFF Investment Vehicles. Any Supervised Person with knowledge of material, non-public information should report and discuss such information only to or with the CCO. Because the law of insider trading involves a number of complex legal interpretations, Supervised Persons are strongly encouraged to confer with the CCO if such Supervised Persons have any question about whether they may be in possession of material non-public information before entering into any securities transaction that may involve such material non-public information. Every Supervised Person must follow the procedures described herein or risk serious sanctions, including dismissal, substantial personal liability, and criminal penalties, including jail sentences. Supervised Persons should note that the requirements set forth in this Section IV apply equally to transactions in securities issued by the TIFF Investment Vehicles.

Identifying Inside Information. Before any Supervised Person trades for themselves or others, including accounts managed by TAS or TEAM, in the securities of a company about which the Supervised Person may have material non-public, or “inside information,” that Supervised Person should ask following questions:

i. Is the information material? That is, is it information that an investor would consider important in making their investment decision? Is this information that would substantially affect the market price of the securities if generally disclosed?

Information is material if there is a substantial likelihood that a reasonable investor would consider it important in making an investment decision, or if that information is reasonably certain to have a substantial effect on the price of an issuer’s securities. Material information can be positive or negative, and can relate to any aspect of a company’s business or to a type of security. While this definition is intentionally broad, examples may include: (i) revenue and earnings information, including projections and forward-looking information; (ii) mergers, acquisitions, tender offers, joint ventures, or changes in assets (even if preliminary); (iii) new products; (iv) developments about customers or suppliers, such as the loss of a major contract; (v) changes in control or management; (vi) events regarding an issuer’s securities, including defaults; calls of securities for redemption; repurchase plans; stock splits; changes in dividends; changes to rights of security holders; debt restructurings; convertible bond offerings; PIPE transactions; and public or private sales of securities; (vii) change in auditors or audit report; and (viii) bankruptcies or receiverships.

ii. Is the information non-public? To whom has this information been provided? Has the information been effectively communicated to the marketplace by, for example, being published in Reuters, Bloomberg, The Wall Street Journal, or other publications of general circulation?

Information is non-public until it has been effectively communicated to the marketplace. Practically speaking, this means that some fact will show that the information is available to the general public, e.g. through an SEC filing, a newspaper or online article, a quotation service such as Bloomberg, or a widely distributed communication by the issuer. A rumor or other information known to a smaller segment of the investment community (even if true) is not considered sufficient public disclosure.

If, after consideration of the above, the Supervised Person believes that the information is material and non-public, or if the Supervised Person has questions as to whether the information is material and non-public, that Supervised Person should consult with the CCO to determine if the information is material and non-public. Supervised Persons must not trade while in possession of material non-public information (even if that information is not a factor or is among other factors in a decision to trade).

Supervised Persons should be sensitive to the following scenarios where they may be more likely to learn material non-public information:

Restricted List

Should a Supervised Person believe that they have material non-public information concerning the issuer of any security (regardless of whether it is currently owned by a TIFF Investment Vehicle or any other client), that information must be provided immediately to the CCO so that the issuer can be considered for inclusion on the Restricted List. Supervised Persons also should notify and discuss with the CCO any sensitive or confidential information they have concerning the issuer of any security, even if such information may not technically meet the definition of material non-public information, for possible inclusion on the Restricted List out of an abundance of caution.

The CCO is responsible for adding and removing names from the Restricted List. The CCO will consider the nature of the information learned, the context in which the information was learned, the time the information was learned, other persons in possession of the information, and such other factors as they may deem relevant in determining whether the information learned should be considered material non-public information and/or whether a particular name should be added to or removed from the Restricted List. If a Supervised Person serves on the board of directors of a public company, that public company name typically will be added to the Restricted List for as long as such Supervised Person serves on the board; provided, however, that the CCO may remove such name from the Restricted List during periods that the company in question permits its directors and other insiders to trade its securities and the Supervised Person in question represents to the CCO that they do not have material non-public conformation concerning such company.

The Restricted List also may include from time to time names of certain issuers whose securities TAS or TEAM trades directly, in which case Supervised Persons will be prohibited from purchasing or selling such securities for so long as they are included on the Restricted List (in effect, a “blackout period” on trading such securities). In that regard, the Restricted List will include only those direct traded securities that had an average 30 daily trading volume of greater than 1%, which TAS believes is a reasonable and appropriate test above which it was very unlikely that personal trading by a Supervised Person in a security could impact TAS’s trading in that security. Also, one category of securities that TAS trades directly, securities that are distributed in kind to the private equity funds managed by TAS, are not subject to the 1% trading volume test so that all such “DIK” securities will be included on the Restricted List for such period as TAS is actively selling them, regardless of their trading volume.

After a name is added to or removed from the Restricted List, the CCO or their designee will promptly circulate the revised Restricted List to all Supervised Persons. The Restricted List and the information contained therein must be kept confidential and may not be shared with or provided to any third parties absent the prior approval of the CCO.

No Supervised Person may purchase or sell securities of any issuer appearing on the Restricted List. In addition, as noted on the Restricted List, TAS and TEAM also may be prohibited from purchasing or selling, either for itself or on behalf of a client, securities of one or more of the issuers appearing on the Restricted List.

Rumor Policy. Supervised Persons should be aware that it is illegal to intentionally create or spread false rumors or information about a security or its issuer for the purpose of affecting a security’s price or manipulating the market. Therefore, no Supervised Person shall originate or, except as permitted below, circulate in any manner a false or misleading rumor about a security or its issuer for the purpose of influencing the market price of the security or otherwise manipulating the market.

Where a legitimate business reason exists for discussing a rumor (for example, where a client is seeking an explanation for an erratic share price movement which could be explained by the rumor), care should be taken to ensure that the rumor is communicated in a manner that: (a) sources the origin of the information (where possible); (b) gives it no additional credibility or embellishment; (c) makes clear that the information is believed to be a rumor; and (d) makes clear that the information has not been verified.

If asked about a rumor relating to TAS, TEAM, TIP, or another TIFF Investment Vehicle, Supervised Persons generally should respond that it is our policy not to comment on market rumors or speculation.  Any exceptions to this policy should be discussed in advance with the CCO.

Protection of Confidential Information. In addition to the restrictions set forth above regarding the use of material non-public information, Supervised Persons are expected to conduct business in a manner that protects confidential information relating to TAS, TEAM, the TIFF Investment Vehicles (including portfolio holdings and information about underlying funds), Members, and any other TAS or TEAM clients. Supervised Persons are prohibited from intentionally disclosing confidential information relating to TAS, TEAM, the TIFF Investment Vehicles, Members, and any other TAS or TEAM clients to outsiders (including relatives). In addition, in order to protect any confidential information from being publicly disseminated accidentally, Supervised Persons should note the following guidelines:

More detailed procedures and controls regarding the protection of confidential information are set forth and should be referenced in TAS and TEAM’s Information Security Program. All Supervised Persons who are TAS employees are required to meet the requirements and comply with the provisions of the Information Security Program.

These policies are drafted with the intent that the interests of clients of TAS and TEAM, such as direct advisory clients of TAS, and the TIFF Investment Vehicles, including TIP, should take priority over a Supervised Person’s personal interests or benefits. Supervised Persons generally should also consider the interests of Members, provided that such Members’ interests are not inconsistent with the interests of clients of TAS and TEAM. Supervised Persons should avoid any conflict of interest, the potential for conflict, or even the appearance of such conflict. Decisions about the best interests of clients and Members should not be compromised or appear to be compromised by a Supervised Person’s personal investments, interests or benefits. Notwithstanding the foregoing, Supervised Persons are permitted to participate in Overlapping Private Investments (as defined herein), subject to the terms and conditions set forth in Section VI.

Questions of proper business ethics and conflicts of interest are often difficult to determine and resolve. If there is any uncertainty about a given situation, please consult the CCO before acting.

Fiduciary Duty

As investment advisers, TAS and TEAM owe a fiduciary duty to their clients. This fiduciary duty is comprised of both the duty of loyalty and the duty of care. An adviser and client may shape the scope of their relationship by agreement if there is full and fair disclosure and informed consent; however, the adviser’s fiduciary duty cannot be waived.

In general, the duty of care requires an adviser to provide investment advice in the best interests of each client based on the client’s objectives. To do so, TAS and TEAM must have a reasonable understanding of each client’s objectives or, with respect to the TIFF Investment Vehicles, their specific investment mandates and investment guidelines and objectives. The duty of care includes the requirement that an adviser have a reasonable belief that the advice is in the best interests of its clients. An adviser’s duty of care also includes a duty to seek best execution of a client’s transactions where the adviser has the responsibility to select broker-dealers to execute client trades. Finally, an adviser’s duty of care encompasses the duty to provide advice and monitoring at a frequency that is in the best interests of each client.

In general, the duty of loyalty means that an adviser may not subordinate its clients’ interests to its own. To meet this standard, an adviser must (i) make full and fair disclosure to its clients of all material facts relating to the advisory relationship, including the capacity in which the firm is acting with respect to the advice provided; and (ii) eliminate or mitigate, or at least expose through full and fair disclosure, all conflicts of interest which might include an adviser, consciously or unconsciously, to render advice which was not disinterested. For disclosure to be full and fair, it should be sufficiently specific so that a client is able to understand the material fact or conflict and make an informed decision.

Political Contributions and Solicitations

Procedures regarding Outside Activities

Upon receipt of disclosures furnished pursuant to the preceding section, the CCO shall take such actions as they deem necessary or appropriate under the circumstances.

All Access Persons are subject to the following procedures pertaining to personal trading of Reportable Securities for their own accounts or for accounts in which the Access Person has Beneficial Ownership.

Procedures

Pre-Approval Required for Purchases of Securities in a Limited Offering or an Initial Public Offering

Access Persons must obtain prior written approval of the CCO for the acquisition of Beneficial Ownership in any Reportable Security in an Initial Public Offering or Limited Offering (including a Limited Offering of a TIFF Investment Vehicle). The Access Person may submit a request for approval that provides the proposed transaction date, name and description of the Reportable Security, number of shares or amount of transaction, transaction type (purchase or other type of acquisition), and any additional information that is relevant to the transaction. If the Access Person making the request is a member of the investment staff of TAS or TEAM, he or she must also indicate whether the Reportable Security was made available to the TIFF Investment Vehicles and, if so, what decision TAS or TEAM, as applicable, made regarding that Reportable Security. The Access Person may be required to represent to the CCO that the Reportable Security is not being offered to them with an expectation of favored treatment from TAS, TEAM or the TIFF Investment Vehicles.

With respect to Limited Offerings by private equity fund issuers (including TIFF Investment Vehicles) or similarly structured investment vehicles that may be subject to capital calls or draw downs, Access Persons are required to obtain written approval of the CCO for the full amount of their commitment to each such issuer prior to committing any money to such issuer. Access Persons are not, however, required to obtain prior written approval for each transfer of money made in response to capital calls or draw downs exercised by such a private equity fund issuer pursuant to such issuer’s legal right to call a portion of the money which has been committed by such Access Persons to such issuer.

Pre-Approval Required for Purchases and Redemptions of TIP Shares

Access Persons must obtain prior written approval of the CCO for the acquisition or redemption or other disposition of Beneficial Ownership in any shares issued by a TIP mutual fund. This includes shares of a TIP mutual fund that are acquired or redeemed in an Access Person’s individual retirement account (IRA). The Access Person may submit a request for approval that provides the proposed transaction date, number of shares or amount of transaction, transaction type, and any additional information that is relevant to the transaction. Prior written approval is required for subsequent purchases as well as initial purchases of shares issued by a TIP mutual fund. Access Persons are not, however, required to obtain prior written approval for: (a) redemptions of shares of a TIP mutual fund that are effected solely in order to fund capital calls or draw downs exercised by other TIFF Investment Vehicles in which such Access Persons are invested, when such redemptions are effected pursuant to powers of attorney or standing instructions previously received from such Access Persons; (b) purchases of shares of a TIP mutual fund that are effected solely in order to invest distribution proceeds received from other TIFF Investment Vehicles in which such Access Persons are invested, when such purchases are effected pursuant to powers of attorney or standing instructions previously received from such Access Persons; or (c) redemptions of shares of TIFF Multi-Asset Fund that are effected in accordance with such Fund’s systematic withdrawal plan.

Pre-Approval Required for Opening Brokerage Accounts

Supervised Persons must obtain prior written approval of the CCO before they or any of their Immediate Family Members open a Brokerage Account (with the exception of SEP IRA accounts with Charles Schwab that are opened by TAS for Supervised Persons).

General Criteria Used in Determining Pre-Approval

The CCO will respond as quickly as practicable to requests for pre-approval of transactions.

With respect to the acquisition of Beneficial Ownership in any Reportable Security in an Initial Public Offering or Limited Offering, approval will be based on the determination that the transaction does not present, or can be structured to avoid, a material conflict of interest between the Access Person, on the one hand, and Members and clients of TAS or TEAM, on the other hand. In considering whether there is a material conflict, the CCO will consider, among other things, whether a TIFF Investment Vehicle is planning to invest in the Reportable Security, whether the investment opportunity was facilitated by the Access Person, and whether the investment opportunity is size-constrained.² The CCO’s pre-approval decisions concerning proposed Overlapping Personal Investments will primarily be based on whether such proposed investments comply with the terms and conditions set forth below, although the CCO may also consider the general criteria discussed above and other relevant information.

With respect to the purchase or redemption of shares issued by a TIP mutual fund, approval will be based on the determination that the transaction does not present, or can be structured to avoid, a material conflict of interest between the Access Person, on the one hand, and Members and clients of TAS or TEAM, on the other hand. In addition, approval will not be granted if the CCO determines that the Access Person is purchasing or redeeming shares issued by a TIP mutual fund based upon their possession of material non-public information that could reasonably be expected to positively impact the value of the shares issued by such TIP mutual fund.

² Because TIFF Investment Vehicles do not typically invest in Initial Public Offerings, these issues are most likely to arise in connection with Limited Offerings in hedge funds, and other private fund offerings in which a TIFF Investment Vehicle may seek to invest.

With respect to opening brokerage accounts, approval will be primarily based on whether or not the broker in question is able to facilitate automatic electronic feeds of transaction confirms and account statements into the Schwab Compliance Technologies compliance software solution that is utilized by TAS.

Trading That May Disadvantage Clients

Supervised Persons’ personal trading must be conducted in a manner that does not disadvantage clients. Supervised Persons may not take for themselves investment opportunities suitable for client accounts or otherwise disadvantage client accounts. Supervised Persons are not permitted to trade in the same securities that are traded by the Advisers for the Advisers’ client accounts ahead of the client trades or on the same day that client trades are placed by the Advisers. In addition, no Supervised Person may engage in the practices of “front-running.” Front running can occur if a Supervised Person knows of a pending “buy” recommendation by an Adviser and buys securities or other instruments before such Adviser takes action on the recommendation for its clients, or if a Supervised Person is aware of a pending “sell” recommendation and sells securities or other instruments before such Adviser takes action on the recommendation for its clients.

Stock Options, Short Sales and Certain Other Derivatives

A “stock option” is a security which gives the owner the right, but not the obligation, to buy or sell a specific security at a specified price within a specified time frame. Stock options include puts (an option to sell a security) and calls (an option to buy a security), as well as combinations of puts and calls such as straddles. Stock options may be exchange traded (also known as listed options) or over-the-counter (OTC). Employee stock options are a form of stock option which are granted to employees based on the stock of their employer’s company. Employee stock options are generally used as a form of remuneration, bonus, or incentive to join a company.

Stock options, whether purchased by or granted to an Access Person or an Immediate Family Member, are considered to be Reportable Securities. Therefore, transactions in employee stock options in which you or a spouse or other Immediate Family Member engage must be reported quarterly and holdings of such stock options must be reported annually. (Please note that employee stock option transactions and holdings may occur outside of your and your spouse’s Brokerage Account(s)).

A “short sale” is a transaction in which the short seller borrows shares of an issuer and sells them to a third party, expecting that the shares will be cheaper to buy back in the future because of a decrease in the price of the issuer’s stock. Short sales of Reportable Securities by you or a spouse or other Immediate Family Member must be reported quarterly.

A “security-based swap” is a swap transaction that is based on (i) a narrow-based security index, (ii) a single security or loan, or (iii) the occurrence or nonoccurrence of an event relating to a single issuer of a security or the issuers of securities in a narrow-based security index, provided that such event directly affects the financial statements, financial obligations, or financial condition of the issuer. A “security-based future” is a contract of sale for future delivery of a single security or of a narrow-based security index. Security-based swaps and security-based futures are considered to be Reportable Securities. Therefore, transactions in these instruments in which you or a spouse or other Immediate Family Member engage must be reported quarterly and holdings of such instruments must be reported annually.

Bitcoin and Other Digital Currencies

Bitcoin has been described as a decentralized, peer-to-peer virtual currency that is used like money – it can be exchanged for traditional currencies such as the U.S. dollar, or used to purchase goods or services, usually online.  Unlike traditional currencies, Bitcoin operates without central authority or banks and is not backed by any government.

Under the Code, Bitcoin and other digital currencies are not considered to be Reportable Securities (whether purchased or held for investment or speculative purposes or for use as payment for goods and services). However, an investment in an Initial Coin Offering (“ICO”) may be considered to be a Reportable Security and Access Persons should consult with the CCO prior to investing in an ICO to confirm whether the proposed ICO investment would be a Reportable Security. ICOs are the cryptocurrency industry’s equivalent to an Initial Public Offering, in which interested investors have the opportunity to buy into an initial offering of a new digital currency and receive in return a new cryptocurrency token issued by the company sponsoring the ICO. ICO investments also may be considered to be Initial Public Offerings and therefore Access Persons may be required to obtain prior written approval of the CCO for the acquisition of Beneficial Ownership in any ICO (as set forth in Section VI of the Code).

Terms and Conditions for Overlapping Personal Investments

In the event that a Supervised Person wishes to make an Overlapping Personal Investment, he or she must obtain the pre-approval of the CCO, whose pre-approval will primarily be based on whether such Overlapping Personal Investment complies with the following terms and conditions:

In the event that a Supervised Person who wishes to make an Overlapping Personal Investment is a person to whom the CCO reports, such Supervised Person must obtain the pre-approval of TAS’s Chief Executive Officer in addition to the pre-approval of the CCO prior to making the proposed Overlapping Personal Investment.

The CCO shall monitor purchases, redemptions and sales of Limited Offering securities by Supervised Persons that are reported in the quarterly transaction reports that are required by this Code of Ethics in order to assess (i) whether and to what extent conflicts of interest may exist or have arisen after an Overlapping Personal Investment is made and (ii) whether any Limited Offering securities that were redeemed were made available initially as investments to applicable TIFF Investment Vehicles.

Reporting Requirements

All Access Persons are subject to the following procedures pertaining to reporting for accounts in which the Access Person has Beneficial Ownership of a Reportable Security.

Exempt Transactions

The Code’s reporting requirements do not apply to the following transactions:

Reporting Requirements for Third-Party Discretionary Accounts

Rule 204A-1(b)(3)(i) of the Advisers Act and Rule 17j-1(d)(2)(i) of the 1940 Act each provide an exemption (the “Reporting Exemption”) to the above reporting requirements with respect to an access person’s “securities that are held in accounts over which the access person had no direct or indirect influence or control.” However, in IM Guidance Update No. 2015-03, published by the Securities and Exchange Commission in June 2015, the SEC staff clarified the circumstances in which the Reporting Exemption is available. The staff contrasted a “blind trust” – an arrangement in which a trustee manages a securities account for an access person who has no knowledge of the trustee’s actions and no power to interfere with the trustee’s actions – with other types of trusts and discretionary accounts. According to the staff, a blind trust would be within the Reporting Exemption. However, the staff noted, the fact that an access person provides a trustee or a third-party manager discretionary investment authority over a personal account “by itself, is insufficient for an adviser to reasonably believe that the access person had no direct or indirect influence or control over the trust or account for purposes of relying on the [Reporting Exemption].”

As a result of the above guidance, all Access Persons are required to quarterly report the transactions that occur within, and to initially and annually report the holdings of, any third-party discretionary accounts that they have established in which any Reportable Securities are held for the Access Person’s direct or indirect benefit, unless the third-party discretionary account qualifies for the Reporting Exemption.

In order for an Access Person to rely on the Reporting Exemption for a third-party discretionary account, the CCO must reasonably determine that the Access Person has no direct or indirect influence or control over such account. In order for the CCO to make this determination, the Access Person in question must certify on a quarterly basis that: (1) they reasonably believe that the third-party manager has full discretionary authority over the account; (2) the opening of the account was not conditioned or dependent upon any current or future investment by any TIFF Investment Vehicles in any investment fund sponsored by the third-party manager; (3) they did not exercise direct or indirect influence or control over the account; (4) they did not suggest the third-party adviser make any particular purchases or sales of securities for the account; (5) they did not direct the third-party manager to make any particular purchases or sales of securities for the account; and (6) they did not consult with the third-party manager as to the particular allocation of investments to be made in the account.

Any accounts that do not qualify for the Reporting Exemption must satisfy all of the reporting and pre-approval requirements discussed above that pertain to accounts in which the Access Person has Beneficial Ownership of a Reportable Security.

TIP Independent Trustees are subject only to the requirements set forth in this Section VII of the Code and are NOT subject to the other provisions of the Code.

Material Non-Public Information. To the extent that a TIP Independent Trustee should learn of any material non-public information, that trustee should conduct himself or herself in accordance with the terms of Section IV of this Code. TIP Independent Trustees are prohibited from trading, either personally or on behalf of others, in securities issued by the TIP mutual funds or other TIFF Investment Vehicles while in possession of material non-public information (commonly referred to as insider trading). TIP Independent Trustees that gain access to any material non-public information concerning the TIP mutual funds or other TIFF Investment Vehicles shall not make impermissible use of such information for any direct or indirect personal benefit. This restriction applies regardless of the source of such information and includes trading securities issued by the TIP mutual funds or other TIFF Investment Vehicles on the basis of such material, non-public information or advising others to trade on such basis.

Conflicts of Interest. It is acknowledged that the TIP Independent Trustees owe duties to both their employers and to TIP and that, should a conflict of interest arise in this regard, such conflict must be managed in an acceptable manner. The TIP Independent Trustees are encouraged to consult with the CCO should any such conflicts arise.

Conduct of TIP Independent Trustees. A TIP Independent Trustee shall not:

Reporting Requirements. If, during the 15-day period immediately before or after a transaction in a Reportable Security by a TIP Independent Trustee, that Trustee knows or, in the ordinary course of fulfilling their official duties as a trustee, should have known that a TIFF Investment Vehicle purchased or sold or considered purchasing or selling the same Reportable Security, the trustee shall be required to report such transaction to the CCO.

Pre-Approval Required for Purchases and Redemptions of TIP Shares

TIP Independent Trustees must obtain prior written approval of the CCO for the acquisition or redemption or other disposition of Beneficial Ownership in any shares issued by a TIP mutual fund. The TIP Independent Trustee may submit a request for approval that provides the proposed transaction date, number of shares or amount of transaction, transaction type, and any additional information that is relevant to the transaction. Prior written approval is required for subsequent purchases as well as initial purchases of shares issued by a TIP mutual fund. TIP Independent Trustees are not, however, required to obtain prior written approval for: (a) redemptions of shares of a TIP mutual fund that are effected solely in order to fund capital calls or draw downs exercised by other TIFF Investment Vehicles in which such TIP Independent Trustees are invested, when such redemptions are effected pursuant to powers of attorney or standing instructions previously received from such TIP Independent Trustees; (b) purchases of shares of a TIP mutual fund that are effected solely in order to invest distribution proceeds received from other TIFF Investment Vehicles in which such TIP Independent Trustees are invested, when such purchases are effected pursuant to powers of attorney or standing instructions previously received from such TIP Independent Trustees; or (c) redemptions of shares of TIFF Multi-Asset Fund that are effected in accordance with such Fund’s systematic withdrawal plan.

The general criteria used by the CCO in determining whether to grant pre-approvals are set forth in Section VI.

Supervised Consultants are subject only to the requirements set forth in this Section VIII of the Code and are NOT subject to the other provisions of the Code.

Material Non-Public Information. Supervised Consultants should not trade while in possession of material non-public information (commonly referred to as insider trading) or transmit such information to others who may trade on such information. To the extent that a Supervised Consultant should learn of any material non-public information, they should conduct themselves in accordance with the terms of Section IV of this Code. Supervised Consultants are prohibited from trading, either personally or on behalf of others, in securities issued by a TIFF Investment Vehicle while in possession of material non-public information (commonly referred to as insider trading). Supervised Consultants that gain access to any material non-public information concerning a TIFF Investment Vehicle shall not make impermissible use of such information for any direct or indirect personal benefit. This restriction applies regardless of the source of such information and includes trading securities issued by the TIFF Investment Vehicles on the basis of such material, non-public information or advising others to trade on such basis.

Overriding Principles and Conflicts of Interest. Each Supervised Consultant must recognize that the interests of clients of TAS should take precedence and that they must avoid any abuse of their positions of trust and responsibility. Each Supervised Consultant is expected to accept the obligations that apply to fiduciaries, to place the interests of clients ahead of their own, and to be aware of and avoid any situation that may give rise to any actual, perceived or potential conflict of interest with a client’s interests. It is acknowledged that Supervised Consultants owe duties to both their employers and to TAS and that, should a conflict of interest arise in this regard, such conflict must be managed in an acceptable manner. Supervised Consultants are encouraged to consult with the CCO should any such conflicts arise.

Conduct of Supervised Consultants. A Supervised Consultant shall not:

Supervised Consultants are required to comply with all Federal Securities Laws. In addition, it is strictly prohibited for any Supervised Consultant, either directly or indirectly, to offer or make any bribes, kickbacks, rebates or other payments to any company, financial institution, person or U.S. or foreign governmental official to obtain favorable treatment in receiving or maintaining business.

Supervised Consultants will not have independent or individual access to TAS’ proprietary data, management, or research systems, or client data, including but not limited to personally identifiable information (information that, when used alone or with other relevant data, can identify an individual) and information regarding future purchases or sales of portfolio securities or other investments, recommendations regarding the purchase or sale of portfolio securities or other investments, or portfolio holdings of, any TAS advisory client or any TAS-advised fund. Supervised Persons are required to protect confidential information relating to TAS, TEAM, the TIFF Investment Vehicles, including TIP, any other TAS or TEAM clients, and Members.

Each Supervised Consultant shall be provided a copy of the Code and all amendments that are applicable to Supervised Consultants and each Supervised Consultant is required to read and understand these policies and procedures and provide a certification or representation to that effect. Failure to comply with these policies and procedures may result in disciplinary action by TAS, up to and including withholding of fees payable pursuant to a Supervised Consultant’s consulting agreement or termination of such consulting agreement, as well as civil and criminal liability, including legal prohibition against further employment in the securities industry.

TAS Advisory Board members are subject only to the requirements set forth in this Section IX of the Code and are NOT subject to the other provisions of the Code.

Material Non-Public Information. TAS Advisory Board members should not trade while in possession of material non-public information (commonly referred to as insider trading) or transmit such information to others who may trade on such information. To the extent that a TAS Advisory Board member should learn of any material non-public information, they should conduct themselves in accordance with the terms of Section IV of this Code. TAS Advisory Board members are prohibited from trading, either personally or on behalf of others, in securities issued by a TIFF Investment Vehicle while in possession of material non-public information (commonly referred to as insider trading). TAS Advisory Board members that gain access to any material non-public information concerning a TIFF Investment Vehicle shall not make impermissible use of such information for any direct or indirect personal benefit. This restriction applies regardless of the source of such information and includes trading securities issued by the TIFF Investment Vehicles on the basis of such material, non-public information or advising others to trade on such basis.

Conflicts of Interest. Each TAS Advisory Board member must recognize that they must avoid any abuse of their positions of trust and responsibility. Each TAS Advisory Board member is expected to be aware of and avoid any situation that may give rise to any actual, perceived or potential conflict of interest with TAS’s or a TAS client’s interests. It is acknowledged that, should a conflict of interest arise in this regard, such conflict must be managed in an acceptable manner. TAS Advisory Board members are encouraged to consult with the CCO should any such conflicts arise.

Conduct of TAS Advisory Board Members. A TAS Advisory Board member shall not:

TAS Advisory Board members are required to comply with all Federal Securities Laws. In addition, it is strictly prohibited for any TAS Advisory Board member, either directly or indirectly, to offer or make any bribes, kickbacks, rebates or other payments to any company, financial institution, person or U.S. or foreign governmental official to obtain favorable treatment in receiving or maintaining business.

TAS Advisory Board members will not have independent or individual access to TAS’ proprietary data, management, or research systems, or client data, including but not limited to personally identifiable information (information that, when used alone or with other relevant data, can identify an individual) and information regarding future purchases or sales of portfolio securities or other investments, recommendations regarding the purchase or sale of portfolio securities or other investments, or portfolio holdings of, any TAS advisory client or any TAS-advised fund. TAS Advisory Board members are required to protect confidential information relating to TAS, TEAM, the TIFF Investment Vehicles, including TIP, any other TAS or TEAM clients, and Members.

Each TAS Advisory Board member shall be provided a copy of the Code and all amendments that are applicable to TAS Advisory Board members and each TAS Advisory Board member is required to read and understand these policies and procedures and provide a certification or representation to that effect. Failure to comply with these policies and procedures may result in disciplinary action by TAS, as well as civil and criminal liability, including legal prohibition against further employment in the securities industry.

Administration

The CCO shall be responsible for administering this Code and shall take all steps necessary to implement the provisions of the Code, including the following:

Recordkeeping

The CCO shall preserve, or ensure the preservation of, in an easily accessible place for five years:

The CCO shall preserve, or ensure the preservation of, Access Persons’ personal trading records. The records will be accessible only to the individual, the CCO, and applicable regulatory agencies, as well as any other person reasonably determined by the CCO as necessary or appropriate to have access for a particular purpose. All reports of personal securities transactions and any other information filed pursuant to the Code will be treated as confidential information to the extent permitted by law. Records will be maintained for at least six years, the first two years in an easily accessible place.