Exhibit (p11)

CODE OF ETHICS

The Code of Ethics, in conjunction with the Compliance Manual, sets forth policies and procedures to assist the Access Persons of Westbeck Capital Management LLP (“Westbeck” or the “Firm") in complying with their fiduciary duty to the Firm’s clients.

An Access Person is defined as any supervised person of the Firm who (i) has access to non-public information regarding clients’ purchase or sale of securities or (ii) is involved in making securities decisions or recommendations to clients or has access to such decisions and recommendations that are not public.

The Firm takes the position that all staff involved in the day to day business of the Firm are Access Persons.

The Code of Ethics sets out the standards of conduct expected of the Firm’s staff and details policies and procedures addressing certain potential conflicts of interest.

Staff are responsible for reading, understanding and consenting to comply with the Code of Ethics. Any questions regarding the policies set out below should be directed to the Compliance Officer. Westbeck requires each member of staff to provide written acknowledgement of receipt of the Code of Ethics upon joining the Firm and annually thereafter. An additional acknowledgement will be required upon material amendments to the Firm’s policies and procedures.

The importance of compliance with this Code of Ethics cannot be overemphasized. Failure to comply may result in fines, censures and other sanctions against Westbeck and/or staff of the Firm. A member of staff found not to be in compliance with the Code of Ethics will be subject to disciplinary measures up to and including termination. Any staff member who has or obtains knowledge of information that constitutes a violation of the Code of Ethics must promptly notify the Compliance Officer. The Firm discloses certain aspects of its Code of Ethics on the Form ADV.

Westbeck is a “fiduciary” to the Firm’s clients and has a fundamental obligation to act in their best interests. Staff should not engage in any activity that may represent a conflict of interest to any client and are expected to take reasonable steps to fulfil the Firm’s fiduciary obligation on an ongoing basis.

In addition, in connection with advisory services that Westbeck provides to a client that is registered under the Investment Company Act (a “RIC Client”), Westbeck is subject to the provisions of Rule 17j-1 under the Investment Company Act. Accordingly, in connection with the purchase or sale, directly or indirectly, of a security held or to be acquired by a RIC Client, staff must not:

Staff are required to follow the policies of the Firm and all applicable federal securities laws. Violations of the Code of Ethics, the Compliance Manual, or securities regulations must be promptly reported to the Compliance Officer. Violations may result in severe penalties to the Firm and the individuals involved, including potential civil or criminal penalties.

To fulfil the Firm’s regulatory obligations the Firm must fully understand any activities of its staff that might give rise to a conflict or a potential conflict with the Firm’s clients. To that end, Westbeck has established policies and procedures regarding the following activities:

All activities of the Compliance Officer that require preclearance will be approved by Sam Dipper, General Counsel.

This Policy covers all accounts holding reportable securities in which a staff member has a direct or indirect beneficial ownership and includes any accounts maintained by of for:

A staff member is deemed to have beneficial ownership if the staff member has or shares a direct or indirect opportunity to profit or share in any profit derived from the account.

The term reportable securities includes all traditionally traded instruments as defined in Section 202(a)(18) of the Advisers Act, except:

The SEC has taken the position that Exchange Traded Funds are reportable securities and as such must be reported pursuant to these procedures.

Staff must obtain pre-approval from the Compliance Officer prior to undertaking any transactions in any reportable securities, including initial public offerings.

Staff members must also obtain pre-approval to participate in any limited offering or private investment.

In all transactions involving securities exempt from pre-approval, staff should conform to the spirit of the Code of Ethics and avoid any activity which might appear to conflict with the interests of the Firm or its clients.

Trade requests must contain the following:

The requested transaction must be executed within 24 hours of the approval. The Compliance Officer maintains all requests and approvals on file.

Staff are discouraged from frequent or excessive trading or trading in highly speculative securities or other instruments. Such trading activities are more likely to give rise to conflicts or perceived conflicts and to detract from the Firm’s client investment focus. Trading on the basis of actual or possible material non-public information i.e. inside information is strictly prohibited, as set out in the Firm’s Compliance Manual. The Firm encourages staff to adopt a medium to long-term investment strategy, as opposed to a short-term trading strategy.

All trades involving securities of individual companies require a 30-day holding period. All other trades require a 5-day holding period. These holding periods do not apply to exercises of calls or puts or options that occur automatically, and not as a result of any action by the employee.

Pre-approval is not required for transactions in accounts managed by a professional adviser and over which the staff member exercises no discretion. While third party managed accounts must be approved by the Compliance Officer, the securities maintained by such accounts do not need to be reported on annual or quarterly holdings reports (see below).

In order for the Compliance Officer to confirm that an account is solely managed by a third party the staff member and professional adviser will provide an initial and periodic representations confirming the terms of the arrangement. The Compliance Officer reserves the right to, on a sample basis, request reports on transactions and/or holdings of third party managed accounts.

Staff must submit to the Compliance Officer an initial holdings report of all securities and private investments at the commencement of employment. The initial report must:

The annual holdings report must be submitted to the Compliance Officer on an annual basis no later than 45 days after the end of calendar year. It should contain the same information as the initial holdings report and must be current within 45 days of the report date.

The Compliance Officer has the responsibility to ensure receipt of all holdings reports. The Compliance Officer reviews such reports to determine that staff trades are consistent with the Firm’s policies and do not otherwise indicate improper trading activities.

In addition to holdings reports, every member of staff must submit a quarterly transaction report to the Compliance Officer. The report must include all securities transactions that were undertaken, including the following information:

Each staff member must submit the quarterly transaction report no later than 30 days after each calendar quarter, regardless of whether the staff member undertook any transactions during the quarter.

The Compliance Officer has the responsibility to ensure the receipt of all quarterly transaction reports submitted. The Compliance Officer reviews such reports to confirm that staff trades are consistent with the Firm’s policies and do not otherwise indicate improper trading activities.

Quarterly transaction reports are not required regarding transactions undertaken:

Any member of staff seeking an exemption from these reporting requirements for a specific account must do so in writing to the Compliance Officer. In the unlikely case an exemption is granted the Compliance Officer reserves the right to periodically request holdings and/or transaction reports for the exempted account.

The Compliance Officer maintains a list of securities that may not be traded by Westbeck or personally by staff (the “Restricted List”). A security may be placed on the Restricted List for a variety of reasons including, but not limited to:

The Compliance Officer is responsible for maintaining the Restricted List and periodically reviewing trading records to confirm that no trading in Restricted List securities has occurred.

Staff should always conduct themselves in such a manner as to avoid the appearance of a potential conflict. Staff should not, directly or indirectly, offer or accept a gift of more than a nominal value from any person or company in relation to their employment with Westbeck. Even gifts of nominal value may raise special concerns for persons associated with pension plan sponsors, including state, municipal and other governmental plans. Any gifts to persons known to be affiliated with such plans must be pre-approved in writing by the Compliance Officer.

A “gift” is anything of value, given or received, where there is no business communication involved in its enjoyment. Examples of gifts include, but are not limited to, tickets to events, lodging and travel expenses, golf clubs, wine, prizes received from raffles or drawings, and perishable items such as food. It may also include other items given in recognition of a life event such as a wedding, anniversary or birthday. The offering or receipt of cash gifts or cash equivalents, such as gift cards, is strictly prohibited.

Gifts should only be offered or accepted when they are clearly reasonable under the relationship’s circumstances. Staff should only accept gifts if there is a true belief that there is no attempt to influence the staff member’s judgment and the gift does not bring feelings of indebtedness or obligation.

Staff are required to obtain approval from the Compliance Officer prior to offering and promptly after receiving any gift that is likely to be valued over the amount of $250. Gifts of any amount offered to or received from a government official or candidate for office, whether domestic or foreign, requires pre-approval from the Compliance Officer. This includes any political contributions. Staff must report to the Compliance Officer any gifts, offered or received, regardless of value.

In addition, Employees must notify the Compliance Officer if they plan to make a charitable contribution to any organization at the request of any existing investor, prospective investor, or other person or entity that does or seeks to do business with or on behalf of the Firm.

Organizing or participating in occasional business entertainment is permitted if the following conditions are met:

If either of these conditions is not met (e.g., a business dinner is followed by a trip to the theater or other entertainment without the host), the activity is considered a gift subject to the standards outlined above.

Entertainment of any amount offered to or received from a government official or candidate for office, whether domestic or foreign, requires pre-approval from the Compliance Officer.

In connection with the advisory services that Westbeck provides to a RIC Client, Westbeck is subject to Section 17(e) of the Investment Company Act, which generally restricts the ability of Westbeck staff to accept any compensation for the purchase or sale of any property to or for a RIC Client. Accordingly, staff may not accept from any source any compensation (including any gifts or business entertainment in any amount) for the purchase or sale of any property to or for a RIC Client.

While Westbeck encourages staff to participate in and provide leadership to community, charitable, and professional activities, prior to engaging in any outside business activity, staff members must obtain written approval from the Compliance Officer. This includes all positions, especially if such activities are appointments as a director, officer, outside employment and/or offer compensation.

Generally, staff may not serve as an executive officer or director or trustee of any business entity with which the Firm conducts business or in whose securities the Firm may invest. Any exceptions will be approved by the Compliance Officer. Staff must disclose to the Firm in writing all benefits, including monetary compensation, that they receive for outside business activities. The Compliance Officer maintains records of all outside business activities and their approval.

It is the Firm’s policy that no member of staff may provide anything of value to a government official or candidate for office, whether domestic or foreign, in the hopes of securing an improper advantage in the furtherance of business relationships or the obtainment of investment advisory contracts. Any staff member found in violation of the Firm’s anti-bribery policy will be subject to disciplinary action, up to and including termination.

The U.S. Foreign Corrupt Practices Act of 1977, as amended ("FCPA"), makes it illegal for members of staff to make payments or provide anything of value to foreign government officials to assist the Firm in obtaining or retaining business. The FCPA applies to any officer or employee of a foreign government and to those acting on the foreign government’s behalf. Thus, the act covers corrupt payments to low-ranking employees and high-level officials alike.

Staff must receive pre-approval from the Compliance Officer prior to providing payment or anything else of value, including gifts and entertainment, to a foreign official.

Rule 206(4)-5 of the Advisers Act (the “pay-to-play rule”) prohibits the Firm from providing advisory services for compensation to a government client for two years after the Firm or its staff contribute to certain elected officials or candidates. This generally includes contributions made by a staff member’s spouse, domestic partner, minor children and any other immediate family members sharing the staff member’s household.

Pay-to-play refers to arrangements by which an investment adviser directs political contributions to a candidate who has the ability, either directly or through appointment, to influence the investment adviser selection process to manage a government account. The SEC prohibits investments advisers from engaging in pay-to-play activities.

Westbeck requires that all political contributions be made in compliance with the pay-to-play rule. This includes contributions to:

Staff must receive pre-clearance from the Compliance Officer prior to making any contribution. Contribution is broadly defined and means anything of value, which includes, but is not limited to payments, gifts, loans, paid participation in fundraisers (e.g. tickets to a dinner), and transition expenses.

The pay-to-play rule requires an investment adviser to look back two years at the political contributions of certain new members of staff. For those who will be involved in the solicitation of clients and investors of the Firm, the look back is two years. For certain other members of staff, not involved in soliciting clients or investors, the look back required by the SEC is a shorter period of six months.

Westbeck has taken the position that upon joining the Firm, all staff will complete a political contributions disclosure form based on the more stringent requirement of two years.

Annually, the Compliance Officer shall review the effectiveness of the Code of Ethics, as well as its implementation and enforcement. At such time, the Compliance Officer shall furnish to the board of trustees of each RIC Client for which Westbeck serves as an investment adviser or investment sub-adviser, if any, a written report for the consideration of the RIC Client's board of trustees that (a) describes any issues arising under the Code of Ethics during the annual period covered by such report, including, but not limited to, information about material violations of the Code of Ethics and sanctions imposed in response to the material violations, and (b) certifies that the Westbeck has adopted procedures reasonably necessary to prevent Access Persons from violating the Code of Ethics.