JAMES INVESTMENT RESEARCH, INC.

THE JAMES ADVANTAGE FUNDS

CODE OF ETHICS

Last Amended April 2026

Rule 17j-1 under the Investment Company Act of 1940 (the “Act”) requires registered investment companies and their investment advisers to adopt codes of ethics and reporting requirements to prevent fraudulent, deceptive and manipulative practices. The James Advantage Funds (the “Trust”) (“JAF”) is registered as an open-end management investment company under the Act. James Investment Research, Inc. (the “Adviser”) (“JIR”) is the investment adviser of the Trust. Except as otherwise specified herein, this Code applies to all employees, officers, directors and trustees of the Trust and the Adviser. Officers, directors and employees of the Trust’s service providers, other than the Adviser, are not covered under this Code, but are subject to the Codes of Ethics of their employers.

This Code of Ethics is based on the principle that the officers, directors, trustees and employees of the Trust and Adviser have a fiduciary duty to place the interests of the Trust before their own interests, to conduct all personal securities transactions consistently with this Code of Ethics (the “Code”) and to do so in a manner which does not interfere with the portfolio transactions of the Trust, or otherwise take unfair advantage of their relationship to the Trust. Persons covered by this Code must adhere to this general principle as well as comply with the specific provisions of this Code. Technical compliance with this Code will not insulate from scrutiny trades, which indicate an abuse of an individual’s fiduciary duties to the Trust. Although it is not prohibited by this Code, day trading by officers, directors, trustees and employees of the Trust and Adviser is not encouraged.

ordinary course of business relate to the making of any recommendation to the Funds regarding the purchase or sale of Securities. In addition, the Adviser’s directors, officers, and general partners are presumed to be Access Persons of the Funds. Notwithstanding the foregoing, employees of the Adviser whose primary responsibilities relate to tax preparation, bookkeeping, or similar administrative or accounting functions will not be deemed Access Persons provided that such employees (a) do not have access to nonpublic information regarding Fund portfolio holdings, transactions, or investment recommendations, and (b) are not involved in making, participating in, or obtaining such information as part of their regular duties.

A natural person in a control relationship, or an employee of a company in a control relationship, does not become an Access Person solely by virtue of the following: (i) normally assisting in the preparation of public reports without receiving information about current recommendations or trading; (ii) a single instance of obtaining knowledge of current recommendations or trading activity; or (iii) infrequently and inadvertently obtaining such knowledge.

The Chief Compliance Officer for the Trust and the Adviser shall determine who qualifies as an Access Person based on the facts and circumstances and shall maintain a current list of such persons.

Immediate family includes adoptive relationships and any other relationship (whether or not recognized by law) which the CCO determines could lead to possible conflicts of interest, diversions of corporate opportunity, or appearances of impropriety which this Code is intended to prevent.

“Purchase or sale of a security” includes, without limitation, the writing, purchase or exercise of an option to purchase or sell a Security, conversions of convertible securities and short sales.

“Security” shall have the meaning set forth in Section 2(a) (36) of the Act, except that it shall not include shares of unaffiliated registered open-end investment companies, direct obligations of the United States government such as U.S. Treasury securities, bankers’ acceptances, bank certificates of deposit, commercial paper, and high-quality short-term debt instruments, including repurchase agreements. The term “Security” shall include cryptocurrencies to the extent a cryptocurrency is deemed a security by the SEC.

All Access Persons shall clear in advance through the Chief Compliance Officer any purchase or sale, direct or indirect, of any Security in which such Access Person has, or by reason of such transaction acquires, any direct or indirect beneficial ownership interest. The CCO shall retain written records of such clearance requests, which records shall indicate approval or rejection of such clearance requests, along with the CCO’s approval and date of approval.

The CCO will not grant clearance for any purchase or sale of a Security on the same day during which any client has a pending buy or sell order in that same Security until that order is executed or

withdrawn nor will the CCO grant clearance for a Security being considered for purchase or sale by the Investment Committee. Being considered for purchase or sale includes being scheduled for discussion in Investment Committee. However, simply being on the Adviser’s BUY or SELL list does not constitute “being considered for purchase or sale”. If the Security proposed to be purchased or sold by the Access Person is an option, clearance will not be granted if the securities subject to the option are being considered for purchase or sale as indicated above. If the Security proposed to be purchased or sold is a convertible security, clearance will not be granted if either that Security or the securities into which it is convertible are being considered for purchase or sale as indicated above.

The Chief Compliance Officer may refuse to preclear a transaction if she deems the transaction to involve a conflict of interest, possible diversion of corporate opportunity, or an appearance of impropriety.

Clearance is effective, unless earlier revoked, until the earlier of (1) the close of business on that trading day, or (2) the Access Person learns that the information provided to the Compliance Officer in such Access Person’s request for clearance is not accurate. If an Access Person places an order for a transaction on a trading day but such order is not executed on that trading day (e.g., a limit order), clearance needs to be retained. Clearance may be revoked at any time and is deemed revoked if, after receipt of clearance, the Access Person has knowledge that a Security to which the clearance relates is being considered for purchase or sale.

The pre-clearance requirements in Section C of this Code shall not apply to:

Notwithstanding a grant of clearance under Section C hereof, or an exemption from pre-clearance requirements under Section D-9 hereof, the following actions and transactions are prohibited and will result in sanctions including but not limited to the sanctions expressly provided for in this Section. The prohibitions of paragraphs 1 through 7 of this Section do not apply to any limited partnership or investment pool for which the Adviser or an affiliated person of the Adviser provides investment management services or to any account managed by the Adviser for the purpose of developing a new product. The prohibitions of paragraph 1 through 7 of this Section also do not apply to disinterested trustees and members of their immediate families or to persons whose only affiliation with the Trust and the Adviser is as a director of the Adviser and members of their immediate families.

fulfilling his or her official duties as a trustee or director, should have known that, during the 15-day period immediately preceding the date of the transaction by the trustee or director, such Security was purchased or sold by the Trust or was being considered for purchase or sale by the Trust.

The Securities and Exchange Commission adopted a rule, effective September 2010, under the Investment Advisers Act of 1940 that prohibits an investment adviser from providing advisory services for compensation to a government client for two years after the adviser or certain of its executives or employees make a contribution to elected officials or candidates of the government client who can directly or indirectly influence the hiring of the investment adviser by the government client. The rule also prohibits an adviser from providing or agreeing to provide, directly or indirectly, payment to third parties for a solicitation of advisory business from any government entity on behalf of such adviser, unless such third parties are registered broker-dealers, registered investment advisers or registered municipal advisers, in each case subject themselves to pay-to-play restrictions (“Regulated Persons”). Additionally, the rule prevents an adviser from soliciting from others, or coordinating, contributions to certain elected officials or candidates or payments to state or local political parties where the adviser is providing or seeking government business. A registered adviser is also required to maintain certain records of the political contributions made by the adviser or certain of its executives or employees.

“Pay-to-Play” is defined as one or more political contributions by the Adviser or any officer; any employee who solicits clients for the Adviser; any supervisor of such employee; any political action committee controlled by the Adviser or its officers or employees that solicit clients for the Adviser; and any supervisor of such employees (each a “Covered Person”) to a person holding public office, running for public office, or to a committee formed for that end, or a successful candidate for public office, for the purpose of obtaining or retaining advisory contacts with governmental entities. Employees may not funnel contributions directly or indirectly through a spouse or family member. Contributions greater than $350 per election ($150 per election where the Covered Person is not entitled to vote) to candidates for political office must be logged and pre-cleared by the CCO or her designee.

If a Covered Person is uncertain whether a proposed contribution violates this prohibition, the officer should seek advice from the President of the Adviser or the Chief Compliance Officer.

Reporting & Recordkeeping Requirements

The Adviser will maintain records showing:

per Covered Person for any election in which that covered associate is entitled to vote, or $150 or less in any election where the associate is not entitled to vote do not need to be logged or pre-cleared; and

Records relating to the contributions and payments referred to in Section 10(c) must be listed in chronological order and indicate:

The Adviser is only required to make and keep current the records referred to in Sections 10(c)(i) and 10(c)(iii) if it provides investment advisory services to a government entity or a government entity is an investor in a Covered Fund.

The Initial Holdings Report (i.e., the Report required within 10 days of commencement of employment or being designated an Access Person) must contain information correct as of the date the person became an Access Person. The Annual Holdings Report must contain correct information as of a date no more than 30 days before the Report is submitted.

paragraph 2 of this Section as to any Security if such trustee or director, at the time of the transaction, knew or, in the ordinary course of fulfilling his or her official duties as a trustee or director, should have known that, during the 15-day period immediately preceding the date of the transaction by the trustee or director, such Security was purchased or sold by the Trust or was being considered for purchase or sale by the Trust.

The Chief Compliance Officer or a designee will monitor and review all reports required under the Code for compliance with the Trust and Adviser’s policies regarding personal securities transactions and applicable SEC rules and regulations. The CCO or designee may also initiate inquiries of Access Persons’ personal securities trading. Access Persons are required to cooperate with such inquiries and any monitoring or review procedures employed by the Trust or Adviser. Any transactions for any accounts of the CCO will be reviewed and approved in accordance with the Code by a member of the JIR Senior Management Team. The CCO or a designee will maintain a listing identifying all Access Persons who are required to file reports pursuant to the Code and Access Persons will be notified at least annually of their reporting obligations.

Although the Code does not impose strict limitations as to the number of transactions an Access Person is permitted to execute during a defined timeframe, the scope and volume of personal trading by JIR Access Persons shall be periodically assessed. JIR recognizes that excessive trading may impede the ability of an individual to fulfill his or her primary obligation to clients. In such circumstances JIR retains the discretionary authority to impose limitations on the personal trading activities of the Access Person. Furthermore, and as part of the Trust and Adviser’s oversight and monitoring of personal trading by Access Persons, JIR may impose heightened supervision and or trading restrictions on an Access Person if it believes such actions are warranted.

A compliance software system is utilized to help monitor the personal trading activities of JIR Access Persons who are required to submit reports under the Rule daily. The CCO or a designee receives email notifications for any perceived exceptions to the Code, which are then reviewed on

a case-by-case basis. Access Persons’ personal securities transactions are also automatically cross referenced against the Adviser’s client trades daily as part of compliance testing and to help identify any potential front running, fraudulent, or manipulative conduct. The software provides many automated compliance monitoring and testing tools to help detect possible violations of the Code and federal securities laws. It is also utilized for certifications or affirmations of Access Persons’ quarterly transaction reports, annual holdings reports, and policies and procedures, among others.

If a violation of the Code occurs, the CCO will promptly take action to correct and remediate any violations that occurred, will document the violation, and will report the violation to Senior Management of JIR and to the Board of Trustees of the Trust.

Every Access Person shall treat as confidential information the fact that a Security is being considered for purchase or sale by the Trust and Adviser, the contents of any research report, recommendation, or decision, whether at the preliminary or final level, and the holdings of the Trust and Adviser and shall not disclose any such confidential information without prior consent from the Chief Compliance Officer. Notwithstanding the foregoing, the holdings of the Trust shall not be considered confidential after such holdings by the Trust have been disclosed in a public report to shareholders or to the Securities and Exchange Commission.

Access Persons shall not disclose any such confidential information to any person except those employees and trustees who need such information to carry out the duties of their position with the Trust or Adviser.

Upon discovering a violation of this Code, the Board of Trustees of the Trust or the Board of Directors of the Adviser (as applicable) may impose such sanctions as it deems appropriate, including, without limitation, a letter of censure or suspension or termination of the employment of the violator. All material violations of this Code and any sanctions imposed with respect thereto shall be reported periodically to the Board of Trustees of the Trust and the Board of Directors or Senior Management of the Adviser.

Each Access Person, except a disinterested trustee or a person whose only affiliation with the Trust or Adviser is as a director of the Adviser, shall annually certify that he or she has read and understands this Code and recognizes that he or she is subject hereto.

All personnel of JIR are required to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. The Adviser’s employees must practice honesty and

integrity in fulfilling their responsibilities and comply with all applicable laws and regulations. It is the responsibility of JIR employees to not only comply with but to report violations or suspected violations of JIR or the James Advantage Funds policies or violations of federal and state laws.

This Whistleblower Policy was created to encourage and enable employees to report serious concerns and complaints regarding any misconduct that has resulted in harm to JIR, clients of JIR, or shareholders of the James Advantage Funds. Employees who in good faith report violations should do so without feeling threatened. It is the policy of JIR not to allow discrimination, retaliation, or retribution against any employee who in good faith submits a report of misconduct.

JIR will also monitor the provisions of its confidentiality or other agreements to seek to ensure the language of such agreements, by itself or under the circumstances in which the agreements are used, does not impede employees and former employees from communicating with the SEC concerning possible securities law violations. In addition, such agreements will seek to make it clear nothing contained in those agreements prohibits employees or former employees from voluntarily communicating with the SEC or other authorities regarding possible violations of law or from recovering an SEC whistleblower award. JIR will monitor for compliance with Rule 21F-17 with respect to regulatory activity and case law as they evolve over time.

Employees may report their concerns in writing or email, telephone, or in-person to any member of JIR’s Senior Management or to the CCO if the matter concerns Senior Management. Compliance software used by the Adviser offers anonymous reporting. Employees may use the software as a means of reporting their concerns. All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation. The CCO will notify the Audit Committee Chair of the James Advantage Funds if a report relates to, or in the view of JIR management, could reasonably relate to the James Advantage Funds is made.