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CODE OF ETHICS RULE 17j1 This Code of Ethics (this Code) has been adopted by the Boards of the Company in accordance with Rule 17j1 under the 1940 Act. Terms that are capitalized in this Code and
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How to Fill Out Code of Ethics:

01
Start by conducting research: Before filling out a code of ethics, it's important to gather information about ethical guidelines and standards relevant to your industry or organization. Research various sources, such as professional organizations or regulatory bodies, to understand the best practices and expectations.
02
Define your organization's values: Determine the fundamental principles and values that guide your organization. These could include integrity, accountability, respect, fairness, or any other core values that are important to your organization's culture and mission. Articulate these values clearly to ensure they align with the code of ethics.
03
Identify potential ethical dilemmas: Consider the possible ethical dilemmas and challenges that employees or stakeholders might encounter within your organization. This could include conflicts of interest, confidential information, decision-making processes, or relationships with clients or customers. Anticipating these situations will help you address them in the code of ethics.
04
Create clear policies and guidelines: Develop specific policies and guidelines that outline the expected ethical behavior for everyone in the organization. These policies should cover a wide range of areas, such as conflicts of interest, bribery, discrimination, whistleblowing, privacy, and more. Each policy should be clearly worded and provide examples or scenarios to help employees understand the expected conduct.
05
Seek input and feedback: Involve employees, stakeholders, and relevant experts in the process of filling out the code of ethics. This can be done through surveys, focus groups, or consultation meetings. Encourage open communication and listen to different perspectives to ensure the code of ethics reflects the collective values of the organization and is practical to implement.
06
Review and revise: Regularly review and update the code of ethics to ensure it remains relevant and effective. Keep an eye on changes in regulations, industry standards, and societal expectations. Seek feedback from employees and stakeholders to identify areas for improvement or any emerging ethical dilemmas that need to be addressed.

Who Needs Code of Ethics:

01
Organizations: Code of ethics are essential for organizations of all sizes and types, including businesses, nonprofits, government agencies, and educational institutions. These codes provide a framework for guiding ethical behavior within the organization and promoting a positive and ethical work culture.
02
Employees: Employees at all levels within an organization need a code of ethics to understand the expectations and standards of conduct. It helps them navigate ethical challenges they may encounter during their day-to-day work, promoting integrity and responsible decision-making.
03
Stakeholders and Partners: Code of ethics can also apply to stakeholders and partners of an organization. These may include clients, customers, vendors, suppliers, shareholders, or any external individuals or entities that interact with the organization. Having a code of ethics helps establish trust, transparency, and a shared understanding of ethical expectations in these relationships.
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Code of ethics is a set of principles and rules that govern the behavior of individuals in a particular organization or profession.
Certain organizations and professions may require individuals to file a code of ethics.
Code of ethics can be filled out by carefully reviewing the guidelines and principles set by the organization or profession.
The purpose of a code of ethics is to ensure that individuals act ethically and responsibly in their professional roles.
Code of ethics may require individuals to report any conflicts of interest, gifts received, and other ethical considerations.
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