Code of Ethics

Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws.

A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to [email protected] or by calling us at 312-982-5059.

FinacleAI and our personnel owe a duty of loyalty, fairness and good faith towards our customers and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code.

Our Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any particular access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity.

Recommendations Involving Material Financial Interest

The Firm has no material financial interest in recommending any specific stock or ETF.

Participation or Interest in Client Securities

The firm and people supervised by the firm, including Investment Adviser Representatives (“employees”), may hold positions in the same securities as the firm’s customers and may themselves follow the recommendations of the Firm. As a result, at times it may be possible for a trading signal to benefit the Firm or its employees more than the client. To manage this potential conflict of interest, the firm has adopted the following principles governing personal investment activities of its employees:

No principal, employee, agent or Investment Adviser

Representative of our firm may put his or her own interest above the interest of an advisory client.

• Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of customers and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts.

• FinacleAI’s trading signals and recommendations are generated by an automated system, and in some cases, Finacle’s AI Trader which is a completely black box system.

• Principals or employees of the Firm that follow the Firm’s trading recommendations simultaneously with the Firm’s customers may make individual decisions on how long to keep a position but this has no effect on the performance of the Firm’s AI systems and automated recommendations.

Participation or Interest in Client Transactions

In the normal course of business customer market positions may occur alongside the positions of the Firm or its employees. We have implemented policy restrictions with respect to transactions in accounts of the firm and its employees, including accounts which an employee may have control or a beneficial interest, including:

• FinacleAI’s trading signals and recommendations are generated by an automated system, and in other cases, Finacle’s AI Trader which is a completely black box system.

• Principals and employees of the Firm do not receive any trading signals or market recommendations before customers. In the event that they do, they are prohibited from executing trades until the recommendations and signals have been passed to the customers.

• We maintain a list of all reportable securities holdings for our firm and anyone associated with this advisory practice that has access to advisory recommendations ("access person"). These holdings are reviewed on a regular basis by our firm's Chief Compliance Officer or his/her designee.