Tidal Trust III 485BPOS

Exhibit 99(p)(xxi)

04/01/2025 

CODE OF ETHICS

August 2025

Contents

Introduction

Introduction

As an investment adviser, Hohimer Wealth Management (“HWM” or “the Firm”), stands in a position of trust and confidence with respect to our clients. Accordingly, we have a fiduciary duty to place the interests of our clients before the interests of HWM and our Supervised Persons. [See Definition of Supervised Persons]

HWM expects each of its Supervised Persons to conduct themselves with integrity, honesty and professionalism. To provide general guidance to Supervised Persons, HWM requires each employee, officer and representative to comply with the principles and standards of conduct contained in this Code of Ethics (“Code”),¹ as revised from time to time. This Code supersedes any prior Codes or policies but should be read in conjunction with the firm’s Policies and Procedures Manual. Any violation of this Code of Ethics by any employee may result in disciplinary action, up to and including discharge.

Furthermore, Supervised Persons must at all times uphold their professional and ethical responsibilities, refraining from any behavior, whether professional or personal, that could tarnish the name and reputation of the Firm. This includes, but is not limited to, maintaining appropriate legal conduct outside of work hours.

Each Supervised Person is responsible for reading, understanding and consenting to comply with the policies contained in this document. This Code will be reviewed on a periodic basis (at least annually) and any significant changes to either regulatory or firm policies will result in the distribution of updates to the Code. Each employee must retain a copy of this Code. This document is the exclusive property of HWM and must be returned should your association with HWM terminate for any reason.

A written Code cannot answer all questions raised in the context of business relationships and the provisions of the

Code are not all-inclusive. The provisions of this Code are intended to serve as a guide for Supervised Persons of HWM in their conduct. Thus, each Supervised Person is required to recognize and respond appropriately to specific situations as they arise. In those situations where a Supervised Person may be uncertain as to the intent or purpose of the Code, he or she is advised to consult with the Chief Compliance Officer, who may grant exceptions to certain provisions contained in the Code only in those situations when it is clear beyond dispute that the interests of our clients will not be adversely affected or compromised. All questions arising in connection with personal securities trading should be resolved in favor of the client even at the expense of the interests of Supervised Persons.

Each Supervised Person must complete the Code of Ethics attestation upon hire and on an annual basis..

Standards of Conduct and Fiduciary Duty

Standards of Conduct and Fiduciary Duty

This Code of Ethics is based on the principle that you, as a Access Person/Supervised Person of HWM, owe a fiduciary duty to Advisory Clients for which HWM serves as an adviser. All employees of HWM are classified as Access Persons. Accordingly, you must avoid activities, interests and relationships that might interfere or appear to interfere with making decisions in the best interests of our Advisory Clients.

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1 . HWM RESERVES THE RIGHT TO AMEND OR OTHERWISE REVISE THIS CODE OF ETHICS AT ANY TIME AND WITHOUT PRIOR NOTICE. HWM WILL ENDEAVOR TO NOTIFY ITS SUPERVISED PERSONS PROMPTLY OF ANY CHANGE HERETO.

This Code is intended to comply with the various provisions of the Investment Advisers Act of 1940 and requires that all Supervised Persons comply with federal securities laws, including the Investment Advisers Act of 1940, as amended and applicable rules and regulations adopted by the Securities and Exchange Commission (SEC”).

Pursuant to Section 206 of the Advisers Act, both HWM and its Supervised Persons are prohibited from engaging in fraudulent, deceptive or manipulative conduct. Compliance with this section involves more than acting with honesty and good faith alone. It means that HWM has an affirmative duty of utmost good faith to act solely in the best interests of our Advisory Clients.

At all times, you must:

1.         Place the interests of our Advisory Clients first. In other words, as a fiduciary you must scrupulously avoid serving your own personal interests ahead of the interests of our Advisory Clients. You may not cause an Advisory Client to take action, or not to take action, for your personal benefit rather than the benefit of the Advisory Client.

2.         Duty of loyalty to clients. HWM and its Supervised Persons owe a duty of loyalty to Advisory Clients and to always act in utmost good faith, place our clients’ interests first and foremost and to make full and fair disclosure of all material facts including conflicts of interest and to never make misleading statements. Our firm also has a duty to ensure that investment advice is suitable to meeting each client’s individual and unique goals and objectives, needs and circumstances.

3.         Report any criminal charges filed against you (felony or misdemeanor) to the Chief Compliance Officer (CCO) within 48 hours of being charged. This includes, but is not limited to, arrests, indictments, and convictions. Failure to report such charges within the specified timeframe may result in severe disciplinary action, up to and including immediate termination of employment and referral to regulatory authorities.

4.         Conduct all of your personal securities transactions in full compliance with this Code. You must not take any action in connection with your personal investments that could cause even the appearance of unfairness or impropriety. Accordingly, you must comply with the policies and procedures set forth in this Code. Doubtful situations should be resolved against your personal trading.

5.         Accept no more than reasonable compensation. HWM believes that fees for its services should be reasonable and commensurate with the level of service provided. Fee structures are available for reference in the HWM’s ADV 2A.

6.         Avoid taking inappropriate advantage of your position. The receipt of investment opportunities, gifts or gratuities from persons seeking business with HWM directly or on behalf of an Advisory Client could call into question the independence of your business judgment. Accordingly, you must comply with the policies and procedures set forth in this Code. Doubtful situations should be resolved against your personal interests.

7.         Investing is a good practice. HWM believes that personal investing which is consistent with HWM’s investment philosophy does not interfere with clients’ services and interests, and accordingly, encourages personal investing. On the other hand, HWM believes that short-term trading is inconsistent with HWM’s investment philosophy, which emphasizes an investment rather than a trading approach to the achievement of favorable investment results.

This Code is adopted pursuant to the requirements of Rule 204A-1 under the Investment Advisers Act of 1940 applicable to all registered investment advisers, and Section 204A of the Investment Advisers Act of 1940 that registered investment advisers adopt procedures reasonably designed to prevent the misuse of material, nonpublic information.

Gifts and Business Entertainment

Gifts and Business Entertainment

HWM reputation is built on the highest standards of professional conduct. As such, all Supervised Persons are required to maintain an unwavering commitment to ethical behavior, especially in matters of business courtesies. When giving or accepting gifts and/or business entertainment, employees must exercise due diligence and sound judgment. It is important that employees fully comprehend what constitutes an appropriate gift or entertainment and to operate strictly within those confines. This vigilance is not merely a matter of personal integrity; it is essential to protecting the reputation and goodwill of the firm.

If Supervised Persons are offered gifts, gratuities, or other favors, they should simply ask themselves three questions:

By refusing inappropriate inducements of any kind, Supervised Persons will be preserving assets of far greater value: their good name, the reputation of HWM, and our clients’ financial welfare.

Supervised Persons may not accept any gift, gratuity, or other thing of more than nominal value (greater than $300), from any person or entity that does business, or desires to do business, with HWM directly or on behalf of an Advisory Client. You may accept gifts from a single giver so long as the aggregate annual value does not exceed $300. You also may attend business meals, sporting events and other entertainment events at the expense of a giver (or at your expense for another), so long as the expense is reasonable, both you and the giver are present, and the events are not excessively frequent. The acceptance of tickets to any event where the giver or you does not attend is considered a gift subject to the $300 annual limit rather than a business meal or other entertainment event. Examples of events that may be considered an unreasonable expense would be World Series or Super Bowl tickets, and vacation trips. You shall not give any gift, gratuity or other thing, or provide business entertainment, which would be construed as unreasonable in value with the intent or purpose of influencing a third party’s business relationship with HWM.

You further may not accept any gift or business entertainment of more than $10 from any person in relation to qualified ERISA plans. This does not include simplified employee pension plans (SEPs), SIMPLE retirement accounts, and IRAs, or to employee welfare benefit plans. The provisions of Title I of ERISA cover most private sector employee benefit plans. Such plans are voluntarily established and maintained by an employer, an employee organization, or jointly by one or more such employers and an employee organization. Exceptions to the gift limit may be made by the Chief Compliance Officer. Supervised Persons should request exceptions for personal circumstances in which the employee has a personal relationship with a third party (such as receiving or providing personal gifts as wedding gifts, or gifts for the birth of a child).

Supervised Persons are prohibited from giving or providing any gift, including a personal gift, to any official of a Public Fund without the express prior approval of the Chief Compliance Officer.

Gifts & Entertainment Reporting

All gifts, business meals, sporting events and other entertainment events of which you are the recipient or giver must be reported to the Chief Compliance Officer or Gaye Ott via email if the value is reasonably judged to exceed $100. Reporting must include the name(s) of the giver/receiver, the date, the organization of the giver/receiver, a description of the gift or event, and the value or estimated value of the gift or event.

Insider Trading

Insider Trading

These procedures are intended to prevent the use of material, nonpublic information by Supervised Persons and to prevent, detect and correct any violations of the prohibition on insider trading. HWM strictly prohibits trading while in possession of material, nonpublic information, tipping of nonpublic information, and scalping by all Supervised Persons for their personal accounts or for Advisory Clients.

1. Overview

Insider trading is based on a simple, well-established principle: if you receive material, nonpublic information about a public company from any source, you are prohibited from discussing or acting on that information.

Under the Advisers Act, the SEC may sue any person (or any person who controls or supervises such person) who trades while in possession of “material, nonpublic information” or who communicates or “tips” such information. Trading the securities of any company while in possession of material, nonpublic information about that company is generally prohibited by the securities laws of the United States and firm policy.

Under insider trading laws, a person or company that illegally trades in securities of a company while in possession of material, nonpublic information about that company may be subject to severe sanctions, including civil penalties, fines and imprisonment.

The rules contained in this Code apply to securities trading and information handled by Supervised Persons of HWM. The law of insider trading is complicated and continuously developing. Individuals may be uncertain about the application of insider trading rules in some circumstances and any questions about insider trading rules should be addressed with the Chief Compliance Officer. You must notify the Chief Compliance Officer immediately if you have any reason to believe that insider trading has occurred or is about to occur.

2. Policy on Insider Trading

No person to whom these procedures apply may trade, either personally or on behalf of others (such as Advisory Client accounts managed by HWM), while in possession of material, nonpublic information, nor may any Supervised Person communicate material, nonpublic information to others in violation of the law.

A. Who is an Insider?

Corporate insiders who possess material, nonpublic information about a corporation may be required either to disclose that information to the investing public or to refrain from passing such information along to others, trading in or recommending the purchase or sale of the corporation’s securities. Similarly, as a general rule, those to whom corporate insiders “tip” material, nonpublic information must refrain from passing such information along to others, trading in or recommending the corporation’s securities. In addition, under most circumstances, tipping or trading on material, nonpublic information about a tender offer may violate the rules of the SEC. Tipping may include spreading rumors about potential tender offers. For example, personnel may not pass along a rumor regarding a tender offer to those who are likely to trade on the information or further spread the rumor if the rumor emanated, directly or indirectly, from someone connected with the target, the offeror, or their respective officers, directors, partners, employees, or persons acting on their behalf, even if such information was inadvertently communicated

B. What is Material Information?

The question of whether information is material is not always easily resolved. Generally, the courts have held that a fact is material if there is substantial likelihood that a reasonable investor would consider the information “important” in making an investment decision. As such, material information would include information which would likely affect the market price of any securities, or which would likely be considered important by a reasonable investor in determining whether to buy, sell or hold such securities.

Examples of material information may include the following:

Material information also may relate to the market for a company’s securities. Information about a significant order to purchase or sell securities may, in some contexts, be material. Prepublication information regarding reports in the financial press also may be material. For example, the United States Supreme Court upheld the criminal convictions of insider trading defendants who capitalized on prepublication information about The Wall Street Journal’s “Heard on the Street” column.

You should also be aware of the SEC’s position that the term “material, nonpublic information” relates not only to issuers but also to HWM’s securities recommendations and client securities holdings and transactions.

C. What is Nonpublic Information?

Information is “nonpublic” if it has not been disclosed generally to the investing public. Information is made public if it has been broadly disseminated and made available to the public by publication in the newspapers or other media or if it has been the subject of a press release addressing the general investing public. However, information is not necessarily made public merely because such information is communicated through rumors or other unofficial statements in the marketplace.

D. Identifying Inside Information

Before executing any trade for yourself or others, including private accounts managed by HWM, you must determine whether you have access to material, nonpublic information. If you think that you might have access to material, nonpublic information, you should take the following steps:

You should consult with the Chief Compliance Officer before taking any action or engaging in any transaction which inside information may have been provided. This degree of caution will protect you, our clients, and the firm.

The Chief Compliance Officer shall use the following reviews and procedures to detect any possible trading on inside information:

Confidential Information

Confidential Information

1. General

In the course of investment advisory activities at HWM, the firm gains access to nonpublic information about its clients. Such information may include the status as a client, personal financial and account information, the allocation of assets in a client portfolio, the composition of investments in any client portfolio, information relating to services performed for or transactions entered into on behalf of clients, advice provided by HWM to clients, and data or analyses derived from such nonpublic personal information (collectively referred to as “Confidential Client Information¨). All Confidential Client Information, whether relating to HWM’s current or former clients, is subject to HWM’s policies and procedures. Any doubts about the confidentiality of information must be resolved in favor of confidentiality.

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All Supervised Persons must safeguard confidential information about clients, potential clients, and their accounts (including profit data, credit information, financial condition, and business transactions). In particular:

2. HWM Proprietary Information

HWM provides its Supervised Persons with access to its physical resources, electronic media and proprietary information, as well as technology developed or used by HWM. Supervised Persons are responsible for the proper use of HWM’s physical resources, electronic media, proprietary information, and technology. Accordingly, Supervised Persons may not disseminate, sell or otherwise use HWM’s physical resources, electronic media, proprietary information or technology for their personal benefit or for the benefit of a third party. This restriction continues to apply after employment terminates, regardless of the reason for termination. HWM’s resources and electronic media may be used only for those activities that are directly related to HWM’s business or that has been approved in advance.

Supervised Persons should be aware that any product, program, or writing developed or produced by HWM’s Supervised Persons during job time, by using HWM’s facilities, or as a result of performing their job responsibilities, is the property of HWM.

Supervised Persons should take appropriate steps to protect all of HWM’s proprietary interests, both while employed by HWM and after employment with HWM. Further, copying any records for any purpose other than a necessary job-related activity is strictly prohibited. No HWM records, information, or copies thereof may be retained by an employee following termination of employment.

3. Third Party Proprietary Information

Supervised Persons are responsible for using the patented, copyrighted, or other proprietary material or information (including software) of a third party in compliance with applicable provisions of any contract between HWM and the third party. HWM, as well as individual Supervised Persons, may be held liable for both civil damages and criminal penalties for copyright, trademark, or patent infringement and for any other illegal or improper use of another’s property. Supervised Persons should also be aware that other uses of third-party materials or information, such as the duplication of computer software and the downloading of data from information retrieval services (databases), may also require the owner’s permission. Thus, Supervised Persons may not use HWM’s technology resources to copy, retrieve, forward or send copyrighted materials unless the employee has the author’s permission. Supervised Persons are encouraged to consult their immediate supervisors or the Chief Compliance Officer regarding the photocopying, duplication, reproduction, data downloading, or other use of proprietary material or information owned by a third party.

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4. Security of Confidential Personal Information

HWM enforces the following policies and procedures to protect the security of Confidential Client Information:

Service on Boards of Directors and Other Outside Activities

Service on Boards of Directors and Other Outside Activities

Current information regarding our Supervised Persons is crucial to HWM’s overall supervisory effort. To help maintain current information and ensure awareness of all information regarding Supervised Persons, HWM requires each employee to disclose to HWM (and maintain current) the following information:

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Personal Securities Trading

Personal Securities Trading

1. Trading in General

Each Supervised Person is expected to devote his or her workdays to serving the interests of clients and HWM. All Supervised Persons are required to follow reporting procedures below and shall disclose to HWM information on any Beneficial Ownership of Reportable Securities [See Definitions Section] or other investments that may have an effect on the ability to make unbiased and objective recommendations.

Maintenance of Personal Brokerage Accounts

Supervised Persons shall be required to maintain their personal brokerage/custodian accounts at First Clearing.

However, HWM may permit Supervised Persons to maintained certain accounts in which they have Beneficial Ownership of elsewhere, such as pension plan accounts and 529 plans. Supervised Persons are required to seek permission from the CCO for any account not maintained at the designated broker. The CCO will be required to seek exception to this policy from the Managing Member of HWM.

2. Beneficial Ownership

To determine whether a person has “Beneficial Ownership,” Supervised Persons are considered to have Beneficial Ownership of Securities if such Supervised Person, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise have or share a direct or indirect “pecuniary interest” in such Securities.

A Supervised Person has a pecuniary interest in the Securities if such Supervised Person has the opportunity, directly or indirectly, to profit or share in any profit derived from a transaction in the Securities.

The following are examples of an indirect pecuniary interest in Securities:

Supervised Persons do not have an indirect pecuniary interest in the portfolio Securities held by a corporation or similar entity in which you own securities if such Supervised Person is not a controlling shareholder of the entity and do not have or share investment control over the entity’s portfolio.

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The following circumstances constitute Beneficial Ownership of Securities held by a trust by a Supervised Person:

3. Employee Trading

Every Supervised Person shall provide initial and annual holdings reports and quarterly transaction reports to the Chief Compliance Officer, which must contain the information described below. In lieu of providing quarterly transaction reports with personal securities transaction information to the Chief Compliance Officer, Supervised Persons are encouraged to arrange for their brokerage firm(s) to send automatic duplicate brokerage account statements to the Chief Compliance Officer, or to maintain their accounts with a brokerage firm with which HWM may have access to Supervised Persons’ personal account information.

A. Initial & Annual Holdings Reports

If you are a new Supervised Person, you must report no later than ten (10) days after you become a Supervised Person to the Chief Compliance Officer the following information:

i. the title and type of security, ticker symbol or CUSIP number as appropriate, number of shares and principal amount of each Security in which the Supervised Person had any direct or indirect Beneficial 

Ownership when the person became a Supervised Person; ii. the name of any broker, dealer or bank with whom the Supervised Person maintained an account in which any Securities were held for the direct or indirect benefit of the Supervised Person as of the date the person became a Supervised Person*; and 

iii. the date that the report is submitted.

* Note the report requires disclosure of the name of any broker-dealer or bank with which the Supervised Person has an account in which any Securities are held for his or her direct or indirect benefit.

Each Supervised Person must submit annually thereafter a holdings report setting forth the above-specified information which must be current as of a date no more than forty-five (45) days before the report is submitted. The form used to report initial and annual personal holdings is set forth in the Appendix to this Code or provided electronically via a compliance platform.

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B. Quarterly Transaction Reports

Every Supervised Person must report to the Chief Compliance Officer no later than thirty (30) days after the end of the calendar quarter, the following information:

i. With respect to any transaction during the quarter in a Reportable Security in which the Supervised Person had any direct or indirect Beneficial Ownership:

The foregoing Item ii includes reporting securities acquired through a gift or inheritance. ii. With respect to any account established by the Supervised Person in which any Reportable Securities were held during the quarter for the direct or indirect benefit of the Supervised Person:

iii. If a Supervised Person instructs all broker-dealers, who hold Reportable Securities in which such Supervised Person has beneficial ownership, to provide duplicate account statements required under the above section to the Chief Compliance Officer within the time period required for a Quarterly Transaction Report (i.e., within 30 days after the end of the applicable calendar quarter) and provides the information required in part b. above, then such Supervised Person need only represent on the Quarterly Transaction Report:

It is the obligation of each Supervised Person relying on part iii to ensure compliance with its requirements.

Exception to Reporting Requirements:

A person need not make a report to the Chief Compliance Officer under the Reporting Section above with respect to transactions effected for, and Reportable Securities held in, any account over which the person has no direct or indirect influence or control. (For example, if Supervised Person makes an affirmative demonstration that control has been delegated to an independent third party, or that Supervised Person’s ownership involves a blind trust.)

A person need not make a transaction report to the Chief Compliance Officer under the Quarterly Transaction Reports section above with respect to transactions effected pursuant to an automatic investment plan.

C. Employee Trades and Client Conflicts

Supervised persons including employees, partners, and affiliates who would like to transact in securities held in client accounts must not do anything that conflicts with their fiduciary duty to HWM’s clients and the firm. The following policies are applicable:

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C. Pre-Clearance Required for Participation in IPOs and Private or Limited Offerings

No Supervised Person shall acquire any beneficial ownership in any securities in an Initial Public Offering or any securities in a limited offering or private placement for his or her account without the prior written approval of the Chief Compliance Officer who has been provided with full details of the proposed transaction (including written certification that the investment opportunity did not arise by virtue of the Supervised person’s activities on behalf of a client) and, if approved, will be subject to continuous monitoring for possible future conflicts.

Reporting Violations & Remedial Actions

Reporting Violations & Remedial Actions 

All supervised persons shall promptly report to their supervisor, the Chief Compliance Officer or a Member of Senior Management all apparent violations of the Code. Supervisors and other Members of Senior Management shall immediately report possible material violations of the Code to the Chief Compliance Officer. The Chief Compliance Officer shall promptly report to Senior Management all material violations of the Code. In instances where the Chief Compliance Officer finds that a violation could not reasonably found to have resulted in a fraud, deceit or a manipulative practice in violation of Section 208 of the Advisers Act, he or she shall submit a written memorandum of the event in lieu of reporting to senior management.

It is every Supervised Person’s obligation to promptly report to their supervisor, the Chief Compliance Officer or a member of Senior Management if the Supervised Person possesses a reasonable belief that there is a possible violation of the Firm’s Code of Ethics, the Firm’s Compliance Policies & Procedures or a securities law violation that has occurred, is ongoing or is about to occur. The Firm will not permit any form of intimidation or retaliation against any Supervised Person who possess a reasonable belief that the information being provided relates to a possible violation. All appropriate reports will be treated confidentially and investigated promptly and appropriately. Senior Management shall consider reports made to it hereunder and shall determine whether or not the Code has been violated and what sanctions, if any, should be imposed.

If you violate this Code, you are subject to remedial actions, which may include, but are not limited to, a letter of reprimand, disgorgement of profits, imposition of a substantial fine, demotion, suspension or termination.

Misleading and false responses or refusal to complete compliance duties in Orion Compliance will be recorded as a violation of the Code of Ethics.

All violations of the Code and remedial actions will be recorded and maintained for a minimum of 5 years.

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Conflicts of Interest. Examples.

A conflict of interest arises when an advisor’s personal interests, or the interests of The Firm, could potentially interfere with their duty to act in the best interests of their clients.

Essentially, it’s a situation where an advisor’s judgment or actions might be swayed by factors other than what’s best for the client.

Compensation-Related Conflicts:

2. Client Relationship Conflicts:

3. Trading and Investment Conflicts:

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4. Gifts and Entertainment:

5. Outside Business Activities:

6. Conflicts Regarding Fiduciary Duty:

Artificial Intelligence Use – A.I Usage

This policy outlines the ethical and responsible use of artificial intelligence (AI) tools and technologies by Hohimer Wealth Management and its supervised persons in the provision of wealth management services. It aims to ensure that AI is used in a manner consistent with our fiduciary duty to clients, regulatory requirements, and the firm’s Code of Ethics.

Guiding Principles:

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Specific Requirements:

This policy may be amended from time to time as needed to reflect changes in technology, regulations, or the firm’s business practices.

By using AI tools and technologies in connection with their work at Hohimer Wealth Management, Supervised Persons acknowledge that they have read, understood, and agree to comply with this policy.

Marketing / Advertising –

Definition of Advertisement:

Supervised Persons must understand the broad definition of “advertisement” under the Marketing Rule, which includes any communication that refers, directly or indirectly, to the firm or its advisory services.

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General Principles:

All marketing and advertising materials must first be approved by Compliance, and must adhere to the following principles:

Specific Requirements:

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By engaging in marketing or advertising activities on behalf of Hohimer Wealth Management, Supervised Persons acknowledge that they have read, understood, and agree to comply with this policy.

Off–Channel Communications

This policy applies to all supervised persons, including employees, contractors, and agents, who use unapproved communication methods for business-related purposes. This includes, but is not limited to:

Definitions:

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Policy Statement:

All business-related communications must be conducted through the firm’s approved communication systems. Off-channel communications are strictly prohibited unless explicitly authorized by the Chief Compliance Officer (CCO) in writing for specific, documented reasons.

Specific Requirements:

Exceptions:

Consequences of Non-Compliance:

Violations of this policy may result in disciplinary action, including but not limited to:

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Interpretations and Exceptions

Interpretations and Exceptions

Any questions regarding the applicability, meaning or administration of this Code shall be referred by the person concerned in advance of any contemplated transaction to the Chief Compliance Officer. Exemptions may be granted by such person, if, in his or her judgment, the fundamental obligation of the person involved is not compromised. The Chief Compliance Officer shall request exemptions from an appropriate control person of HWM. The Chief Compliance Officer’s personal securities transactions, outside business activities and any other reportable events shall be reported to an appropriate management person.

Definitions

Definitions

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² . If HWM or a Supervised Person of the Firm provided investment advice to or controlled an open-end fund then such fund would also be reportable. However, such relationships are not anticipated to exist at HWM. Any Supervised Person must inform the CCO of any such advisory or control relationship with an open-end fund.