CODE OF ETHICS

As required by Rule 204A-1 of the Investment Advisers Act of 1940, Vukota Capital Management, LLC (“VCM”) has adopted a Code of Ethics that sets forth the basic policies of ethical conduct for all officers and employees of the firm. The Code of Ethics describes the firm’s fiduciary duties and obligations to investors, and sets forth VCM’s practice of supervising the personal securities transactions of employees who maintain access to investor information.

All employees will act with competence, dignity, integrity, and in an ethical manner, when dealing with investors, the public, prospects, third-party service providers and fellow employees. You must use reasonable care and exercise independent professional judgment when conducting investment analysis, promoting VCM’s products and services, and engaging in other professional activities.

We expect all employees to adhere to the highest standards with respect to any potential conflicts of interest with investors. As a fiduciary, VCM must act in its investors’ best interests. Neither VCM, nor any employee should ever benefit at the expense of any investor.

VCM collects and maintains records of securities holdings and transactions made by employees. The firm reviews the personal trading practices of its employees to identify and resolve any potential or realized conflicts of interest.

Upon request, VCM will furnish investors with a copy of the Code of Ethics.