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Code of Ethics

A. Code of Ethics

All employees of HSAX must act in an ethical and professional manner. In view of the foregoing and applicable provisions of relevant law, HSAX has determined to adopt a Code of Ethics to specify and prohibit certain types of transactions deemed to create conflicts of interest (or at least the potential for or the appearance of such a conflict), and to establish reporting requirements and enforcement procedures relating to personal trading by HSAX personnel. HSAX’s Code of Ethics, which specifically deals with professional standards, insider trading, personal trading, gifts and entertainment, and fiduciary duties, establishes ideals for ethical conduct based upon fundamental principles of openness, integrity, honesty, and trust. HSAX will provide a copy of its Code of Ethics to any client or prospective client upon request.

B. Participation of Interest in Client Transactions

HSAX does not recommend or effect transactions in securities which any related person may have material financial interest.

C. Proprietary Trading

At times, HSAX and/or its affiliated persons may buy or sell securities for their own accounts that we have also recommend to clients. HSAX will always document any transactions that could be construed as conflicts of interest. To mitigate or remedy any conflicts of interest or perceived conflicts of interest, we will monitor our proprietary and personal trading reports for adherence to our Code of Ethics.

D. Simultaneous Trading

From time to time, representatives of HSAX may buy or sell securities for themselves at or around the same time as clients. In any instance where similar securities are being bought or sold, we will uphold our fiduciary duty by always transacting on behalf of our client before transacting for our own benefit.

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