At Vukota Capital Management LLC and its affiliated companies (“VCM”), we recognize that in the industry in which we operate, trust and reputation are so important. VCM has worked hard to cultivate a culture of ethics and open and honest communication within our organization and in our interactions with investors. Our clients’ interests are always of upmost importance.

As required by Rule 204A-1 of the Investment Advisers Act of 1940, VCM has adopted a Code of Ethics that sets forth the basic policies of ethical conduct for all officers and employees of the firm. The Code of Ethics describes the firm’s fiduciary duties and obligations to investors and sets forth VCM’s practice of supervising the personal securities transactions of employees who maintain access to investor information.

All employees will follow the law and act with competence, dignity, integrity, and in an ethical manner, when dealing with investors, the public, prospects, third-party service providers and fellow employees. Employees must use reasonable care and exercise independent professional judgment when conducting investment analysis, promoting VCM’s products and services, and engaging in other professional activities.

We expect all employees to adhere to the highest standards with respect to any potential conflicts of interest with investors. As a fiduciary, VCM must act in its investors’ best interests at all times. Neither VCM, nor any employee shall benefit at the expense of any investor.

VCM collects and maintains records of securities holdings and transactions made by employees. The firm reviews the personal trading practices of its employees to identify and resolve any potential or realized conflicts of interest.

Upon request, VCM will furnish investors with a copy of the Code of Ethics.