What follows are several relevant excerpts from the Jones Heward Code of Ethics document.

The Jones Heward Code of Ethics explicitly references both client account conduct and employee trading conduct. The purpose of the Code is to ensure the fair treatment of our clients through the highest standards of integrity and ethical business conducted by our employees, officers and directors.

An employee, officer or director of Jones Heward recognizes that they must put the interests of our clients first, ahead of personal self-interests. Above all, employees and partners are strictly forbidden from taking unfair advantage of their position, knowledge or relationship with any clients, or engage in any conduct that is not in the best interests of our clients.

Trading transactions for our clients always have priority over personal trading transactions. We have a statutory duty to our clients to act honestly, in good faith and in their best interests and to exercise the degree of care, diligence and skill that a reasonably prudent manager would exercise in the circumstances. This standard of care extends to each area of our business operations.

All employees are subject to special rules and restrictions with respect to trading in securities within accounts covered by our Code.

Employees must not use any non-public information about a Client or their account for their direct or indirect personal benefit or in a manner that would not be in the best interests of our clients. Employees also must not use their position in the Company to obtain special treatment or investment opportunities not generally available to our clients or the public.

All employee trades are submitted to the compliance officer for pre-approval. An employee trade is not approved if Jones Heward is trading in the security for client accounts.

Jones Heward Investment Counsel Inc. is in compliance with the OSC Soft Dollar Standards. The Compliance Department conducts all soft dollar transactions. Client brokerage is the property of the client accounts, which generate the brokerage.