In order to minimize conflicts, potential conflicts, or the appearance of conflicts, Adviser has adopted the following:
1. Adviser’s only business line is providing investment advisory services.
2. Gifts, Entertainment, and Sponsorships Policy to address conflicts related to providing and receiving gifts and entertainment.
3. Code of Ethics and Insider Trading Policy to address conflicts related proprietary trading of Adviser and personal trading activities of supervised persons.
4. Proxy Voting Policy to address conflicts related to the voting of proxies by Adviser on behalf of clients.
5. Allocation of Investment Opportunities and Aggregated Trades Policy to prevent any client from being systematically favored over any other client in: (a) the allocation of investment opportunities, or (b) the allocation of aggregated trades
6. Soft Dollar and Best Execution Policies to address conflicts related to the use of client brokerage.
7. Pay-to-Play Restrictions – Political Contributions Policy to address conflicts related to the giving of political contributions.
8. Adviser does not engage in the following activities which involve actual or potential conflicts of interest:
(a) portfolio pumping,
(b) window dressing,
(c) use of affiliated brokers,
(d) directing brokerage other than at clients’ request, and (e) agency cross transactions.