Horizons West Capital Partners, LLC

Code of Ethics

As a holder in good standing of the Chartered Financial Analyst (CFA) designation and a current member of the CFA Institute, Mr. MacNamara is bound to uphold the CFA Institute Code of Ethics and Standards of Professional Conduct. All current and future associates of HWCP who are CFA Institute members and/or CFA candidates must also abide by the Code and Standards.

HWCP is also adopting the Asset Manager Code of Professional Conduct as published by the CFA Institute in its entirety. The Code is a fully encompassing protocol that governs all aspects of the investment management relationship between investment advisory providers and clients. The Code sets forth a standard of business conduct that fulfills the objectives of Sections 204A, 204-2, and 206 of the Investment Advisor Act of 1940.

The five main areas of broad application that govern asset managers who adopt the Code in its entirety are:

1. Loyalty To Clients
2. Investment Process & Actions
3. Trading
4. Compliance & Support
5. Performance & Valuation

All current and prospective clients will be provided upon request with a copy of the CFA Institute Code of Ethics and Standards of Professional Conduct and the Asset Manager Code of Professional Conduct as adopted by HWCP. A copy of both documents will be attached to all Investment Advisory agreements for new clients.

CFA Institute Required Disclaimer

Horizons West Capital Partners claims compliance with the CFA Institute Asset Manager Code of Professional Conduct. This claim has not been verified by CFA Institute.