Core Planning, LLC (“CP”) has adopted a code of ethics that satisfies SEC Rule 204A-1 with the goal to:

• Set forth standards of conduct expected of all supervised persons (including compliance with federal securities laws);
• Safeguard material non-public information about client transactions; and
• Require “access persons” to report their personal securities transactions. In addition, the activities of an investment adviser and its personnel must comply with the broad anti-fraud provisions of Section 206 of the Advisers Act.

Our Code

As an investment advisory firm, we have an overarching fiduciary duty to our clients, as outlined in Section 206 of the Investment Advisers Act of 1940. They deserve our undivided loyalty and effort, and their interests come first. We have an obligation to uphold that fiduciary duty and to ensure that we do not take inappropriate advantage of our position and the access to information that comes with our position.

All of us are accountable for adhering to the following general standards to the best of our knowledge and ability:

• Always place the interest of the clients first and never benefit at the expense of clients;
• Always act in an honest and ethical manner, including in connection with the handling and avoidance of actual or potential conflicts of interest between personal and professional relationships;
• Always maintain the confidentiality of information concerning the identity of security holdings and financial circumstances of clients;
• Fully comply with applicable laws, rules and regulations of federal, state and local governments and other applicable regulatory agencies; and
• Proactively promote ethical and honest behavior within the firm including, without limitation, the prompt reporting of violations of, and being accountable for adherence to, this Code of Ethics.

Failure to comply with this Code of Ethics may result in disciplinary action, up to and including termination of employment.

Definitions