Terms and Conditions

SN Capital Management business is subject to extensive government regulation and control. SN Capital Management and its employees must comply with applicable laws, rules, and regulations, including those related to insider trading.

Conflicts of interest may arise when an individual's private interests conflict, or appear to conflict, with those of SN Capital Management, or when an employee's or our interests conflict with the interests of a customer or potential customer, thereby jeopardizing the interests of SN Capital Management or others. Some of our customers may be harmed, for example, if an employee takes an action or pursues an interest that makes it difficult for him or her to objectively and effectively fulfill his or her obligations to SN Capital and customers, or if an employee or a person related to the employee, including but not limited to a family member or household member of the employee, receives an improper personal benefit, such as money or loan, as a result of his or her position at SN Capital. SN Capital Management has policies, procedures, and controls to manage conflicts of interest. Employees must comply with these and other compliance-related policies, procedures, and controls and mitigate potential conflicts of interest by adhering to the following standards of conduct:

Act solely in the best interests of our clients

Adhere to SN Capital Management's high ethical and professional standards

Identify, report, and manage actual, apparent, or potential conflicts of interest

Disclose all conflicts of interest fully and fairly, as appropriate.

Conflicts of interest are not always clear, and it is impossible to describe all situations in which a conflict may arise. All questions regarding whether a conflict of interest exists and about actual or potential conflicts of interest should be referred to your Manager and L&C.

Employees and directors who have access to confidential information about SN, its clients, or issuers in which we invest client assets are prohibited from using or disclosing that information for securities trading purposes or any other purpose, except as required by law for our business. All non-public information about SN or our clients or issuers is considered "Confidential Information." Using material non-public information in connection with any investment decision or recommendation, or providing "tips" to others who may make investment decisions based on that information, is unethical and illegal, and may subject you to civil and/or criminal liability and/or penalties.

Employees must act in the best interest of their customers and consider SN Capital Management's reputation when accepting or offering gifts or entertainment. Employees are prohibited from offering, promising, giving or accepting, or permitting others to offer, promise, give, or accept, anything of value, directly or indirectly, to improperly obtain or retain business or to obtain an improper business advantage. In addition, the provision of gifts and entertainment, including meals, transportation, and lodging, to public officials is subject to strict laws (including criminal laws). Employees are prohibited from giving gifts or items of value to public officials or their employees or family members with the intent of obtaining or retaining business or obtaining a business advantage in connection with SN Capital Management’s business.

Employees must pre-approve political contributions.

Employees and Directors:

. May not pursue personal opportunities arising from the use of company property, information, or position without L&C’s consent

. May not use company property, information, or position for improper personal gain

. May not compete directly or indirectly with SN Capital

· SN Capital Management must pursue its legitimate interests when the opportunity arises.

SN Capital Management employees and directors are subject to a duty of confidentiality to SN and its customers. Confidential information includes non-public information that may benefit a competitor or that, if disclosed, may harm SN Capital or its customers, as well as non-public information entrusted to SN Capital Management by customers and other parties. The obligation to protect confidential information remains even after the employment relationship has ended. This obligation does not prevent employees from reporting possible violations of law to supervisory authorities or disclosing information under whistleblower provisions.

All employees are required to report any illegal or unethical conduct they become aware of, including accounting or auditing issues. SN Capital Management will not punish or discriminate against employees for good faith reports. Employees have the right to contact supervisory authorities directly and may do so anonymously. Employees may, in any case, make protected disclosures under whistleblower laws and voluntarily cooperate with regulators without fear of retaliation by SN Capital.