Section 1: Our Code of Ethics: A Commitment to Integrity

Trust is the currency of our business. To earn and keep that trust, Canyon Creek Investment Advisors (“CCIA”) has established a rigorous Code of Ethics that governs every aspect of our operations.

1-1. The Fiduciary Standard

As an investment adviser, we are fiduciaries. This means we have a fundamental legal and ethical obligation to act in your best interest.

• Client First: We place the integrity of the investment profession and the interests of our clients above our own personal interests.

• Duty of Loyalty: We act with reasonable care and exercise prudent judgment, strictly prohibiting any conduct involving dishonesty, fraud, or deceit.

• Transparency: We believe in full and fair disclosure. If a conflict of interest arises that cannot be avoided, we are committed to disclosing it prominently and plainly so you can make an informed decision.

1-2. Adopting a Global Standard

To reinforce our commitment to excellence, CCIA has formally adopted the CFA Institute Code of Ethics and Standards of Professional Conduct for all our personnel. This is widely considered the "gold standard" for investment professionals globally. By holding ourselves to this higher bar, we ensure that our firm operates with the same level of professionalism as the world’s leading investment institutions.

1-3. Zero Tolerance for Misconduct

Our Code of Ethics establishes strict prohibitions to protect the integrity of the markets and your portfolio:

• Insider Trading & Manipulation: We strictly prohibit the use of material nonpublic information for personal gain and any practices intended to distort prices or mislead market participants.

• Personal Trading: To prevent conflicts, our employees (designated as "Access Persons") must pre-clear their personal trades. Client trades always take priority over our own, and we are prohibited from profiting from short-term trading of the same securities we recommend to you.

1-4. A Culture of Accountability

We encourage a culture of openness. Our "Whistleblower Protection" policy ensures that any employee can report potential violations without fear of retaliation, ensuring issues are identified and resolved promptly.

Section 2: Professional Standards & Competence

We believe that high ethical standards must be matched by technical excellence.

2-1. The CFA Institute Asset Manager Code

CCIA claims compliance with the CFA Institute Asset Manager Code (AMC). This voluntary code outlines the ethical and professional responsibilities of firms that manage client assets. By adopting the AMC, we pledge to:

• Act in a professional and ethical manner at all times.

• Act with independence and objectivity.

• Act with skill, competence, and diligence.

Note: Canyon Creek Investment Advisors, Ltd. claims compliance with the CFA Institute Asset Manager Code. This claim has not been verified by CFA Institute.

2-2. Commitment to Competence

Financial markets are complex and constantly evolving. To navigate them effectively, we place a premium on professional competence:

• Rigorous Qualifications: We evaluate all advisory personnel based on their education, experience, and professional credentials to ensure they are qualified to serve you.

• Continuing Education: Learning never stops. Our advisors are required to complete continuing education (CE) annually to stay current with new investment products, strategies, and regulatory changes.

2-3. Fair Dealing & Best Execution

Our professional standards extend to how we handle your transactions:

• Best Execution: When we trade on your behalf, we don't just look for the lowest commission. We seek "best execution"—a holistic assessment of price, speed, and reliability—to ensure you get the most favorable terms reasonably available.

• Fair Allocation: We treat all clients fairly. If we trade a block of securities for multiple accounts, we allocate the trades equitably so that no client is favored over another.

2-4. Performance Integrity

We believe you deserve an accurate picture of how your investments are performing.

• Consistent Methodology: Our performance calculations utilize methodologies aligned with the Global Investment Performance Standards (GIPS®).

• Net-of-Fees: We present performance data net of fees, so you can see the true value of your returns after costs are deducted.

• Clear Benchmarks: We compare performance against appropriate, objective benchmarks to give you a fair frame of reference.