Code of Ethics

Overview

Vetta Investments LLC maintains a comprehensive Code of Ethics in compliance with Rule 204A-1 under the Investment Advisers Act of 1940. This Code establishes standards of conduct for all supervised persons of the firm and addresses potential conflicts of interest.

Standards of Business Conduct

All supervised persons of Vetta Investments are required to:

• Place the interests of clients ahead of their own personal interests
• Conduct all personal securities transactions in compliance with the Code
• Avoid taking inappropriate advantage of their position
• Maintain the confidentiality of client information
• Act with competence, dignity, integrity, and in an ethical manner

Personal Trading Policy

Vetta maintains strict policies governing personal securities transactions by supervised persons. These policies are designed to prevent conflicts of interest between the firm's investment recommendations and personal trading activities. All personal trading is subject to pre-clearance requirements and reporting obligations.

Reporting Requirements

All supervised persons are required to provide initial and annual holdings reports, as well as quarterly transaction reports for personal securities accounts. These reports are reviewed by the Chief Compliance Officer to ensure compliance with the Code.

Gifts and Entertainment

The Code includes provisions governing the receipt of gifts and entertainment from persons doing business with or on behalf of clients. These provisions are designed to prevent conflicts of interest and ensure that investment decisions are made solely in the best interests of clients.

Violations and Sanctions

Any violation of the Code of Ethics may result in sanctions including, but not limited to, disgorgement of profits, suspension, termination, and referral to regulatory authorities. All supervised persons are required to promptly report any violations of the Code.