RS Crum Inc. believes that we owe clients the highest level of trust and fair dealing. As part of our fiduciary duty, we place the interests of our clients ahead of the interests of the Firm and our personnel.

RS Crum Inc.’s personnel are required to conduct themselves with integrity and follow the principles and policies detailed in our Code of Ethics.

RS Crum Inc.’s Code of Ethics attempts to address specific conflicts of interest that either we have identified or that could likely arise. Our personnel are required to follow clear guidelines from the Code of Ethics in areas such as gifts and entertainment, other business activities, prohibitions of insider trading, and adherence to applicable state and federal securities laws. Additionally, individuals who formulate investment advice for clients, or who have access to nonpublic information regarding any clients’ purchase or sale of securities, are subject to personal trading policies governed by the Code of Ethics (see below).

RS Crum Inc. and its affiliates may trade for their own accounts in securities, which are recommended to and/or purchased for RS Crum Inc.’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of RS Crum Inc. will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts.

The Code of Ethics requires pre-clearance of many employee transactions, and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between RS Crum Inc. and its clients. The Chief Compliance Officer of RS Crum Inc. is Daniel Sexton. He reviews employee trades each quarter, except for his own trading activity that is reviewed by another principal or officer of the Firm. Under the Code of Ethics, certain classes of securities (i.e., open-end mutual funds and U.S.

Government Securities) have been designated as exempt transactions, based upon a determination that trading in these would not materially interfere with the best interest of RS Crum Inc.’s clients.

RS Crum Inc.’s clients or prospective clients may request a copy of the Firm's Code of Ethics by contacting our office.