Exhibit (r)(ii)

EVANSTON CAPITAL MANAGEMENT, LLC

CODE OF ETHICS

This Code of Ethics is given to all “Supervised Persons” of Evanston Capital Management, LLC and its subsidiaries (collectively, “EC”). Additionally, “Access Persons” are generally required to file various written reports with EC, detailing certain personal security holdings and transactions, and general compliance with this Code of Ethics. Subject to certain limited exceptions in this Code of Ethics, all of EC’s “Access Persons” must pre-clear “Reportable Securities” trades prior to execution. EC is registered as an investment adviser with the United States Securities and Exchange Commission (“SEC”).

MARCH 31, 2026

EVANSTON CAPITAL MANAGEMENT, LLC

CODE OF ETHICS

Evanston Capital Management, LLC and its subsidiaries¹ (collectively, “EC”) have adopted this Code of Ethics in accordance with Rule 204A-1 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The Code of Ethics provides policies and procedures consistent with the Advisers Act to seek to prevent certain EC-affiliated persons from engaging in any conduct prohibited by Rule 204A-1 or from breaching any other applicable Federal Securities Laws, such as:

EC recognizes that it owes a fiduciary duty to its clients. Consistent with those duties, no Supervised Person will (a) place personal interests ahead of those of any EC client, (b) conduct personal Reportable Security transactions in a manner that is inconsistent with this Code of Ethics or that creates an actual or potential conflict of interest or abuses his or her position of trust and responsibility, (c) take inappropriate advantage of his or her position with EC, (d) execute transactions in an issuer’s Securities, where the Supervised Person has actual knowledge that a Portfolio Manager is contemplating or in the process of executing a transaction in those Securities; or (e) otherwise breach any applicable Federal Securities Laws, including those relating to insider trading.

No Access Person will:

Every Access Person will submit the following reports by logging on to CAS and completing the applicable electronic form (unless excepted by Section 9(iv)):

“Insider trading” is a crime. From time to time, EC might receive “inside information” from a Portfolio Manager. EC has established written Policies and Procedures to Detect and Prevent Insider Trading, as required under the Advisers Act (please see Appendix B). EC vigorously enforces these procedures to prevent insider trading violations. EC maintains a record of Reportable Securities trades by Access Persons so that it can supervise and detect possible violations of the prohibition on insider trading.

Employees must consult with the CCO or General Counsel if there is any question about this gifts and entertainment policy.

EC encourages its employees to engage in charitable and civic activities, including by providing time and/or financial support to appropriate causes. EC also believes in supporting the goals and values of its clients and Fund investors, as well as the communities in which they live and operate.

EC and its employees may donate to charitable causes or other similar organizations when requested by prospective and current EC clients, Fund investors, and other business partners

(collectively, “Business Partners”) in certain circumstances as outlined in EC’s Charitable Contributions Policy with respect to Business Partners. However, EC strictly prohibits EC and its employees from making any contribution in any amount to a Business Partner’s charitable cause, organization, or other event if the contribution is intended to influence the Business Partner to hire EC or to invest in the Funds.

The SEC’s “pay-to-play” rules seek to curtail campaign contributions and related payments to elected officials to influence awards of contracts to manage public pension plan assets and similar government investment accounts, or their investment in an investment fund.

Appendix C contains EC’s policies and procedures prohibiting EC and its Restricted Persons (as defined in Appendix C) from (1) making or soliciting others to make political contributions, and (2) providing anything of value to state or local candidates or officials for purposes of obtaining investments or business from a Government Entity (as defined in Appendix C). However, EC will permit its Restricted Persons to make de minimis political contributions with the CCO’s prior written approval. Please see Appendix C for more details.

Upon discovering a violation of this Code of Ethics, the CCO, the General Counsel and/or EC’s partners (or, for violations by any partners, the remaining partners, as appropriate) may impose such sanctions as deemed appropriate, including, among other things, a letter of censure or termination of the violator’s employment.

EC will use reasonable diligence and institute procedures reasonably necessary to prevent violations of this Code of Ethics.

Appendix A

EVANSTON CAPITAL MANAGEMENT, LLC

BENEFICIAL OWNERSHIP

Rule 16a-1(a)(2) under the Exchange Act states that the term “beneficial owner” means, for all relevant purposes, “any person who, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, has or shares a direct or indirect pecuniary interest in the [issuer’s] equity securities.” The definition revolves around the term “pecuniary interest,” which is defined in Rule 16a-1(a)(2)(i) to mean “the opportunity, directly or indirectly, to profit or share in any profit derived from a transaction in the subject securities.”

Rule 16a-1(a)(2) makes clear that a pecuniary interest may exist indirectly through another person or entity. That rule and Rule 16a-8 give precise guidance on how to apply the definition to several common indirect ownership situations.

Beneficial Ownership of securities includes:

Beneficial Ownership of securities excludes:

Appendix B

EVANSTON CAPITAL MANAGEMENT, LLC

POLICIES AND PROCEDURES TO DETECT

AND PREVENT INSIDER TRADING

(“Policy Statement”)

SECTION I. POLICY STATEMENT

This Policy Statement implements procedures to prevent the misuse of material, nonpublic information by employees of Evanston Capital Management, LLC and its subsidiaries (collectively, “EC”) in securities transactions. All references herein to “employees” will include EC’s members, officers, and employees.

Trading securities while in possession of material, nonpublic information (“Inside Information”) or improperly communicating that information to others may expose you to stringent penalties. Criminal sanctions are severe, and may include significant monetary fines and/or imprisonment. The SEC can recover the profits gained or losses avoided through the violative trading, impose a penalty of up to three times the illicit windfall, and permanently bar you from the securities industry. Finally, you may be sued by investors seeking to recover damages for insider trading violations.

Regardless of whether a government inquiry occurs, EC views seriously any violation of this Policy Statement. Such violations constitute grounds for disciplinary sanctions, including dismissal.

This Policy Statement is drafted broadly; it will be applied and interpreted in a similar manner. This Policy Statement applies to securities trading and information handling by all employees, including spouses, minor children and adult members of their households and any other relative of the employee on whose behalf the employee is acting for their own account or the account of any EC client.

If any employee has questions about who this Policy Statement covers, please consult the Chief Compliance Officer (“CCO”).

You must notify the CCO immediately if you have any reason to believe that a violation of this Policy Statement has occurred or is about to occur (or the General Counsel if the CCO is the subject of the alleged violation), whether or not such

violation involves you or other employees. Failure to do so constitutes grounds for disciplinary sanctions, including dismissal.

All personal securities trades are subject to EC’s Code of Ethics. However, compliance with the Code of Ethics’ trading restrictions by no means assures full compliance with the prohibition on trading while possessing Inside Information. No employee may trade, either personally or on behalf of clients, while he or she has any reason to believe that he or she may possess Inside Information; nor may such EC personnel communicate Inside Information to others (except to employees as necessary to effect the purposes of this Policy Statement).

All employees must report any affiliation or business relationship they may have with any issuer of underlying securities to the CCO.

Section 9(a)(2) of the Exchange Act and Rule 10b-5 thereunder make it unlawful for any person, acting alone or with others, to trade any security in order to create actual or apparent active trading in such security, or raise or depress the security’s price.

Employees are prohibited from engaging in actual or apparent trading in a security for the purpose of (a) inducing a security’s purchase or sale by others; or (b) causing a security’s price to move up or down. The Exchange Act does not prohibit otherwise lawful activity that has the incidental result of changing a security’s supply or demand, or its intrinsic value.

To constitute Inside Information, information must be both (a) material and (b) nonpublic.

Information is “public” when it has been disseminated broadly to investors in the marketplace through commonly recognized channels. Tangible evidence of such dissemination is the best indication that the information is public. For example, information is public after it has become available to the general public through a public filing with the SEC or some other governmental agency, the Dow Jones “tape” or the Wall Street Journal or some other publication of general circulation, and after sufficient time has passed so that the information has been disseminated widely. If you believe that you have information concerning an issuer which gives you an advantage over other investors, such information is, in all likelihood, non-public.

Before executing any trade for yourself, your affiliates or an EC client, you must determine whether you have access to material, nonpublic information. If you think that you might have access to material, nonpublic information, you must take the following steps:

Each employee must follow the steps above or risk serious sanctions, including dismissal, substantial personal liability and criminal penalties.

Tender offers represent a particular concern in the law of insider trading for two reasons. First, tender offer activity often produces extraordinary gyrations in the price of the target company’s securities. Trading during this time period is more likely to attract regulatory attention (and produces a disproportionate percentage of insider trading cases). Second, the SEC has adopted Rule 14e-3 which expressly forbids trading and “tipping” while in possession of Inside Information regarding a tender offer received from the tender offeror, the target company or anyone acting on behalf of either. Employees should exercise particular caution any time they believe they may have become aware of any nonpublic information (regardless of how trivial such information may be) relating to a tender offer.

Employees must be aware that even where there is no expectation of confidentiality, a person may become an insider upon receiving material, non-public information. Whether the “tip” made to the employee makes him/her a “tippee” depends on whether the corporate insider expects to benefit personally, either directly or indirectly, from the disclosure.

The “benefit” is not limited to a present or future monetary gain; it could be a reputational benefit or an expectation of a quid pro quo from the recipient by a gift of the information. Employees may also become insiders or tippees if they obtain material, non-public information by happenstance, at social gatherings, by overhearing conversations, etc.

In the past, securities laws have been interpreted to prohibit the following activities:

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SECTION II. PROCEDURES TO IMPLEMENT THE POLICY STATEMENT

EC has established the following procedures to aid its officers and employees in avoiding insider trading, and to aid EC in preventing, detecting and imposing sanctions against insider trading. Every officer and employee must follow these procedures or risk serious sanctions, including dismissal, substantial personal liability and criminal penalties. If you have any questions about these procedures, you should consult the CCO.

Employees must comply with EC’s Code of Ethics with respect to personal securities trading.

Employees should understand that if EC becomes aware of material, nonpublic information about the issuer of the underlying securities (even if the particular employee does not himself or herself have such knowledge), EC will not bear any

losses resulting in personal accounts through the implementation of this Policy Statement.

Employees will not disclose any nonpublic information (whether or not it is material) about EC or its securities transactions to any person outside EC (unless the CCO authorizes the disclosure). Inside Information may not be communicated to anyone outside EC; such information must be secured. For example, access to files containing material, nonpublic information and computer files containing such information should be restricted, and conversations containing such information, if appropriate at all, should be conducted in private.

Each employee will annually execute an acknowledgement of this Policy Statement via CAS (which will be done via the annual certification that such employee has received and read EC’s Code of Ethics).

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SECTION III. SUPERVISORY PROCEDURES

The CCO will implement and maintain this Policy Statement to seek to prevent and detect insider trading.

To prevent insider trading, the CCO should:

To detect insider trading, the CCO or her delegate should promptly investigate all reports of any possible violations of this Policy Statement.

Appendix C

EVANSTON CAPITAL MANAGEMENT, LLC

POLICY AND PROCEDURES REGARDING POLITICAL CONTRIBUTIONS

(“Political Contributions Policy”) 

Rule 206-4(5) of the Advisers Act addresses “pay-to-play” practices by investment advisers seeking to manage money for state and local governments. “Pay-to-play” involves making campaign Contributions and related Payments to elected officials in order to influence contract awards to manage public pension or other government assets in an investment fund.

It is EC’s policy that neither EC nor any of its Restricted Persons may make political Contributions, Solicit (as defined below) others to make political Contributions, or provide anything of value, directly or indirectly, to elected officials to obtain an investment in a Fund or otherwise obtain business from a Government Entity. For purposes of Rule 206-4(5) and this Appendix C, when EC provides investment advisory services to Funds that have Government Entity investors or that solicit any Government Entity, EC will be treated as if it was providing or seeking to provide investment advisory services directly to the Government Entity. EC has instituted the following procedures to govern political Contributions by Restricted Persons. The procedures are designed to avoid even the appearance that a Restricted Person made political Contributions to influence EC being hired to provide advisory services to any Government Entity.

Many states may have ethics laws that apply to, among other things, political Contributions, and these laws may have additional requirements that must be met. EC also intends to comply with state law requirements.

Capitalized terms that are not defined in this Section II or elsewhere in this Appendix C will have the meanings assigned to them in EC’s Code of Ethics. 

A Restricted Person may not directly or indirectly make any Contribution to a Covered Official unless made in accordance with Section III.B or subject to the exception set forth in Section III.D. A Contribution would include, for example, expenses incurred in organizing a fundraiser. Depending on the facts and circumstances, this may include providing certain of EC’s resources or facilities, such as the use of conference rooms or other office facilities, equipment or supplies or hosting an event for the official or candidate (each generally an “EC Resource”). Accordingly, use of any EC Resource for the benefit of any official or candidate is strictly prohibited.

If you have any questions about whether a Contribution requires prior approval or whether a payment or expenditure constitutes a “Contribution,” please contact the CCO.

A Restricted Person that is an individual may, with the CCO’s prior written approval (or if the CCO seeks to make the Contribution, the General Counsel’s prior written approval), make a Contribution that does not exceed (1) $350 per election to a Covered Official that the Restricted Person was eligible to vote for at the time of the Contribution, and (2) $150 per election to a Restricted Person for any other election (the “De Minimis Limit”). Primary and general elections are considered separate elections.

No Restricted Person may Coordinate, or Solicit any person or political action committee to make, Contributions or “bundle” Contributions to a Covered Official of a Government Entity to which EC is providing or seeking to provide investment advisory services, nor may any Restricted Person Coordinate, or Solicit any person or political action committee to make, Payments to a political party in any state or locality from which EC is providing or seeking to provide investment advisory services to a Government Entity. Before Coordinating or Soliciting any Contributions or Payments as described here, Restricted Persons must contact the CCO to determine whether EC is seeking to do business with the Covered Officials or political parties the Restricted Person seeks to support, and are therefore prohibited.

A Restricted Person’s proposed Contribution or Payment to a Political Committee will be excepted from the requirements set forth in Sections III.A and III.B so long as:

The CCO must pre-approve in writing any placement agent or other third party that EC hires to solicit Government Entities (including Government Entity investors in a Fund) to ensure compliance with the ban on unregulated placement agents. The CCO will also confirm that any Placement Agent is a Regulated Person.

Restricted Persons requesting to make any Contribution or Payment:

Approved Contributions or Payments must be made within five (5) days of obtaining the CCO’s written pre-approval.

Restricted Persons will also complete a political contribution certification on a quarterly basis. Any Contribution or Payment made during such quarter will be reported by providing the name of each recipient, the date the Contribution or Payment was made, and the dollar amount. All newly-hired Restricted Persons must, prior to commencing work with EC, disclose to the CCO any Contribution the Restricted Person has made to a Covered Official in the two years immediately prior to the Restricted Person’s date of hire.

The CCO will obtain certifications from each Restricted Person: (1) as of the employment offer date and (2) on a quarterly basis thereafter. The certifications will address any political Contributions to any Covered Official of a Government Entity and/or any Payments to a political party of a state or political subdivision thereof, or to a political action committee, made by a Restricted Person.

The CCO or her delegate is responsible for maintaining a separate list, or other record, of: