Common use of Policies and Procedures of the Trust Clause in Contracts

Policies and Procedures of the Trust. Conduct a detailed review of the Trust's Compliance Program pertaining to compliance by registered investment companies with the Federal Securities Laws, among other things: 1. Pricing of portfolio securities and Fund shares, with a focus on the following items within the pricing polices and procedures: (a) monitoring for circumstances that may necessitate the use of fair value prices; (b) establishing criteria for determining when market quotations are no longer reliable for a particular portfolio security; (c) providing a methodology or methodologies by which the Funds determine the current fair value of their portfolio securities; and (d) reviewing the appropriateness and accuracy of the methodology used in valuing securities, including making any necessary adjustments. 2. Processing of Fund shares, with a focus on the following items: (a) segregation of investor orders received before the Funds price their shares from those that were received after the Funds price their shares; and (b) methodology used by the Funds to protect themselves and their shareholders against late trading. 3. Identification of affiliated persons to ensure that any transactions with affiliated persons are executed in compliance with the 1940 Act. 4. Protection of nonpublic information, including: (a) prohibitions against trading portfolio securities on the basis of information acquired by analysts or portfolio managers employed by the Trust or the Funds' investment adviser ("Adviser") or the Funds' investment subadviser ("Subadviser") ; (b) disclosure to third parties of material information about the Funds' portfolio holdings, trading strategies or pending transactions; and (c) purchase or sale of Fund shares by the personnel of the Trust or the Adviser or Subadviser based on material, nonpublic information about the Funds' portfolios. 5. Compliance with Fund governance requirements, including the procedures to guard against: (a) an improperly constituted Board of Trustees ("Board"); (b) failure of the Board to properly consider matters entrusted to it; and (c) failure of the Board to request and consider information required by the 1940 Act from the Trust and other Service Providers. 6. The excessive short-term trading of mutual fund shares that may be harmful to the Funds, including a focus on the following areas: (a) consistency of policies and procedures with the Funds' disclosed policies regarding market timing; (b) monitoring of shareholder trades or flows of money in and out of the Funds in order to detect market timing activity; (c) enforcement of the Funds' policies regarding market timing; (d) prevention of waivers that would harm the Funds or their shareholders, or subordinate the interests of the Funds or their shareholders to those of the Trust or any other affiliated person or associated person of the Trust; and (e) reporting to the Trust's Board regarding all waivers granted, so that the Board can determine whether such waivers were proper. 7. The distribution, marketing and advertising of the Funds' shares. 8. The trading of portfolio securities by the Funds, including a focus on enforcement of the Trust's policies with respect to brokerage, soft dollars and allocation of trades. 9. The review of any electronic mail communications.

Policies and Procedures of the Trust. Conduct a detailed review of the Trust's ’s Compliance Program pertaining to compliance by registered investment companies with the Federal Securities Laws, among other things: 1. Pricing of portfolio securities and Fund shares, with a focus on the following items within the pricing polices policies and procedures:: 2 “Federal Securities Laws” are defined by the Rule as the Securities Act of 1933, the Securities Exchange Act of 1934, the Sxxxxxxx-Xxxxx Act of 2002, the Investment Company Act of 1940, the Investment Advisers Act of 1940, Title V of the Gxxxx-Xxxxx-Xxxxxx Act, any SEC rules adopted under any of the foregoing laws, the Bank Secrecy Act, as it applies to registered investment companies, and any rules adopted thereunder by the SEC or the Department of Treasury. (a) monitoring for circumstances that may necessitate the use of fair value prices; (b) establishing reviewing criteria for determining when market quotations are no longer reliable for a particular portfolio security; (c) providing a methodology or methodologies by which the Funds determine the current fair value of their portfolio securities; and (d) reviewing the appropriateness and accuracy of the methodology used in valuing securities, including making any necessary adjustments. 2. Processing of Fund shares, with a focus on the following items: (a) segregation of investor orders received before the Funds price their shares from those that were received after the Funds price their shares; and (b) methodology used by the Funds to protect themselves and their shareholders against late trading. 3. Identification of affiliated persons to ensure that any transactions with affiliated persons are executed in compliance with the 1940 Act. 4. Protection of nonpublic information, including: (a) prohibitions against trading portfolio securities on the basis of information acquired by analysts or portfolio managers employed by the Trust or the Funds' ’ investment adviser ("“Adviser"”) or the Funds' ’ investment subadviser sub-adviser ("“Subadviser") ”); (b) disclosure to third parties of material information about the Funds' ’ portfolio holdings, trading strategies or pending transactions; and (c) purchase or sale of Fund shares by the personnel of the Trust or the Adviser or Subadviser based on material, nonpublic information about the Funds' ’ portfolios. 5. Compliance with Fund governance requirements, including the procedures to guard against: (a) an improperly constituted Board of Trustees ("Board"); (b) failure of the Board to properly consider matters entrusted to it; and (c) failure of the Board to request and consider information required by the 1940 Act from the Trust and other Service Providers. 6. The excessive short-term trading of mutual fund shares that may be harmful to the Funds, including a focus on the following areas: (a) consistency of policies and procedures with the Funds' disclosed policies regarding market timing; (b) monitoring of shareholder trades or flows of money in and out review of the Funds in order to detect market timing activity; (c) enforcement appropriateness of the Funds' ’ policies regarding on market timing; (d) prevention of waivers that would harm the Funds or their shareholders, or subordinate the interests of the Funds or their shareholders to those of the Trust or any other affiliated person or associated person of the Trust; and (e) reporting to the Trust's Board regarding all waivers granted, so that the Board can determine whether such waivers were propertiming and frequent trading. 7. The distribution, marketing and advertising of the Funds' ’ shares. 8. The blockchain-enabled aspects of a Fund’s shares. 9. The trading of portfolio securities by the Funds, including a focus on enforcement of the Trust's ’s policies with respect to brokerage, soft dollars and allocation of trades. 910. The review of any electronic mail communicationscommunications by registered representatives of the Trust’s Distributor and employees of the Adviser.

Policies and Procedures of the Trust. Conduct a detailed review of the Trust's ’s Compliance Program pertaining to compliance by registered investment companies with the Federal Securities Laws, among other things: 1. Pricing of portfolio securities and Fund shares, with a focus on the following items within the pricing polices and procedures: (a) monitoring for circumstances that may necessitate the use of fair value prices; (b) establishing reviewing criteria for determining when market quotations are no longer reliable for a particular portfolio security; (c) providing a methodology or methodologies by which the Funds determine the current fair value of their portfolio securities; and (d) reviewing the appropriateness and accuracy of the methodology used in valuing securities, including making any necessary adjustments. 2. Processing of Fund shares, with a focus on the following items: (a) segregation of investor orders received before the Funds price their shares from those that were received after the Funds price their shares; and (b) methodology used by the Funds to protect themselves and their shareholders against late trading. 3. Identification of affiliated persons to ensure that any transactions with affiliated persons are executed in compliance with the 1940 Act. 4. Protection of nonpublic information, including: (a) prohibitions against trading portfolio securities on the basis of information acquired by analysts or portfolio managers employed by the Trust or the Funds' ’ investment adviser ("“Adviser"”) or the Funds' ’ investment subadviser ("“Subadviser") ”); (b) disclosure to third parties of material information about the Funds' ’ portfolio holdings, trading strategies or pending transactions; and (c) purchase or sale of Fund shares by the personnel of the Trust or the Adviser or Subadviser based on material, nonpublic information about the Funds' ’ portfolios. 5. Compliance with Fund governance requirements, including the procedures to guard against: (a) an improperly constituted Board of Trustees ("“Board"”); (b) failure of the Board to properly consider matters entrusted to it; and (c) failure of the Board to request and consider information required by the 1940 Act from the Trust and other Service Providers. 6. The excessive short-term trading of mutual fund shares that may be harmful to the Funds, including a focus on the following areas: (a) consistency of policies and procedures with the Funds' disclosed policies regarding market timing; (b) monitoring of shareholder trades or flows of money in and out review of the Funds in order to detect market timing activity; (c) enforcement appropriateness of the Funds' ’ policies regarding on market timing; (d) prevention of waivers that would harm the Funds or their shareholders, or subordinate the interests of the Funds or their shareholders to those of the Trust or any other affiliated person or associated person of the Trust; and (e) reporting to the Trust's Board regarding all waivers granted, so that the Board can determine whether such waivers were propertiming and frequent trading. 7. The distribution, marketing and advertising of the Funds' ’ shares. 8. The trading of portfolio securities by the Funds, including a focus on enforcement of the Trust's ’s policies with respect to brokerage, soft dollars and allocation of trades. 9. The review of any electronic mail communicationscommunications by registered representatives of the Trust’s Distributor and employees of the Trust’s Investment Advisor.