Code of Ethics

HSA has adopted a Code of Ethics (the “Code”) which establishes policies and procedures to handle potential conflicts of interest that may arise from providing advisory services to its clients. HSA’s Code recognizes that HSA is a fiduciary and is designed so that HSA meets its fiduciary obligation to its clients by setting forth standards of conduct for its officers and employees (“Supervised Persons”). Among other things, HSA’s Code requires that HSA maintain the confidentiality of client information; prohibits insider trading; prohibits acceptance of gifts or entertainment that exceed our policy standards; requires the reporting of gifts and entertainment by certain of HSA’s employees; and requires that certain employees report all of their personal securities transactions.  HSA allows Supervised Persons to purchase or sell the same securities that may be recommended to clients. HSA does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. HSA does not have a material interest in any securities traded in client accounts. Owning the same securities that are recommended (purchase or sell) to clients presents a conflict of interest that, as fiduciaries, must be disclosed and mitigated through policies and procedures.

As noted above, the Advisor has adopted the Code to address insider trading (material nonpublic information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its clients
can potentially be violated if personal trades are made with more advantageous terms than client trades, or by trading based on material non-public information. This risk is mitigated by HSA requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies
and procedures to detect the misuse of material, non-public information.