Purpose.

TetraHomes maintains a Code of Ethics that governs the conduct of all employees, officers, and access persons. The Code is designed to protect clients and investors, prevent conflicts of interest, and reflect the fiduciary standard that governs registered investment advisers.

Personal securities transactions.

Access persons must pre-clear certain personal securities transactions, report holdings and transactions on a periodic basis, and refrain from trading in restricted securities. A restricted list is maintained and updated by the Chief Compliance Officer.

Gifts and entertainment.

Gifts and entertainment given or received in connection with firm business are subject to a de minimis threshold and mandatory reporting. Cash and cash equivalents are prohibited.

Outside business activities.

All outside business activities must be disclosed and pre-approved. Serving as a director of another company requires written approval.

Political contributions.

Political contributions are subject to pre-clearance procedures designed to comply with the pay-to-play rules under Rule 206(4)-5.

Reporting violations.

Employees are required to report suspected violations. Retaliation against reporters is prohibited (see the Whistleblower Policy).

This policy is provided for informational and disclosure purposes. It may be amended from time to time. For the current version, contact [email protected].