Exhibit (p)(16)

Capital Wealth Planning

Code of Ethics

CAPITAL WEALTH PLANNING

9015 Strada Stell Ct
Suite 203

Naples, Florida 34109

Main: 239.593.2100

www.capitalwealthplanning.com

Table of Contents

This Code of Ethics (the “Code”) is an expression of Capital Wealth Planning’s (“CWP”) recognition of its fiduciary obligations to its clients and its duty to comply with all federal and state securities laws. It is CWP’s intent to use the Code to set out ideals for the ethical conduct of CWP and its Supervised Persons in the performance of their investment advisory services. These ideals are premised on the fundamental principles of openness, integrity, honesty, fairness and trust. These ideals are both an indication of the value CWP places on the ethical conduct of its Supervised Persons and a challenge to its Supervised Persons to live upto the high standards demanded by the investment advisory profession.

CWP strives to maintain the highest standards of ethics and conduct in all of its business relationships. CWP’s business philosophy is that its clients deserve undivided loyalty and effort and that their interests always come first. The Code memorializes this philosophy through written standards of business conduct that deter wrongdoing and promote, among other things:

Only by conducting business in accordance with the highest ethical, legal and moral standards can CWP achieve its goals. Since corporate behavior begins with the individual behavior of its personnel, CWP has adopted the Code so that its Supervised Persons may know the individual ethical, legal and moral standards expected of them. All activities of CWP’s Supervised Persons should be guided by and adhere to these standards.

It is a condition of employment with CWP that a Supervised Person receives a copy of the Code and acknowledges their understanding of the Code both initially upon their employment and annually thereafter (Exhibit A: Code Acknowledgement). CWP urges each Supervised Person, no matter how long or short a time he or she may have been affiliated with CWP, to study this Code and to review it periodically. Abiding by its letter and its spirit is important to each Supervised Person’s personal success and to the collective success of CWP.

For purposes of the Code, the following terms have the meanings specified in this section:

As a registered investment adviser, CWP and its Supervised Persons are subject to regulation by federal and state securities authorities pursuant to applicable federal and state securities laws. CWP expects its Supervised Persons to comply with both the spirit and letter of all federal and state securities laws, rules and regulations applicable to CWP’s investment advisory operations and business. Supervised Persons should seek guidance whenever they are in doubt as to the applicability of any law, rule or regulation regarding any contemplated course of action.

A Supervised Person shall offer and provide investment advisory services with integrity, objectivity and competence. Integrity requires a Supervised Person to be, among other things, honest and candid within the constraints of client confidentiality. Integrity requires that a Supervised Person’s advisory services must not be subordinated to personal gain and advantage. Objectivity requires intellectual honesty and impartiality. The principle of objectivity imposes an obligation on the Supervised Person to be free of conflicts of interest. Competence requires an adequate level of knowledge and skill and the ability to apply that knowledge and skill effectively when providing investment advisory services to clients. Competence also requires a commitment to learning and professional improvement that must continue throughout a Supervised Person’s professional life.

Each Supervised Person should be scrupulous in avoiding any conflict of interest with regard to CWP’s or a client’s interests. A “conflict of interest” occurs when a Supervised Person’s private interest interferes with the interests of CWP or a client. A conflict situation can arise when a Supervised Person pursues interests that prevent the Supervised Person from performing his or her duties objectively or effectively. Any conflict of interest that arises in a specific situation or transaction must be disclosed by the Supervised Person and resolved before taking any action.

Conflicts of interest may also arise where CWP or its Supervised Persons have reason to favor the interests of one client over another client (e.g., larger accounts over smaller accounts, accounts compensated by performance fees over accounts not so compensated, accounts in which Supervised Persons have made material personal investments, accounts of close friends or relatives of Supervised Persons). Supervised Persons are specifically prohibited from inappropriate favoritism of one client over another client that would constitute a breach of fiduciary duty.

Supervised Persons must exercise care in maintaining the confidentiality of (a) any client’s (or former client’s) Nonpublic Personal Financial Information, (b) any material nonpublic information about CWP’s securities recommendations and (c) any material nonpublic information about clients’ (or former clients’) securities holdings and transactions. Supervised Persons shall not disclose any information about a client (or former client) including the client’s identity, the client’s financial circumstances, the client’s security holdings, the securities investments made by CWP on behalf of the client, information about the client’s contemplated securities transactions or advice furnished to the client by CWP without the specific consent of the client (or former client) unless in response to proper legal process.

All Supervised Persons are required to comply with CWP’s Privacy Policy and Information Security Policy as set forth in the Compliance Manual. Supervised Persons should consult with the Chief Compliance Officer if they believe they have a legal obligation to disclose confidential information. The obligation to preserve the confidentiality of this information shall continue after the Supervised Person’s association with CWP ends.

Supervised Persons shall perform investment advisory services in a manner that is fair and reasonable. Supervised Persons shall endeavor to at all times deal fairly with CWP’s clients and shall not seek unfair advantage through improper concealment, abuse of improperly acquired confidential information, or misrepresentation of material facts. Supervised Persons shall make a full and fair disclosure of all material facts to CWP’s clients and such disclosure shall be accurate, timely and understandable. Supervised Persons shall always offer investment opportunities to CWP’s clients before they act on such opportunities themselves. Supervised Persons shall not use knowledge about pending or currently considered securities transactions for clients to profit personally, directly or indirectly, as a result of such transactions.

All personal securities transactions shall be conducted in such a manner as to be consistent with this Code and to avoid any actual or potential conflict of interest or any abuse of an Access Person’s position of trust and responsibility.

No Access Person may, directly or indirectly, acquire any beneficial ownership in any Covered Security, unless such transaction has been approved in advance by the Chief Compliance Officer in accordance with Section 4.3 below.

To obtain pre-approval for the purchase or sale of (i) any Covered Security pursuant to an IPO; or (ii) any Covered Security pursuant to a Limited Offering, (iii) any Covered Security purchased in any CWP portfolio, the Access Person must submit an email to the Chief Compliance officer detailing any desired purchase or sale. Once approved, the Access Person shall have one (1) business days to make the transaction. If such transaction is not made within the one (1) business day period, the Access Person must resubmit the request to the Chief Compliance Officer for his or her approval. The Chief Compliance Officer shall maintain records of decisions approving or disapproving an Access Person’s personal securities transactions.

CWP does not impose strict limitations as to the number of transactions an access person is permitted to engage in during a defined time frame, the scope and volume of personal trading by access persons shall be assessed. CWP also recognizes that excessive trading may impede the ability of an individual to fulfill his or her primary obligation to our clients. In such circumstances CWP retains the discretionary authority to impose limitations on the personal trading activities of the access person. Furthermore, CWP’s Chief Compliance Officer can impose heightened supervision and or trading restrictions on an Access Person if it is believed that such actions are warranted.

All Access Persons must file an initial holdings report containing the following information:

Initial holdings are required to be submitted no later than 10 days after an individual becomes an Access Person and must be current as of a date no more than 45 days prior to the date the individual became an Access Person.

All Access Persons must file an annual holdings report containing the same information required in the initial holdings report. The information submitted must be current as of a date no more than forty-five (45) days before the annual report is submitted.

All Access Persons must file a quarterly transaction report containing the following information:

All Access Persons are required to notify the Compliance Department prior to or at the time of establishing a new custodial account or the closing of an existing custodial account, providing the following details:

The Chief Compliance Officer shall, on a quarterly basis, review all Access Person statements and transactions to:

The Chief Compliance Officer will designate review of his reports to another Access Person.

An Access Person is not required to submit a:

To maintain objectivity, receiving gifts from clients or their representatives or giving gifts to clients or their representatives should be limited to those of a de minimis amount (so small or minimal in value that it does not matter, or the law does not take it into consideration) or, in certain instances, avoided completely. Allowable gifts should not exceed a total value of $300 per person per calendar year.

DEFINITIONS:

Gifts include:

The following gifts are exempt from the $300 per person per calendar year limit:

When initiating a gift request, an employee must fill out a Marketing Intake Form that details WHAT item(s) being requested. WHO the gift is going to, along with the address of the recipient, as well as the FIRM that the recipient is employed with. Any additional information/notes needed will be added to the form as well. Once the form is approved, the items requested will be sent out.

Because of the high potential for conflicts of interest and insider trading problems, no Supervised Person may serve as director of any publicly traded company without first obtaining the approval of Chief Compliance Officer. Any such approval shall be based on a determination by the Chief Compliance Officer that such board service will be consistent with the interests of the clients of CWP and that such Supervised Person will be isolated from those making investment decisions with respect to such company by appropriate procedures.

No Supervised Person may recommend, implement or attempt to cause any securities transactions by a client or participate in any investment decision without disclosing his or her material beneficial ownership, business or personal relationship, or other material interest in the issuer or its affiliates, to the Chief Compliance Officer. If the Chief Compliance Officer deems the disclosed interest to present a material conflict, the Supervised Person may not participate in any decision-making process regarding the securities of that issuer.

All Supervised Persons must initially, and annually thereafter, disclose all outside business activities Exhibit (G: Request for Approval of Outside Business Activity Form). A Supervised Person may not engage in any outside business activity with or without the receipt of compensation, either directly or indirectly, from any other person or entity other than CWP, without first obtaining the written approval of Chief Compliance Officer (Exhibit H: Request for Approval of Outside Business Activity Form).

Pay to play is the practice of making campaign contributions and related payments to elected officials in order to influence the awarding of lucrative contracts for the management of public pension plan assets and similar government investment accounts.

CWP is prohibited from providing advisory services for compensation — either directly or through a pooled investment vehicle — for two years, if CWP or its Covered Associates make a political contribution to an elected official who is in a position to influence CWP’s selection.

CWP and its Covered Associates are prohibited from soliciting or coordinating campaign contributions from others — a practice referred to as “bundling” — for an elected official who is in a position to influence the selection of CWP. It also prohibits solicitation and coordination of payments to political parties in the state or locality where CWP is seeking business.

CWP is prohibited from paying a third party, such as a solicitor or placement agent, to solicit a government client on CWP’s behalf, unless that third party is an SEC-registered investment adviser or broker-dealer subject to similar pay to play restrictions.

All Covered Associates as well as any immediate family member living in the same household wishing to make a political contribution will require the Covered Associate to submit a request form prior to making any politicalcontribution (Exhibit I: Political Contribution Request Form).

Section 6.5.2 does not apply to contributions made by a Covered Associate, if a natural person, to officials for whom the Covered Associate was entitled to vote at the time of the contributions and which in the aggregate do not exceed $350 to any one official, per election, or to officials for whom the Covered Associate was not entitled to vote at the time of the contributions and which in the aggregate do not exceed $150 to any one official, per election.

Access Persons may not open or maintain brokerage accounts or place personal securities transaction with a broker that has not been approved by the Chief Compliance Officer. The Company shall maintain a list of approved brokerage accounts for each Access Person.

CWP forbids all Supervised Persons, either personally or on behalf of others, to trade on material nonpublic information or to communicate material nonpublic information to others in violation of the law. In addition, CWP discourages its Supervised Persons from seeking or knowingly obtaining material, nonpublic information.

A Supervised Person may not buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment with CWP unless the information is also available to the investing public on reasonable inquiry.

Any question as to what constitutes material nonpublic information should be resolved in the most conservative fashion (i.e. that the determination be made that the information in question is material nonpublic information) which should be made by the Chief Compliance Officer or his or her designee. If an Access Person believes they have come into possession of non-public information of a public issuer, they need to report that information to the CCO. All accounts will need to be monitored for purchases/sales to ensure that the information is not shared with others.

If a Supervised Person receives information that may constitute material, nonpublic information, the Supervised Person, including family members, must not:

Under no circumstances should information that may constitute material, nonpublic information be shared with any persons other than the Chief Compliance Officer, including family members and friends.

The Chief Compliance Officer shall discuss insider trading issues with each Supervised Person each year. The review shall emphasize the necessity to continually maintain client confidentiality, to avoid insider trading, and to comply with CWP’s Code of Ethics. A Supervised Person’s execution of the Insider Trading Affidavit (Exhibit J: Insider Trading Affidavit) is an acknowledgment of that Supervised Person’s understanding of these topics.

EACH SUPERVISED PERSON HAS THE ULTIMATE RESPONSIBILITY FOR COMPLYING WITH THE PROCEDURES FOR THE HANDLING OF INSIDE INFORMATION.

The Code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not shield Supervised Persons from liability for personal trading or other conduct that violates a fiduciary duty to advisory clients.

Each Supervised Person is expected to discharge his or her responsibilities in full compliance with the Code. Each Supervised Person is responsible for the prompt reporting of any existing or potential violations of the Code to the Chief Compliance Officer. Failure to do so is itself a violation of the Code. No Supervised Person shall retaliate against any other Supervised Person for reports of potential violations that are made in good faith. Any such retaliation would be in itself considered a violation of the Code.

Any violations discovered by or reported to the Chief Compliance Officer shall be reviewed and investigated promptly. Any disciplinary action shall be based on, among other things, the severity of the infraction, whether it is a first or repeat offense, and whether it is part of a pattern of disregard for the letter and intent of this Code. Upon recommendation of the Chief Compliance Officer, CWP may impose such sanctions for violation of the Code as it deems appropriate, including, but not limited to, a letter of censure, suspension or termination of employment, reversal of a securities trade at the violator’s expense and risk,including disgorgement of any profit; and, in serious cases, referral to law enforcement or regulatory authorities.

Central to CWP’s compliance culture is an ingrained commitment to fiduciary principles. The policies and procedures in this Code of Ethics, and their consistent implementation by all Supervised Persons evidence CWP’s unwavering intent to place the interests of clients ahead of self-interest for CWP, its members and its personnel.

Every Supervised Person has a responsibility for knowing and following CWP’s policies and procedures. Every Supervised Person in a supervisory role is also responsible for those individuals under his/her supervision.

Recognizing CWP’s shared commitment to its clients, all Supervised Persons are required to conduct themselves with the utmost loyalty and integrity in their dealings with CWP’s clients, stakeholders and one another. Improper conduct on the part of any employee puts CWP and its personnel at risk. Therefore, while senior management ultimately has supervisory responsibility and authority, senior management cannot stop or remedy misconduct unless they know about it. Accordingly, all Supervised Persons are not only expected to, but are required to report their concerns about potentially illegal conduct as well as violations of CWP’s policies.

A whistleblower as defined by this policy, is an employee or independent contractor of CWP who reports an activity that he/she considers to be unethical, wrongful, illegal or dishonest to one or more of the parties specified in this policy. The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities. Examples of unethical, wrongful, illegal or dishonest activities are violations of federal, state or local laws; billing for services not performed or for goods not delivered; violations of the Code of Ethics and Compliance Manual; and other fraudulent financial reporting.

To ensure consistent implementation of such practices, it is imperative that Supervised Persons have the opportunity to report any concerns or suspicions of improper activity at CWP (whether by another Supervised Person or other party) confidentially and without retaliation. This Whistleblower Policy covers the treatment of all concerns relating to suspected illegal activity or potential misconduct. Supervised Persons should report potential misconduct by submitting a notice to the Chief Compliance Officer or CWP’s Human Recourses Department, if the matter pertains to the Chief Compliance Officer (may be submitted anonymously).

A person must be acting in good faith in reporting a complaint or concern under this Whistleblower Policy and must have reasonable grounds for believing a deliberate misrepresentation has been made regarding accounting or audit matters or a breach of this Code of Ethics. A malicious allegation known to be false is considered a serious offense and will be subject to disciplinary action that may include termination of employment or affiliation with CWP.

CWP will take seriously any report regarding a potential violation of CWP policy or other improper or illegal activity, and recognizes the importance of keeping the identity of the reporting person from being widely known. Supervised Persons are to be assured that CWP will appropriately manage all such reported concerns or suspicions of improper activity in a timely and professional manner, confidentially and without retaliation.

In order to protect the confidentiality of the individual submitting such a report and to CWP to conduct a comprehensive investigation of reported misconduct, Supervised Persons should understand that those individuals responsible for conducting any investigation are generally precluded from communicating information pertaining to the scope and/or status of such reviews.

It is CWP’s policy that no Supervised Person who submits a complaint made in good faith will experience retaliation, harassment, or unfavorable or adverse employment consequences. A Supervised Person who retaliates against a person reporting a complaint will be subject to disciplinary action, which may include termination of employment. A Supervised Person who believes s/he has been subject to retaliation or reprisal as a result of reporting a concern or making a complaint is to report such action to the Chief Compliance Officer or CWP’s outside compliance consultant, if the matter pertains to the Chief Compliance Officer (may be submitted anonymously).

Any employment contract or agreement that contains retaliatory provisions or otherwise requires the reporting of instances of impropriety, fraud or violations of law at CWP exclusively to CWP and its senior management and/or otherwise prohibits the reporting, either directly or indirectly, to any regulatory body, such as the Securities and Exchange Commission, shall be deemed null and void. The provisions of this Whistleblower policy, particularly with respect to non-retaliation, shall supersede any employment or other agreements, either written or verbal, regardless of the execution date of any such agreement.

Training shall take place periodically at the discretion of the Chief Compliance Officer, but no less than annually. All Supervised Persons shall be required to attend any training session or read any applicable materials. Supervised Persons are required to recertify annually that they have read and understood this Code.

New Supervised Persons will be required to attend an orientation session that explains their obligations under this Code.

CWP’s Chief Compliance Officer shall maintain and cause to be maintained in a readily accessible place the following records:

Exhibit A

CODE OF ETHICS ACKNOWLEDGEMENT

By signing in the space provided below, you certify that:

Exhibit B

SUPERVISED PERSONS AND ACCESS PERSONS

Exhibit C

TRADE APPROVAL

I hereby certify that I have read and understand the Capital Wealth Planning Code of Ethics and that this transaction is being made in compliance with all aspects of Capital Wealth Planning’s policies. Further, I certify that I am not aware of any material, non-public information concerning this issuer or the market for its securities. Nor am I aware of any plans of Capital Wealth Planning to purchase this security for Capital Wealth Planning clients.

Authorization

Exhibit D

HOLDINGS REPORT

Attach additional sheets as necessary.

Exhibit E

TRANSACTIONS REPORT

Attach additional sheets as necessary.

Exhibit F

GIFT & ENTERTAINMENT REPORT

I hereby certify that I have disclosed all gifts:

Review

I hereby certify that I have reviewed the above listed gifts:

Exhibit G

OUTSIDE BUSINESS ACTIVITY DISCLOSURE FORM

YES ______   NO ______

YES ______   NO ______

YES ______   NO ______

Exhibit H

REQUEST FOR APPROVAL OF OUTSIDE BUSINESS ACTIVITY

If approval is granted, I agree to:

Approval Granted by / Denied by:

Exhibit I

POLITICAL CONTRIBUTION REQUEST FORM

NOTE: Pre-Approval is not needed for personal political contributions to candidates for Federal office who are not State or local officials at the time of the contribution.

Check at least one of the following:

________ I am requesting approval to make a Political Contribution. (Complete Attachment 1)

________ I am requesting approval to volunteer for a Campaign. (Complete Attachment 2)

________ I am requesting approval to Coordinate or Solicit Contributions, including Fundraising. (Complete Attachment 2)

By signing below, I certify that the political contribution or activity described in the attached is accurate, and the proposed contribution or activity is not made to influence or induce the obtaining or retaining of investment advisory services business for CWP.

Attachment 1

Description of Political Contribution

If Contribution Is In-Kind or Other Than Cash or Check Indicate Its Nature:

If Contribution is to a Candidate, Officeholder, or Campaign, Provide the Information Below:

Are You Entitled To Vote for This Candidate/Officeholder: Yes __________  No __________

If Contribution is to a Political Organization (such as a Political Party or PAC), provide the information:

Yes __________   No  __________

Attachment 2

Description of Volunteer Activity/

Solicitation or Coordination of Contributions, or Fundraising

Part I

Name of Beneficiary (Officeholder, Candidate, Campaign, Political Party, Political Organization Benefiting from Volunteer Activity, or Soliciting or Coordinating Contributions or Fundraising):

Type of Beneficiary (Check One):

Candidate/Officeholder/Campaign _________

Political Party _________

PAC _________

Other _________   (describe)

Part 2

Yes __________   No __________

Yes __________   No __________

Yes __________   No __________

(Please note that such personal expenditures may be a political contribution requiring a separate Pre-Approval request to be submitted on Attachment 1)

Yes __________   No __________

Exhibit J

INSIDER TRADING AFFIDAVIT

I hereby represent and warrant for the benefit of Capital Wealth Planning (“CWP”) as follows:

My signature below indicates that I have received a copy of CWP’s Code of Ethics and Compliance Manual and have read and understood all applicable provisions relating to insider trading and personal securities transactions. I agree to continually abide by these policies.