Code of Ethics

Introduction

Developing Financial has adopted this Code of Ethics (the “Code”) setting forth the standards of conduct expected of our personnel and addressing conflicts that arise from personal trading by our personnel. This Code is intended to promote compliance with our fiduciary standards to our clients.

General Principles

The reputation of Developing Financial is important, and in order to protect this reputation, we must uphold principles of honesty, integrity, and professionalism. Because Developing Financial is a fiduciary for our Advisory Clients, we have the following general principles:

• The duty at all times to place the interests of clients first. All Associated Persons must scrupulously avoid serving their own personal interest ahead of the interests of the client, and must work diligently to ensure that no client is preferred over any other client.
• Personal transactions in securities by Associated Persons must be accomplished so as to avoid even the appearance of a conflict of interest with the interest of the clients.
• Associated Persons must avoid actions or activities that allow (or appear to allow) a person to profit or benefit from his or her position with Developing Financial at the expense of clients, or that otherwise bring into question the person’s independence or judgment.
• All Associated Persons are prohibited from engaging in any practice that defrauds or misleads any client, or engaging in any manipulative or deceitful practice with respect to clients or securities.

Guidelines for Professional Standards

All Associated Persons must at all times reflect the professional standards expected of those engaged in the investment advisory business and shall act within the spirit and the letter of the federal, state, and local laws and regulations pertaining to investment advisers and the general conduct of business.

It is every Associated Person’s obligation to report suspected or actual violations of laws, government rules and regulations, the Code, or other suspected wrongdoings to the CCO immediately. Such reports will be held in confidence, and Developing Financial will not permit any form of intimidation or retaliation against any Associated Person who made a good-faith report.

No Associated Person may serve on the board of directors of any publicly traded company without prior written permission by the CCO. Access Persons are prohibited from accepting compensation for services from outside sources without specific prior written permission.

Personal Trading Policies

These policies apply to all Covered Accounts — those owned or controlled by an Access Person or members of their Family/Household, accounts in which an Access Person exercises investment discretion, and any account in which the Access Person has a beneficial interest.

Reporting Requirements

Annual Holdings Reports: By January 31st of each year, you must complete an Annual Holdings Report to the CCO listing all Covered Securities in which you (or a member of your Family/Household) had Beneficial Ownership as of December 31st of the prior year, along with all brokers, dealers and banks where accounts were maintained.

Client Priority

Clients must always receive the best price, in relation to employees, on same-day adviser-directed transactions. Employees must first give priority on all purchases and sales of securities to Developing Financial’s clients, prior to executing transactions for their proprietary accounts.

Private Placements and IPOs

No employee may acquire, directly or indirectly, Beneficial Ownership of any security in a private placement or an initial public offering without the prior approval of the CCO.

Insider Trading

All Associated Persons are prohibited from trading or recommending trading in securities for any account (personal or client) while in possession of material, Non-Public Information about the issuer of the securities, and from communicating material, Non-Public Information about the issuer of any securities to any other person.

Any Associated Person who possesses or believes they may possess material, Non-Public Information about any issuer of securities must report the matter immediately to the CCO.

Sanctions and Certification

All disciplinary responses to violations of the Code shall be administered by the CCO, subject to approval by the President of Developing Financial. All Associated Persons are required to annually certify their understanding and continuing acceptance of, as well as an agreement to abide by, the guidelines and policies set forth herein.