Exhibit (r)(2)

EXHIBIT C

INTELLIGENCE DRIVEN ADVISERS

CODE OF ETHICS

DATED August 5, 2025

This Code of Ethics (the “Code”) applies to all Access Persons, as defined in Section 1(a) below, of Intelligence Driven Advisers (“IDA” or the “Firm”). This Code supersedes all previous versions of the Firm’s Code.

The Firm and its Access Persons have an ongoing fiduciary responsibility to the Firm’s clients and must ensure that the needs of the clients always come first. The Firm holds its Access Persons to a very high standard of integrity and business practices. In serving its clients, the Firm and its Access Persons must at all times deal with clients in an honest and ethical manner and comply with all the Federal Securities Laws.

While affirming its confidence in the integrity and good faith of its Access Persons, the Firm understands that the knowledge of present or future client portfolio transactions and the power to influence client portfolio transactions, if held by such individuals, places them in a position where their personal interests might become conflicted with the interests of the Firm’s clients. Such conflicts of interest could arise, for example, if securities are bought or sold for personal accounts in a manner that either competes with the purchase or sale of securities for clients results in an advantageous position for the personal accounts.

Because the Firm is a fiduciary to its clients, Access Persons must attempt to avoid actual and potential conflicts of interest with the Firm’s clients. Therefore, in view of the foregoing and in accordance with the provisions of Rule 204A-1 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and Rule 17j-1 under the Investment Company Act of 1940, as amended (the “1940 Act”), the Firm has adopted this Code to outline and prohibit certain types of activities that are deemed to create conflicts of interest (or at least the potential for, or the appearance of, such a conflict) and to outline reporting requirements and enforcement procedures.

In addition, Access Persons must adhere to the following general principles as well as to the Code’s specific provisions:

It is unlawful for any Access Person:

No Access Person may purchase or sell any Covered Securities in their own Personal Accounts, including those for which they have beneficial ownership, with the exception of the exempted transactions listed in section 4(b) below, without written pre-approval by the CCO or designee. All preapproved trades must be completed within 24 hours of when approval is received. The CCO or designee shall be responsible for documenting preapproval trades of the Firm.

Access Persons include all individuals with direct or indirect access to the holdings, trading activity, or investment considerations of IDA, including the IDA Private Access Fund (the “Fund”). Access Persons are subject to pre-clearance, reporting, and trading restrictions under this Code.

Please note: At the discretion of the CCO and in accordance with the Firm’s written policy and procedures regarding aggregated block trades, Access Person transactions may be included in an aggregated block trade for clients, so long as it is in the same direction (i.e., all buys or all sells), for the same security and requested on the same day the aggregated block trade takes place. If block trading is not possible, the access person may not place the personal trade for the same security on the same day as a client.

No Access Person shall divulge or act upon any material, non-public information as such activity is defined and as further detailed in Appendix 2, IDA’s Insider Trading Policies and Procedures, which are incorporated herein. Upon initial execution of this Code and annually thereafter, all Access Persons are required to read the Insider Trading Policies and Procedures and acknowledge via the Firm’s Compliance Portal within 15 days of receipt. See also Appendix 3 for the IDA’s Insider Trading Acknowledgement Form.

The Firm, any solicitor on behalf of the Firm, or any Firm employee that is considered a “Covered Associate” (as defined below) may not make, without first obtaining prior written approval from the CCO, a Political Contribution (as defined below) to any one candidate or official, per election that in the aggregate would exceed $150 if the Covered Associate could not vote for the candidate or official, or $350 if the Covered Associate could vote for the candidate or official. All Firm employees and solicitors must report each political contribution to the CCO using the Firm’s Compliance Portal., within 10 days after the contribution has been made. See also Appendix 4, IDA’s Political Contributions Reporting Form.

In addition, new employees, any promoted employees and any new solicitors that fall within the definition of Covered Associate will be required to report all political contributions they made within the last six months from date of hire, promotion, or engagement, or within the last two years, if their employment or promotion requires the Covered Associate to solicit clients on behalf of the Firm. These reports must include the name of the employee or solicitor, the name of the office holder or candidate that received the contribution, the office the recipient is running for, the amount of the contribution, when the contribution was made, whether or not the contributing employee is eligible to vote for the recipient and whether or not the official or candidate has an existing or potential relationship with the Firm and/or the contributing employee.

Covered Associate of the Firm means:

Political Contribution means any gift, subscription, loan, advance, or deposit of money or anything of value made for:

In accordance with this Rule 204-2, the CCO will maintain the following records on behalf of IDA:

Records relating to contributions and payments will be listed in chronological order and include all information outlined in Rule 204-2 of the Advisers Act.

For transactions in personal brokerage accounts for which the Firm has not timely received⁷ a duplicate statement, the Access person is required to complete and submit IDA’s Quarterly Personal Securities Transaction Report via the Firm’s Compliance Portal, or Appendix 10 within 30 days following quarter-end.

The CCO or designee will review all reports and other information submitted under this Code. All reviews will be documented by the CCO and kept in accordance with record keeping requirements under Section 10 of this Code.

Access Persons are required to immediately report any potential violation or violation of this Code of which he or she becomes aware to the CCO. No Access Person will be sanctioned for reporting a potential violation or violation.

Each Access Person shall receive a copy of the Code annually and anytime the Code is amended. Upon receipt, each Access Person is required to read and acknowledge his or her understanding of the requirements of the Code through the submission of IDA’s Code of Ethics Acknowledgment Form on the Firm’s Compliance Portal, also found at Appendix 12, to the CCO, which in addition provides that the Access Person agrees to abide by the Code. This Acknowledgment must be submitted no later than 30 days from the date of receipt of the Code, including any amendments thereto.

The CCO or designee will assess whether any violation has occurred. If it is determined that a violation has occurred, the CCO may impose such sanctions as he deems appropriate, including, but not limited to suspension of personal trading privileges for a period, disgorging of profits made by the violator, fines and/or dismissal from the Firm.

While facts and circumstances will greatly influence those actions and steps taken by IDA, generally, the CCO will administer the appropriate disciplinary action against the Associated Persons who committed the violation, using the general guidelines outlined below:

The CCO has discretion to waive any of the above guidelines or take additional action depending on the facts and circumstances of the violation.

The following are examples of some of the violations that, if found to have occurred, will be deemed to be instances of misconduct unless there are exceptional mitigating circumstances:

The CCO will document all disciplinary actions taken against any Associated Person(s) and a copy of such documentation will be maintained in the Associated Person’s personnel file. The documentation will include the nature of the cause for the disciplinary action, the specific fines or penalties imposed, the response of the Associated Person disciplined, and any and all corrective actions taken by IDA. In addition, IDA encourages all Associated Persons to immediately notify the CCO whenever he/she believes there may have been a violation of the Firm’s Code.

The CCO may grant written exceptions to the provisions of the Code based on equitable considerations (e.g., rapid markets, hardship, satisfaction of a court order, etc.). The exceptions may be granted to individuals or classes of individuals with respect to particular transactions, classes of transactions or all transactions, and may apply to past as well as future transactions, provided that no exception will be granted where the exceptions would result in a violation of Rule 204A-1 of the Advisers Act or any other Federal Securities Law.

The CCO or designee will be responsible for maintaining the following records pertaining to the Code for a minimum of five years from the end of the fiscal year in which the information was obtained and/or in effect, the first two years onsite in an accessible place, with the exception of 10(c) below, which will be kept for five years after the individual ceases to be deemed an Access Person:

Any Access Person having questions relating to the Code should contact the CCO.

INTELLIGENCE DRIVEN ADVISERS

EXAMPLES OF BENEFICIAL OWNERSHIP

INTELLIGENCE DRIVEN ADVISERS

INSIDER TRADING POLICIES AND PROCEDURES

The Insider Trading and Securities Fraud Enforcement Act of 1988 (“1988 Act”) further extends the safeguards of the Securities Exchange Act of 1934 as it pertains to “insider trading.” The purpose of this Insider Trading Policies and Procedures is to comply with the 1988 Act and the Advisers Act. In addition, the policies and procedures herein are designed to provide a program for educating, detecting and preventing insider trading by Supervised Persons of the Firm.

“Insider” is a person with access to material key information about a publicly traded company before it is announced to the public. Typically, the term refers to corporate officers, directors and key personnel, but may be extended to include family members, relatives and/or others in a position to capitalize on insider information. Additionally, persons may be characterized as “temporary” or “constructive” insiders if they have access to material non-public information for a legitimate purpose in the context of performing a service for a particular company. Examples include, but are not limited to accountants, attorneys, IT service providers, and even printers who print financial information.

“Insider Information” describes material non-public information regarding corporate events that have not yet been made public. For example, the officers of a firm know in advance if the company is about to be acquired or if the latest earning report is going to differ significantly from information previously released. If information reasonably influences the purchase, sale or market value of a company’s securities and such information has not yet been publicized in a widely used medium, then it is considered insider information.

“Misappropriation” usually occurs when a person acquires inside information about one company in violation of a duty owed to another company. For example, if an employee of ABC Public Company has knowledge that XYZ Public Company is negotiating a merger with ABC Company, that employee has material nonpublic information about both companies and must not trade in such companies’ stocks or pass on the information to anyone that does not already know.

“Tipping” is passing along inside information to others. A tip occurs when an insider (the “tipper”) discloses inside information to another person (the “recipient”), which causes the recipient to become an insider and therefore subject to a duty not to trade or pass along the information while in possession of that information. The act of tipping violates the 1988 Act and both the tipper and the recipient may be subject to liability for insider trading regardless of whether a benefit was derived from the action.

Penalties for trading on or communicating material, nonpublic information are severe, both for the individuals involved in the unlawful conduct and for the employers. A person can be subject to some or all of the penalties set forth below even if he or he does not personally benefit from the violation. Penalties may include:

IDA and its Associated Persons are prohibited from acting upon material non-public information, which includes tipping.

There may be times that an Associated Person receives insider information during the ordinary course of employment with the Firm and regardless if the receipt of such information is advertent or inadvertent, that person will be deemed an “insider”. This may occur under a variety of circumstances, including but not limited to the following:

Example 1: An IDA client may be an officer or director of a publicly traded company that is undergoing material structural changes and discloses these changes to an Associated Person.

Example 2: An Associated Person inadvertently receives insider information during a research call with a public company, an expert network consultant, a broker-dealer, an investment manager, or others with such information.

Example 3: An Associated Person receives non-public information regarding a tender offer.

If an Associated Person is unsure or suspects that he/he may have obtained or may be perceived to have obtained insider information, they should notify the CCO immediately.

Prohibited activity while in receipt of material non-public information includes but is not limited to the following activities:

To help avoid possible violations, senior management of IDA will exercise great care, in accordance with the procedures outlined below, in the supervision of Associated Persons and of the securities transactions of their personnel. If there is any question as to whether a contemplated purchase or sale would violate the insider trading rules, Associated Persons must consult with the CCO prior to effecting the transaction.

Use of Expert Networks Providing Research

Expert networks are defined as “A group of professionals who are paid by outsiders for their specialized information and research services.” Associated Persons must notify the CCO prior to engaging/contracting with an expert network firm to provide specialized research. The CCO or designee will perform and document a due diligence review of the expert network firm, including a review of the controls in place at the firm regarding insider trading and for ensuring that material non-public information is not passed on to their clients. This review shall be conducted prior to engagement and at least annually thereafter. Additionally, all contracts entered into with the expert network firm must contain a certification by the expert network firm that they will not at any time provide material non-public information to or any of the firm’s Associated Persons.

If the Firm becomes aware or suspects that MNPI may have been shared during an interaction with an expert network:

Contacts with Public Traded Companies

Any Associated Person that has contact with an employee, director, officer, or majority shareholder of any publicly traded company to obtain research information or to discuss matters that relate to any investment advisory account of IDA, the Associated Person will:

Clients Who Are Officers of Public Companies

From time to time, IDA may have clients who are majority shareholders, directors, officers, or employees of publicly traded companies. When this occurs, the IAR assigned to such client(s) is responsible for immediately notifying the CCO, who will determine whether that security should be added to the Firm’s Restricted Securities List.

Restricted Securities List

A security will be placed on the firm’s Restricted Securities List, when it has been determined that the firm may have inside information pertaining to the security, or the security should not be traded by the firm or employees for other reasons determined by senior management (“Restricted Security”). When a security is placed on the Restricted Security List, Associated Persons are prohibited from purchasing or selling such Restricted Security in any Access Person Account or on behalf of any client account during the time period the security is included on the List. The CCO shall be responsible for maintaining the Firm’s Restricted Securities List and will ensure that all Associated Persons are notified of the securities listed on the Restricted Securities List, along with changes that are made from time to time.

Notification of Receipt of Material Non-Public Information

Any Associated Person who becomes aware of material, non-public information, or becomes aware of any Associated Person that may have or has obtained such information should immediately advise the CCO. Associated Persons are prohibited from discussing such with any other firm personnel.

Ongoing Responsibility of all IDA Associated Persons

All Associated Persons must make an ongoing diligent effort to ensure that a violation of these Insider Trading Policies and Procedures does not occur. This requires all Associated Persons to:

Associated Persons will be provided a copy of this Insider Trading Policies and Procedures initially upon hire, annually, and anytime an amendment is made, and must execute acknowledgments as outlined in Item 4 above. IDA also provides periodic educational training with respect to the prohibitions of insider trading, and the Firm’s Insider Trading Policies and Procedures, which will be delivered in different ways that may include attendance to seminars, meetings, and/or webinars, and providing written materials for review.

Any potential violation of IDA’s Insider Trading Policies and Procedures will result in an internal review and could result in immediate sanctions (including those outlined in Item 2 above), and termination of employment for all Associated Person(s) involved. No Associated Person will be sanctioned for the reporting of any potential or actual violation of the Firm’s Insider Trading Policies and Procedures

INTELLIGENCE DRIVEN ADVISERS

INSIDER TRADING POLICIES AND PROCEDURES

ACKNOWLEDGEMENT FORM AND CERTIFICATE OF COMPLIANCE

INTELLIGENCE DRIVEN ADVISERS

POLITICAL CONTRIBUTIONS PRE-APPROVAL & REPORTING FORM

Section I: Contribution Information

Please complete the following:

Does the recipient have an existing or potential business relationship with the Firm and/or the contributor? (Please check one) ☐ Yes   ☐ No

If yes, please describe the relationship:

Is the contributor eligible to vote for recipient? (Please check one) ☐ Yes   ☐ No

Section II: Certification of Contributor

By signing below, I certify to the following:

For Compliance Use Only:

Permission from Compliance has been ☐ Granted ☐ Denied for this Employee/Associated Person to transact in the security as outlined above.

ACKNOWLEDGEMENT: By my signature above, I hereby certify that all information provided above is true and correct.

For Compliance Use Only:

Permission from Compliance has been ☐ Granted ☐ Denied for this Employee/Access Person to give/receive the gift(s) as outlined above.

ACKNOWLEDGEMENT: By my signature above, I hereby certify that all information provided above is true and correct.

For Compliance Use Only:

Permission from Compliance has been ☐ Granted ☐ Denied for this Employee/Access Person to give/receive the gift(s) as outlined above.

INTELLIGENCE DRIVEN ADVISERS

OUTSIDE BUSINESS ACTIVITY APPROVAL FORM

Instructions: Please check all that apply:

ACKNOWLEDGEMENT: I hereby certify that all information provided above is true and correct.

For Compliance Use Only:

Permission from Compliance has been ☐ Granted ☐ Denied for this Employee/Access Person to engage in the Outside Business Activity as outlined above.

INTELLIGENCE DRIVEN ADVISERS

OUTSIDE BROKERAGE ACCOUNTS REPORTING FORM

Instructions: Please provide the following information for each securities account you hold at an institution outside of Intelligence Driven Advisers. (“IDA” or the “Firm”). If you have no such accounts outside of the Firm, mark the appropriate box below, print your name and return the form as instructed. IDA will send a letter of authorization to each custodian permitting the account to be maintained and requesting that copies of duplicate statements be provided to the Firm. Any questions should be directed to the CCO. If you have more than three outside brokerage accounts to report, please use additional forms.

ACKNOWLEDGEMENT: By my signature above, I hereby certify that all information provided above is true and correct.

For Compliance Use Only:

Permission from Compliance has been ☐ Granted ☐ Denied for this Employee/Access Person to give/receive the gift(s) as outlined above.

ACKNOWLEDGEMENT: By my signature above, I hereby certify that all information provided above is true and correct.

For Compliance Use Only:

Permission from Compliance has been ☐ Granted ☐ Denied for this Employee/Access Person to give/receive the gift(s) as outlined above.

INTELLIGENCE DRIVEN ADVISERS

INITIAL/ANNUAL HOLDINGS REPORT

Holdings Declaration

In compliance with SEC guidelines and recommendations, once annually, Intelligence Driven Advisers (“IDA” or the “Firm”) mandates each Access Person to complete this declaration of personal securities holdings within 30 days of receipt. The Access Person must declare: (1) all personal securities holdings owned by the Access Person as of the date of this declaration, including securities in accounts where the Access Person is listed as a joint owner, beneficiary or has control over the account (such as a trustee), and (2) securities owned by the Access Person’s immediate family members living in the same household.

As of the __ day of ____________________ 20 ___, I, ______________________________, declare that the following is a complete list of the securities held by me, including all securities in accounts where I am a beneficiary and/or exercise control, and my immediate family members that live in my household as of the end of calendar year ______.

In lieu of listing each security, I am attaching a copy of each account statement, which lists the securities I am required to declare and includes all required information about each security as outlined in the Firm’s Code of Ethics.

Brokerage accounts:

Partnerships:

Securities Not Held in Any Account:

ADDENDUM

TYPES OF SECURITIES FOR INCLUSION

ON ANNUAL HOLDINGS DECLARATION

College Savings Programs

If the program does not invest in any type of security and is not held at a brokerage firm, it does not need to be reported.

Foundations

If the employee owns/created the foundation, it should be reported as an outside business activity, but not a security holding. Donations to foundations or charities do not need to be reported. An employee should not donate to a foundation or charity in exchange for receiving business from the foundation or charity.

Private Partnerships

Private partnerships and private funds (hedge funds, private equity, etc.) need to be reported.

Real Estate

Ownership in real property does not need to be reported. Investments in REITs or private placements/funds that invest in real estate do need to be reported.

Annuities/Insurance Programs

The product needs to be reported only if it invests in securities.

401Ks

The holdings do not need to be reported if the 401K only invests in unaffiliated third party open end mutual funds. If the 401K invests in any other type of security that is not considered “exempt”, then the holdings need to be reported.

IRAs

IRAs need to be reported if the account holds any type of reportable security.

INTELLIGENCE DRIVEN ADVISERS

CODE ACKNOWLEDGEMENT FORM AND

CERTIFICATE OF COMPLIANCE

Intelligence Driven Advisers’ (“IDA” or the “Firm”) Code of Ethics (“Code”) dated October 18, 2018 has been provided to me for my review.