Exhibit 99.(p)(9)

Navian Investment Management, LLC

CODE OF ETHICS

AUGUST 2026

Table of Contents

This Code of Ethics (the “Code”) has been adopted by Navian Investment Management, LLC (“NIM”), in accordance with Rule 204A-1 of the Investment Advisors Act of 1940 (the “Advisers Act”) and Rule 17j-1 under the investment Company Act of 1940 (the “Act”). This Code establishes rules of conduct for all affiliated persons of NIM and is designed to, among other things, govern personal securities trading activities in the accounts of affiliated persons. The Code is based upon the principle that NIM and its affiliated persons owe a fiduciary duty to their Clients to conduct their affairs, including their personal securities transactions, in such a manner as to:

This Code is designed so that high ethical standards be applied and maintained by NIM and its affiliated persons. The purpose of the Code is to preclude activities which may lead to or give the appearance of conflicts of interest, insider trading, and other forms of prohibited or unethical business conduct. Strict compliance with the provisions of this Code is expected of all affiliated persons of NIM. The excellent name and reputation of our firm continues to be a direct reflection of the conduct of each employee.

Building a reputation for fair and honest dealing with our Clients and the investment community in general is very important and takes the cooperative effort of all employees.

Employees are urged to seek the advice of the CCO for any questions as to how this Code applies to their individual circumstances. The CCO may delegate any of their responsibilities or duties described in this Code. The CCO may also, under circumstances that are considered appropriate or after consultation with the CEO of NIM, grant exceptions to the provisions contained in this Code only when it is clear that the interests of NIM Clients will not be adversely affected. All questions arising in connection with personal securities trading should be resolved in favor of the interest of the clients even at the expense of the interest of our employees.

Covered persons are all affiliated persons of NIM as defined below under Supervised Persons, Access Persons, and (where applicable) Family Members.

Supervised persons include:

Access persons include any supervised persons who:

For purposes of personal securities reporting, NIM considers the supervised or access persons defined above to also include the person’s immediate family (including any relative by blood or marriage living in the supervised or access person’s household) and any account in which he or she has a direct or indirect beneficial interest (such as a trust).

All covered persons must comply with all applicable state and Federal securities laws including, but not limited to, the Advisers Act, the Act, Regulation S-P and the Patriot Act, as it pertains to Anti-Money Laundering. Rule 17j-1 under the Act and Section 206 of the Advisers Act generally proscribe fraudulent or manipulative practices with respect to purchases or sales of securities held or to be acquired by investment advisers. In particular, it is unlawful for any affiliated person of NIM in connection with the purchase or sale, directly or indirectly, to:

In the course of investment advisory activities of NIM, the firm obtains and has access to personal and nonpublic information about its Clients. Such information may include a person’s 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 NIM 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 NIM current or former Clients, is subject to the Code’s policies and procedures. Any doubts about the confidentiality of information must be resolved in favor of confidentiality.

NIM, as a fiduciary, has an affirmative duty of care, loyalty, honesty and good faith to act in the best interests of its Clients. Compliance with this duty can be achieved by avoiding conflicts of interest and if they occur, by fully disclosing all material facts concerning any conflict that may arise with respect to any Client.

Conflicts among Client Interests

Conflicts of interest may arise where NIM or its covered persons have reason to favor the interests of one Client over another Client (e.g., larger accounts over smaller accounts, accounts where compensation is greater, accounts in which covered persons have made material personal investments, accounts of close friends or relatives of covered persons). NIM specifically prohibits inappropriate favoritism of one Client over another Client.

Competing with Client Trades

NIM prohibits covered persons from using knowledge about pending or currently considered securities transactions for Clients in order to profit personally, directly or indirectly, as a result. In order to avoid any potential conflict of interest between NIM and its Clients, securities transactions for the accounts of covered persons in the same security as that purchased or sold for advisory accounts should be entered only after the expiration of a black-out period, explained more fully below.

No Transactions with Clients

NIM specifically prohibits covered persons from knowingly selling to or purchasing from a Client any security or other property, except securities that may be issued by the Client.

Disclosure of Personal Interest

NIM prohibits covered persons from recommending, implementing or considering any securities transaction for a Client without having disclosed any material beneficial ownership, business or personal relationship, or other material interest in the issuer or its affiliates, to an appropriate designated person (e.g., the CEO). If this designated person deems the disclosed interest to present a material conflict, the investment personnel may not participate in any decision-making process regarding the securities of that issuer.

INFORMATION BARRIER WITH AFFILIATED BROKER-DEALER

NIM has an affiliated broker-dealer due to common ownership. This creates potential conflict of interest. NIM has created and will maintain a ‘fire wall’ between the investment adviser and the affiliated broker-dealer. The fire wall is intended to prevent NIM’s covered persons who have access to information concerning the composition and/or changes to the ETF’s portfolio from using the information for the affiliated broker-dealer’s business. The following policies and procedures:

transactions. The Portfolio Managers cannot make changes to the approved broker list without approval from Management;

All covered persons are expressly prohibited from knowingly spreading any false rumor concerning any company, or any purported market development, that is designed to impact trading in or the price of that company’s or any other company’s securities, (including any associated derivative instruments), and from engaging in any other type of activity that constitutes illegal market manipulation. This prohibition includes the false spreading of any rumors, or any other form of illegal market manipulation, via any media, including, but not limited to e-mail, instant messages, blogs or chat rooms. Any covered person who is found to have engaged in such conduct shall be subject to disciplinary action which may include termination.

All covered persons of NIM must promptly (upon discovery of violation) report violations of this Code to the CCO. If the CCO is unavailable, the violation must then be reported to NIM’s CEO. Sanctions may be imposed depending on the circumstances of the situation which may include reprimands, censures, fines, disgorgement, or suspensions. Employees of NIM should understand that a material breach of the provisions of this Code will constitute grounds for disciplinary action and/or immediate termination of employment with NIM.

Inside information is presently defined as information that has not been disseminated to the general public through the traditional communications channels; is known by the recipient (tippee) to be non-public; or has been improperly obtained. In addition, the information is material and important enough that a reasonably prudent person might base their decision to invest or not invest on the information. If a NIM supervised person believes they are in possession of inside information, including information on a Fund NIM manages, it is critical that they not act on the information or disclose it to anyone, but instead advise the CCO accordingly. Acting on such information may subject the supervised person to severe federal criminal penalties, and result in disciplinary action and potentially termination of employment with NIM.

The following procedures have been established to assist NIM employees to avoid violations of the insider trading provisions of the Advisers Act. Every employee must follow these procedures or risk being subject to termination. If an employee has any questions about these procedures, he/she should bring them to the CCO promptly.

Identification of Insider Information

All employees of NIM must ask the following questions when presented with a potential conflict of this type:

If, after considering the above, an employee believes that the information may be material and non-public, he/she should:

After reviewing the information, the CCO will determine whether the information is material and non-public, and will advise the employee accordingly of the appropriate course of action.

Prevention of Insider Trading

Steps to Detect Insider Trading

Personal securities transactions by covered persons are subject to the following trading restrictions. This

requirement applies to all transactions a covered person might reasonably have control over, for all members of their household, as well as any other account from which they receive an economic benefit, including any 401(k) and Profit Sharing Plans.

No covered person may purchase or sell any of the following securities without pre-clearing this action through the CCO:

Requests for pre-clearance are made by completing a Personal Securities Trading Request & Authorization (see Exhibit 1 for an example of information required to be reported) and forwarding it to the CCO. A final decision will be communicated to the covered person in a timely fashion. Only upon receipt of the written approval from the CCO can the covered person engage in the requested transaction. All approved transactions are in effect for up to two business days on which approval was requested (unless otherwise noted). If a covered person decides not to execute the transaction on the days pre-clearance approval is given or the entire trade is not executed, a new request for pre-clearance must be made. Limit orders entered must be placed as a day order. In addition, covered persons may not simultaneously request pre-clearance to buy and sell the same security.

All covered persons of NIM are required to provide account statements and transaction confirmations for any personal trading accounts under their control that contain Reportable Securities. This requirement applies to all accounts a covered person might reasonably have control over, for all members of their household, as well as any other account from which they receive an economic benefit, including any 401(k) and Profit Sharing Plans.

If a covered person believes that they should be exempt from the reporting requirements above they should advise the CCO in writing, giving the name of the account, the person(s) or firm(s) responsible for its management, and the reason(s) they should be exempt from reporting requirements under this Code.

“Security” means any note, stock, treasury stock, security future, bond, debenture, evidence of indebtedness, certificate of interest or participation in any profit-sharing

agreement, collateral-trust certificate, pre- organization certificate or subscription, transferable share, investment contract, voting-trust certificate, certificate of deposit for a security, fractional undivided interest in oil, gas, or other mineral rights, any put, call, straddle, option, or privilege on any security (including a certificate of deposit) or on any group or index of securities (including any interest therein or based on the value thereof), or any put, call, straddle, option, or privilege entered into on a national securities exchange relating to foreign currency, or, in general, any interest or instrument commonly known as a “security,” or any certificate of interest or participation in, temporary or interim certificate for, receipt for, guaranty of, or warrant or right to subscribe to or purchase any of the foregoing.

For purposes of this Code, the term “Reportable Securities” means all of the securities described above except:

Exchange Traded Products, (ETPs) including exchange traded notes, (ETNs), exchange traded funds, (ETFs), closed end funds and exchange traded derivative contracts are considered reportable securities under the Code.

If there is any question by a covered person as to whether a security is reportable under this Code, they should consult with the CCO for clarification on the issue before entering any trade for their personal account.

Covered persons are not required to submit:

Initial/Annual Report

All employees of NIM who during the course of their employment become a covered person as defined in subsection 2 of this Code (this may be upon employment), and annually thereafter, must provide the CCO with a Personal Securities Accounts Report (see Exhibit 2 for an example of information required to be reported) or the applicable brokerage statements no later than 10 days after the individual becomes a covered person. The initial holdings information provided in conjunction with this certification must be current as of 45 days before the individual became a covered person.

The annual holdings information provided must be current as of a date no more than 45 days prior to the date the report was submitted.

Quarterly Report

Every covered person must submit a quarterly transaction report to the CCO within 30 days from calendar quarter end. If quarterly brokerage statements are not available, a monthly statement for each respective month will suffice. The quarterly transaction report requirement will be satisfied through receipt by the CCO of quarterly or, if applicable, monthly statements received directly from the custodian.

The CCO will review each statement for any evidence of improper holdings, trading activities, or conflicts of interest by the covered person.

NIM will maintain the following records for at least five years from the end of the fiscal year in which it is made, the first two years in an easily accessible place:

A copy of the Code and any amendments will be provided to each covered person. NIM covered persons must acknowledge initially, annually and as material changes are made, that they have received, read, and understand, the Code of Ethics.

Exhibit 1: Personal Securities Trading Request & Authorization

Navian Investment Management, LLC

This transaction is for investment purposes and to the best of my knowledge will comply with the appropriate personal trading and insider trading provisions contained in Adviser’s Code of Ethics.

D The above transaction is approved based on information provided above and is in effect solely for the 2 business days from the date which approval was granted. If the transaction does not execute or is partially executed, a new pre-clearance request will be required.

D The above transaction is disapproved for the following reasons:

Exhibit 2: Personal Securities Accounts Report

Navian Investment Management, LLC

List all brokerage accounts in which you have direct or indirect beneficial interest or control in the table below. (Include 401(k) Plans and Profit Sharing Plans):

Ill. Please select all that apply:

IV. Covered Person Information

I agree to promptly notify the CCO or designee if any such accounts are opened. I also agree to submit an initial holdings report to the CCO or designee within 10 days of such opening.