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Code of Ethics

This Code of Ethics (the Code) expresses the policies and procedures of Cambridge Investment Research Advisors, Inc. a federally registered investment adviser (CIRA). It is enforced to ensure that no one is taking advantage of their position, or even giving the appearance of placing their own interests above that of the accounts, clients, and shareholders we are serving. In this regard, Section 204A of the Investment Advisers Act of 1940 (“Act”) requires investment advisers to establish, maintain, and enforce policies designed to prevent the misuse of non-public information by the investment advisor and its supervised persons. Moreover, Section 206 of the Act, among other things, prohibits investment advisers from engaging in any device, scheme, or artifice to defraud any existing or prospective client. In compliance with Sections 204A and 206 of the Act, this Code of Ethics contains provisions reasonably necessary to eliminate the possibility of the misuse of
non–public information and/or fraud against any existing or prospective client. This Code also prohibits all supervised persons from trading in any securities listed on the Restricted Trading List without prior written approval.

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