Exhibit p under Form N-1A
Exhibit 99 under Item 601/Reg. S-K
4 WINDS FAMILY OF FUNDS
CODE OF ETHICS FOR ACCESS PERSONS
4 WINDS FAMILY OF FUNDS
CODE OF ETHICS REGARDING PERSONAL SECURITIES TRADING
Pursuant to rule 17j-1 under the Investment Company Act of 1940, this Code of
Ethics has been adopted on behalf of 4 Winds Family of Funds.*
1. GENERAL FIDUCIARY PRINCIPLES
a) Each Access Person:
i) must place the Funds' interests ahead of the Access Person's personal
interests;
ii) must avoid conflicts or apparent conflicts of interest with the Funds; and
iii) must conduct his or her personal transactions in a manner which neither
interferes with Fund portfolio transactions nor otherwise
takes unfair or inappropriate advantage of the Access Person's
relationship to the Fund.
The failure to recommend or purchase a Covered Security for the
Fund may be considered a violation of this Code.
b) Every Access Person must adhere to these general fiduciary
principles, as well as comply with the specific provisions and
Associated Procedures of this Code. TECHNICAL COMPLIANCE WITH THE
TERMS OF THIS CODE AND THE ASSOCIATED PROCEDURES MAY NOT BE
SUFFICIENT WHERE THE TRANSACTIONS UNDERTAKEN BY AN ACCESS PERSON
SHOW A PATTERN OF ABUSE OF THE ACCESS PERSON'S FIDUCIARY DUTY.
2. DEFINITIONS
a) The "1940 Act" means the Investment Company Act of 1940, as amended.
b) "Access Person" means any director, trustee, officer, managing
general partner, or general partner.
c) "Associated Procedures" means those policies, procedures and/or
statements that have been adopted by the Fund, and which are
designed to supplement this Code and its provisions.
d) "Beneficial ownership" will be attributed to an Access Person in all
instances where the Access Person (i) possesses the ability to purchase or
sell the Covered Securities (or the ability to direct the disposition of
the Covered Securities); (ii) possesses voting power (including the power
to vote or to direct the voting) over such Covered Securities; or (iii)
receives any benefits substantially equivalent to those of ownership.
Beneficial ownership shall be interpreted in the same manner as it would be
in determining whether a person is subject to the provisions of Section
16a-1(a)(2) of the Securities Exchange Act of 1934, and the rules and
regulations thereunder, except that the determination of direct or indirect
beneficial ownership shall apply to all Covered Securities which an Access
Person has or acquires.
e) "Control" shall have the same meaning as that set forth in Section
2(a)(9) of the 1940 Act.
f) Except as provided in this definition, "Covered Security" shall include any
Security, including without limitation: equity and debt securities;
derivative securities, including options on and warrants to purchase equity
or debt securities; shares of closed-end investment companies; investments
in unit investment trusts; and Related Securities. "Related Securities" are
instruments and securities that are related to, but not the same as, a
Covered Security. For example, a Related Security may be convertible into a
Covered Security, or give its holder the right to purchase the Covered
Security. For purposes of reporting, "Covered Security" shall include
futures, swaps and other derivative contracts.
"Covered Security" shall not include: direct obligations of the
Government of the United States (regardless of their maturities);
bankers' acceptances; bank certificates of deposit; commercial
paper; high quality short-term debt instruments, including
repurchase agreements; and shares of registered open-end investment
companies.
g) "Disinterested director" means a director, trustee, or managing
general partner of the Fund who is not an "interested person" of the
Fund within the meaning of Section 2(a)(19) of the 1940 Act.
h) "Fund" means 4 Winds Family of Funds, an investment company
registered under the 1940 Act (and any series or portfolios of such
company).
i) "Initial Public Offering" means an offering of securities registered
under the Securities Act of 1933, the issuer of which, immediately
before the registration, was not subject to the reporting
requirements of sections 13 or 15(d) of the Securities Exchange Act
of 1934.
j) "Private Placement" or "limited offering" means an offering that is
exempt from registration under Section 4(2) or Section 4(6) of the
Securities Act of 1933 or pursuant to rule 504, rule 505 or rule 506
under the Securities Act of 1933.
k) "Purchase or sale of a Covered Security" includes, INTER ALIA, the
writing of an option, future or other derivative contract to
purchase or sell a Covered Security.
l) "Security" shall have the meaning set forth in Section 2(a)(36) of the 1940
Act.
3. EXEMPT TRANSACTIONS
The prohibitions or requirements of Section 4 and Section 5 of this Code
shall not apply to:
a) Purchases or sale of the following Securities:
i) direct obligations of the Government of the United States
(regardless of their maturities). This exemption does not
apply to indirect obligations of the U.S. Government,
including FNMAs, GNMAs or FHLMCs.
ii) bankers' acceptances;
iii) bank certificates of deposit;
iv) commercial paper;
v) high quality short-term debt instruments, including repurchase agreements;
and vi) shares of registered open-end investment companies.
b) Purchases or sales effected in any account over which the Access
Person has no direct or indirect influence or control.
4. PROHIBITED TRANSACTIONS AND ACTIVITIES
a) Every Access Person is prohibited from acquiring any Security
distributed in an initial public offering; however, subject to
provisions of this Code and its Associated Procedures, an Access
Person may acquire the security in the secondary market.
b) Every Access Person is prohibited from acquiring any Security in a
private placement or other limited offering, without the express
prior approval of the Fund's President or his designee.
c) Every Access Person is prohibited from executing a personal
transaction in any Covered Security on a day during which the Fund
has a pending "buy" or "sell" order for that Covered Security, until
the Fund's orders are either executed or withdrawn.
d) Every Access Person is prohibited from profiting in the purchase and sale,
or sale and purchase, of the same (or equivalent) Covered Security within
60 calendar days. For purposes of this prohibition, each personal
transaction in the Covered Security will begin a new 60 calendar day
period. As an illustration, if an Access Person purchases 1000 shares of
Omega Corporation on June 1st, 500 shares on July 1st, and 250 shares on
August 1st, the profit from the sale of the 1000 shares purchased on June
1st is prohibited for any transaction prior to October 1st (i.e., 60
calendar days following August 1st). In circumstances where a personal
transaction in a Covered Security within the proscribed period is
involuntary (for example, due to unforeseen corporate activity, such as a
merger), the Access Person must notify the Fund's President or his
designee.
In circumstances where an Access Person can document personal
exigencies, [Name of Person or Department] may grant an exemption
from the prohibition of profiting in the purchase and sale, or sale
and purchase, of the same (or equivalent) Covered Security within 60
calendar days. Such an exemption is wholly within the discretion of
the Fund's President or his designee, and any request for such an
exemption will be evaluated on the basis of the facts of the
particular situation.
e) Every Access Person is prohibited from purchasing or selling,
directly or indirectly, any Covered Security in which he or she has,
or by reason of such transaction acquires, a direct or indirect
beneficial ownership interest and which he or she knows, or should
have known, at the time of such purchase or sale:
i) is being considered for purchase or sale by the Fund; or
ii) is being purchased or sold by the Fund.
f) Every Access Person is prohibited, in connection with the purchase
or sale, directly or indirectly, by the Access Person of a Security
Held or to be Acquired by the Fund:
i) from employing any device, scheme or artifice to defraud the Fund;
ii) from making any untrue statement of a material fact to the
Fund or omit to state a material fact necessary in order to
make the statements made to the Fund, in light of the
circumstances under which they are made, not misleading;
iii) from engaging in any act, practice or course of business that
operates or would operate as a fraud or deceit on the Fund; or
iv) from engaging in any manipulative practice with respect to the Fund.
Examples of this would include causing the Fund to purchase a
Covered Security owned by the Access Person for the purpose of
supporting or driving up the price of the Covered Security, and
causing the Fund to refrain from selling a Covered Security in an
attempt to protect the value of the Access Person's investment, such
as an outstanding option. One test which will be applied in
determining whether this prohibition has been violated will be to
review the Covered Securities transactions of Access Persons for
patterns. However, it is important to note that a violation could
result from a single transaction if the circumstances warranted a
finding that the provisions of Section 1 of this Code have been
violated.
g) Notwithstanding the other restrictions of this Code to which
Disinterested directors are subject, subparagraphs (a) through (d)
of this Section 4 shall not apply to Disinterested directors.
5. PRE-CLEARANCE REQUIREMENT AND EXEMPTED TRANSACTIONS
a) Every Access Person is prohibited from executing a personal transaction in
any Covered Security (including transactions in pension or profit-sharing
plans in which the Access Person has a beneficial interest), without
express prior approval of the Fund's President or his designee, in
accordance with the Associated Procedures governing pre-clearance. A
purchase or sale of Covered Securities not otherwise approved pursuant to
the Associated Procedures may, upon request made prior to the personal
transaction, nevertheless receive the approval of the Fund's President or
his designee if such purchase or sale would be: only remotely potentially
harmful to the Fund; very unlikely to affect a highly institutional market;
or clearly not related economically to the securities to be purchased, sold
or held by the Fund. Notwithstanding the receipt of express prior approval,
any purchases or sales by any Access Person undertaken in reliance on this
provision remain subject to the prohibitions enumerated in Section 4 of
this Code.
b) The pre-clearance requirement in Section 5(a) SHALL NOT apply to:
i) Purchases or sales which are non-volitional on the part of
either the Access Person or the Fund, subject to the
provisions of Section 4 (g) of this Code.
ii) Purchases which are either made solely with the dividend
proceeds received in a dividend reinvestment plan; or part of
an automatic payroll deduction plan, whereby an employee
purchases securities issued by an employer.
iii) Purchases effected upon the exercise of rights issued by an
issuer PRO RATA to all holders of a class of its Covered
Securities, to the extent such rights were acquired from such
issuer, and any sales of such rights so acquired.
iv) Purchases and sales of a Security that represents an interest
in certain indices as determined by the Fund's President or
his designee.
v) Transactions in a Covered Security which involve the giving of gifts or
charitable donations.
vi) Purchases and sales of Covered Securities executed by a person
deemed to be an Access Person SOLELY by reason of his position
as an Officer and/or Director or Trustee of the Fund.
c) Notwithstanding the other restrictions of this Code to which
Disinterested directors are subject, Section 5 shall not apply to
Disinterested directors.
6. PROHIBITION ON THE RECEIPT OF GIFTS
Every Access Person is prohibited from receiving any gift, favor,
preferential treatment, valuable consideration, or other thing of more
than a DE MINIMIS value in any year from any person or entity from, to or
through whom the Fund purchases or sells Securities, or an issuer of
Securities. For purposes of this Code, "DE MINIMIS value" is equal to $100
or less. This prohibition shall not apply to:
i) salaries, wages, fees or other compensation paid, or expenses
paid or reimbursed, in the usual scope of an Access Person's
employment responsibilities for the Access Person's employer;
ii) the acceptance of meals, refreshments or entertainment of
reasonable value in the course of a meeting or other occasion,
the purpose of which is to hold bona fide business
discussions;
iii) the acceptance of advertising or promotional material of
nominal value, such as pens, pencils, note pads, key chains,
calendars and similar items;
iv) the acceptance of gifts, meals, refreshments, or entertainment
of reasonable value that are related to commonly recognized
events or occasions, such as a promotion, new job, Christmas,
or other recognized holiday; or
v) the acceptance of awards, from an employer to an employee, for recognition
of service and accomplishment.
7.
REPORTING
Every Access Person is required to submit reports of transactions in
Covered Securities to the Fund's President or his designee as indicated
below. Any such report may contain a statement that the report shall not
be construed as an admission by the person making such report that he or
she has any direct or indirect beneficial ownership in the Covered
Security to which the report relates.
INITIAL REPORTING REQUIREMENTS
a) Within 10 calendar days of commencement of employment as an Access
Person, the Access Person will provide a list including:
i) the title, number of shares and principal amount of each
Covered Security in which the Access Person had any direct or
indirect beneficial ownership when the person became an Access
Person;
ii) the name of any broker, dealer or bank maintaining an account
in which any Security was held for the direct or indirect
benefit of the Access Person as of the date of employment as
an Access Person; and
iii) the date the report is submitted to the Fund's President or his designee.
b) Every Access Person is required to direct his broker to forward to
the Fund's President or his designee, on a timely basis, duplicate
copies of both confirmations of all personal transactions in Covered
Securities effected for any account in which such Access Person has
any direct or indirect beneficial ownership interest and periodic
statements relating to any such account.
QUARTERLY REPORTING REQUIREMENTS
c) Every Access Person shall report the information described in
Section 7(d) of this Code with respect to transactions in any
Covered Security (other than those personal transactions in
Securities exempted under Section 3 of this Code) in which such
Access Person has, or by reason of such transaction acquires, any
direct or indirect beneficial ownership.
d) Every report shall be made not later than 10 calendar days after the
end of the calendar quarter in which the transaction to which the
report relates was effected, shall be dated and signed by the Access
Person submitting the report, and shall contain the following
information:
i) the date of the transaction, the title and the number of
shares, the principal amount, the interest rate and maturity
date, if applicable of each Covered Security involved;
ii) the nature of the transaction (i.e., purchase, sale or any other type of
acquisition or disposition);
iii) the price at which the transaction was effected;
iv) the name of the broker, dealer or bank through whom the transaction was
effected; and
v) if there were no personal transactions in any Covered Security
during the period, either a statement to that effect or the
word "None" (or some similar designation).
e) Every Access Person shall report any new account established with a
broker, dealer or bank in which any Security was transacted or held
for the direct or indirect benefit of the Access Person during the
quarter. The report shall include the name of the entity with whom
the account was established and the date on which it was
established.
ANNUAL REPORTING REQUIREMENTS
f) Every Access Person, on an annual basis or upon request of the
Fund's President or his designee, will be required to furnish a list
including the following information (which information must be
current as of a date no more than 30 days before the report is
submitted) within 10 calendar days of the request:
i) the title, number of shares and principal amount of each
Covered Security in which the Access Person had any direct or
indirect beneficial ownership;
ii) the name of any broker, dealer or bank maintaining an account
in which any Covered Security was held for the direct or
indirect benefit of the Access Person; and
iii) the date the report is submitted to the Fund's President or his designee.
g) In addition, every Access Person is required, on an annual basis, to
certify that they have received, read, and understand the provisions of
this Code and its Associated Procedures, and that they recognize that they
are subject to its provisions. Such certification shall also include a
statement that the Access Person has complied with the requirements of this
Code and its Associated Procedures and that the Access Person has disclosed
or reported all personal transactions in Securities that are required to be
disclosed or reported pursuant to the requirements of this Code.
Exemption for Disinterested Directors
h) A Disinterested director is exempt from the "initial reporting
requirements" and "annual reporting requirements" contained in
Section 7.
i) A Disinterested director shall be exempt from the "quarterly reporting
requirements" contained in Section 7, so long as at the time of the
personal transaction in the Covered Security, the Disinterested director
neither knew, nor, in the ordinary course of fulfilling his official duties
as a director of the Fund, should have known that during the 15-day period
immediately preceding or after the date of the transaction in the Covered
Security by the Disinterested director the Covered Security was purchased
or sold by the Fund, or considered for purchase or sale.
8. SANCTIONS
a) Upon discovering a violation of this Code or its Associated
Procedures, the Fund's President or his designee may take such
actions or impose such sanctions, if any, as it deems appropriate,
including, but not limited to:,
i) a letter of censure;
ii) suspension;
iii) a fine;
iv) the unwinding of trades;
v) the disgorging of profits; or
vi) the termination of the employment of the violator.
b) The filing of any false, incomplete or untimely reports, as required
by Section 7 of this Code, may be considered a violation of this
Code.
c) All material violations of this Code and any sanctions imposed with
respect thereto shall be reported to the Board of Directors of the
Fund at least annually.
9. APPLICABILITY
Notwithstanding anything to the contrary contained herein, this Code of
Ethics and the Associated Procedures shall not apply to any Access Person
who is also subject to a code of ethics applicable to the Fund's
investment advisers or principal underwriter. All such persons shall be
subject only to such other code of ethics.
PROCEDURES FOR PRIOR APPROVAL OF PERSONAL
SECURITIES TRANSACTIONS BY ACCESS PERSONS
PROCESS
PRECLEARANCE APPROVAL
a) An Access Person who wishes to effect a personal securities
transaction, whether a purchase, sale, or other disposition, must
preclear the Covered Security prior to engaging in the transaction.
a) When trading options, the Access Person must preclear the underlying
security before entering into the option contract.
b) Based on established criteria, the Fund's President or his designee
determines whether the contemplated transaction should be permitted.
c) Approval is either granted or denied immediately.
d) If approval is denied, the Access Person is given a specific reason
for the denial. The contemplated personal transaction in that
Covered Security is prohibited until prior approval is subsequently
granted.
e) If approval is granted, the Access Person is free to effect the personal
transaction in that Covered Security DURING THAT TRADING DAY ONLY. In this
regard, open orders for more than one trading day (good till cancel) must
be approved daily to comply with the Code. If approval is granted, the
Fund's President or his designee must record the reasons supporting the
approval on the following Personal Transaction Notification form so that
the Fund's President or his designee can maintain a record of all approved
preclearance requests.
f) All trade requests and their dispositions are maintained and
reviewed by the Fund's President or his designee in conjunction with
other information provided by Access Persons in accordance with the
Code.
g) The Fund's President or his designee reviews all exceptions
generated due to a fund trade occurring after preclearance approval
has been granted. The Fund's President or his designee determines
the appropriate action to be taken to resolve each exception.
If extraordinary circumstances exist, an appeal may be directed to the
Fund's President or his designee at (604) 925-8029. Appeals are solely
within the discretion of the Fund's President or his designee.
TRANSACTIONS COVERED AND EXEMPTIONS
These procedures apply to Access Persons' personal transactions in
"Covered Security" as defined in Section 2 of the Code. A Covered Security
includes: equity and debt securities; options and warrants to purchase
equity or debt securities; shares of closed-end investment companies; and
investments in unit investment trusts.
These procedures do NOT apply to contemplated transactions in the
following instruments:
a) direct obligations of the Government of the United States
(regardless of their maturities). This exemption does not apply to
indirect obligations of the U.S. Government, including FNMAs, GNMAs
or FHLMCs.);
b) bankers' acceptances;
c) bank certificates of deposit;
d) commercial paper;
e) high quality short-term debt instruments, including repurchase
agreements; and
f) shares of registered open-end investment companies;
In addition, these procedures do NOT apply to the following transactions:
g) Purchases or sales effected in any account over which the Access Person has
no direct or indirect influence or control;
h) Purchases or sales which are non-volitional on the part of either the
Access Person or the Fund, subject to the provisions of the Code;
i) Purchases which are either (i) made solely with the dividend
proceeds received in a dividend reinvestment plan; or (ii) part of
an automatic payroll deduction plan, whereby an employee purchases
securities issued by an employer;
j) Purchases effected upon the exercise of rights issued by an issuer
PRO RATA to all holders of a class of its Securities, to the extent
such rights were acquired from such issuer, and any sales of such
rights so acquired;
k) Purchases and sales of a Security that represents an interest in certain
indices as determined by the Fund's President or his designee;
l) Transactions in a Covered Security which involve the giving of gifts or
charitable donations; and
m) Purchases and sales of Covered Securities executed by a person
deemed to be an Access Person SOLELY by reason of his position as an
Officer and/or Director or Trustee of the Fund.
SANCTIONS
Failure to comply with the preclearance process may result in any of the
following sanctions being imposed as deemed appropriate by the Fund's
President or his designee:
i) a letter of censure;
ii) suspension;
iii) a fine;
iv) the unwinding of trades;
v) the disgorging of profits; or
vi) the termination of the employment of the violator.
PERSONAL TRANSACTION NOTIFICATION
I, [Name] intend to buy/sell shares of [Name of security] for my personal
account or an account over which I have discretion. I am aware of no conflict
this transaction may pose with 4 Winds Family of Funds.
Signed by:
------------------------------
Date:
------------------------------
________ Approval granted for trading on ______________ because ______________.
________ Approval denied.
Acknowledged by:
------
[person/title]
Date
Broker-Dealer Name
Address
RE: Your Name
Brokerage Account Number: 1234-5678
Dear Sir/Madam:
As an employee of 4 Winds Family of Funds, I am subject to certain
requirements applicable to my personal securities transactions, in
accordance with the Codes of Ethics adopted by the 4 Winds Family of
Funds. Among these requirements is my obligation to provide to 4
Winds Family of Funds duplicate brokerage confirmations and account
statements.
Therefore, I hereby request that you provide duplicate confirmations
and account statements with respect to securities in which I have
any beneficial ownership or interest, including securities held in
street name or in house, family, joint or partnership accounts.
These duplicate account memoranda should occur with respect to all
transactions including, but not limited to, those involving options,
warrants, shares of closed end investment companies and futures
contracts. Please forward this information to:
4 Winds Family of Funds
[Address]
Any questions concerning these matters can be directed to [name] at
[phone number]. Your serious attention to this matter is greatly
appreciated.
Sincerely,
PROCEDURES FOR THE REPORTING AND REVIEW
OF PERSONAL TRANSACTION ACTIVITY
INITIAL REPORTING PROCESS
1. The Fund's President or his designee meets with each new Access Person and
reviews the Code of Ethics and the procedures for preclearing personal
securities transactions.
2. The Access Person is required to complete the "Certification and
Acknowledgment Form" to acknowledge his/her understanding of the Code of
Ethics and return it to the Fund's President or his designee within 10
calendar days.
3. In addition, the Access Person is required to complete the "Personal
Security Portfolio Form" which includes the following information:
a. the title, number of shares and principal amount of each Covered Security
in which the Access Person had any direct or indirect beneficial ownership
when the person became an Access Person;
b. the name and address of any broker, dealer or bank with whom the
Access Person maintained an account in which any Covered Security
was held for the direct or indirect benefit of the Access Person as
of the date of employment as an Access Person; and
c. the date the report is submitted to the Fund's President or his designee.
1. A separate form must be completed for the Access Person and all household
members as defined in Section 2(c) of the Code. The signed form(s) must be
returned to the Fund's President or his designee within 10 calendar days.
2. The Fund's President or his designee maintains current portfolio holdings
information as "initial" holdings.
3. The Fund's President or his designee notifies each broker, dealer or bank
that duplicate confirmations and statements for the Access Person, if
applicable, must be sent to the Fund's President or his designee, effective
immediately.
QUARTERLY REPORTING PROCESS
1. On the first business day after each calendar quarter end, the Fund's
President or his designee sends an e-mail to each Access Person giving
step-by-step instructions on how to complete the quarterly reporting
requirements.
2. Within 10 calendar days of the quarter end, the Access Person is required
to:
a. review for accuracy all Covered Security transactions recorded during the
previous calendar quarter in all personal and household member accounts;
b. review all open account information, including names of brokers, banks and
dealers, addresses and account numbers;
c. notify the Fund's President or his designee of any new accounts established
with brokers, banks or dealers during the quarter and the date the account
was established; and
d. resolve any discrepancies with the Fund's President or his designee.
1. Covered Security transactions executed by any Access Person during the
calendar quarter are reviewed by the Fund's President or his designee
periodically throughout the quarter.
2. The Fund's President or his designee issues memos to each Access Person if
any transactions he or she has executed during the quarter have been deemed
to be either exceptions to or violations of the Code's requirements.
3. Based on the activity and the responses to the memos, the Fund's President
or his designee may impose any of the sanctions identified in Section 8.
ANNUAL REPORTING PROCESS
1. At least annually, the Fund's President or his designee requires that each
Access Person read the Code and certify and acknowledge his/her understanding
of the Code and its requirements.
2. This re-certification is required to be completed within 10 calendar days of
the request. The Fund's President or his designee monitors compliance with
this requirement.
3. At the same time, the Fund's President or his designee provides each Access
Person with a current list of securities held in the Access Person's
account(s).
4. Within 10 calendar days of the request, the Access Person is required to:
a. review for accuracy all securities held in all personal accounts, including
the title, number of shares and principal amount of each Covered Security
in which the Access Person had any direct or indirect beneficial ownership;
b. review all open account information, including names of brokers, banks and
dealers, addresses and account numbers;
c. notify the Fund's President or his designee of any new accounts established
with brokers, banks or dealers; and
d. resolve any discrepancies with the Fund's President or his designee.
REPORTING TO THE BOARD OF TRUSTEES
1. Each quarter, the Fund's President or his designee reports any violations
of the Code to the Board of Trustees. Violations of the Code include:
a) failure to preclear a transaction;
b) failure to complete the initial, quarterly or annual reporting
requirements timely, regardless of whether the Access Person
executed any transactions;
c) recognition of a profit on the sale of a security held less than 60 days;
d) failure to comply with the receipt of gifts requirements; and
e) any trends or patterns of personal securities trading which are
deemed by the Fund's President or his designee to be violations of
the Code.
2. The Fund's President or his designee provides the Board with the name of
the Access Person; the type of violation; the details of the
transaction(s); and the types of sanctions imposed, if any.
RECORDKEEPING REQUIREMENTS
The Fund's President or his designee maintains the following books and records
for a period no less than 6 calendar years:
a) a copy of the Code of Ethics;
b) a record of any violation of the Code of Ethics and any action taken as a
result of the violation;
c) a copy of each report made by an Access Person, including initial,
quarterly and annual reporting;
d) a record of all Access Persons (current and for the past five years);
e) a record of persons responsible for reviewing reports; and
f) a copy of any supporting documentation used in making decisions
regarding action taken by the Fund's President or his designee with
respect to personal securities trading.
