Employee Account Dealing Acknowledgement

Employee Account Dealing Acknowledgement

Employee Information

Employee Name:   Employee ID:

Position Information

Scope and Purpose

This acknowledgement sets forth the rules, restrictions and reporting obligations applicable to Employees concerning dealings in accounts and securities where such dealings could create a conflict of interest with the Company or its clients (the "Policy"). The Policy applies to all Employees and covers personal accounts, family accounts and any accounts over which the Employee has investment discretion or beneficial interest.

Definitions

"Account" means any brokerage, investment, retirement, or similar account held or controlled by Employee or by Close Family Members. "Material Nonpublic Information" means information that is not generally available to the public and that a reasonable investor would consider important in making an investment decision.

Employee Obligations and Restrictions

The Employee agrees to comply with the following obligations and acknowledges that violations may result in disciplinary action up to and including termination, restitution and legal action.

1. Prohibition on Personal Dealing: Employee shall not trade in any Account or security when in possession of Material Nonpublic Information obtained as a result of employment. Employee shall not engage in proprietary trading that competes with, or is adverse to, any client or the Company.

2. Pre-Clearance: Employee must obtain written pre-clearance from the Compliance Officer or designated approver prior to initiating any transaction in securities covered by this Policy when pre-clearance is required by the Company.

3. Reporting: Employee must disclose all personal accounts with custodians and provide account numbers (last four digits) for monitoring and recordkeeping.

Disclosures and Exceptions

If no such holdings or accounts exist, check the box below.

I certify that I have no holdings, accounts or relationships to disclose under this Policy.

Pre-Clearance & Reporting Procedures

To request pre-clearance, complete the required Compliance pre-clearance form and obtain written approval prior to placing an order. Post-transaction reports must be submitted within the timeframe required by Compliance.

Employment History (Most Recent)

Employment History (Previous)

Education

References

Legal Disclosures and Authorizations

At-Will Employment: Nothing in this acknowledgement alters the at-will employment relationship. Either the Employee or the Company may terminate employment at any time, with or without cause or notice, subject to applicable law.

Equal Opportunity: The Company maintains an equal employment opportunity policy and expects Employees to comply with Company policies and applicable law.

By checking the box below, I authorize the Company to contact prior employers and conduct background, credit and regulatory checks to the extent permitted by law for the purpose of verifying the information I have provided and assessing compliance with account dealing restrictions.

I authorize contact with prior employers and background checks as described above.

Applicant/Employee Certification

I certify that all information provided in this acknowledgement and accompanying documentation is true, complete and accurate to the best of my knowledge. I understand that omission, misstatement or failure to disclose relevant ownership or account information constitutes a violation of Company policy and may result in disciplinary action, including termination.

I further acknowledge receipt of the Company’s account dealing Policy, understand my obligations under the Policy, and agree to comply with all pre-clearance, reporting and recordkeeping requirements.

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