Promote the highest ethical standards.

Safeguard confidential information and material non-public information (“MNPI”).

Prevent actual or apparent conflicts of interest.

Ensure compliance with federal securities laws.

Places client interests ahead of personal interests,

Complies with applicable securities laws, and

Avoids conflicts of interest or any abuse of position of trust and responsibility.

Clients’ interests are paramount. Always put Client and Investor interests first.

Avoid conflicts. Do not let personal, family, or affiliate interests impair judgment; disclose any potential conflicts promptly.

Maintain confidentiality. Do not misuse or share client information or MNPI, including with affiliates.

Be transparent. Disclose outside activities, gifts, conflicts, or affiliate interactions to Compliance.

Comply with laws. Follow all securities, anti-fraud, and anti-corruption laws.

Promote ethical culture. Lead by example and report concerns promptly.

Treat all client information as strictly confidential (identity, holdings, advice, financial circumstances).

Do not disclose except when authorized, legally required, or approved by Compliance.

Do not share Post’s MNPI or confidential information with affiliates (including Nexus Capital Management, its funds, or its portfolio companies) unless explicitly authorized via documented Compliance-to-Compliance (Clean Team) protocols between the Post CCO and the Nexus CCO (or their designees).

Do not bring MNPI from Nexus or its affiliates into Post.

All affiliate information requests (including from Nexus) must be routed through both Post and Nexus Compliance using Clean Team channels; investment personnel may not participate.

Board Managers may be recused from discussions or materials if conflicts arise (see Section IX).

Post does not engage in wall-crossing arrangements with affiliates. MNPI and affiliate interactions are managed through restricted lists, Board recusals, and information barriers.

Disqualifying Events: Employees must promptly notify the CCO if they are subject to, or become aware they may be subject to, any disqualifying events or notification obligations described in Appendix C. Failure to report such events may result in sanctions up to and including termination.

Personal Finances: Employees must manage finances responsibly. No borrowing from Clients or vendors.

Business Opportunities: Opportunities solicited by or offered to Post belong to Post, not Employees.

Outside Business Activities (OBA): All OBAs must be pre-cleared with Compliance via gVue. Includes compensated and uncompensated roles. Service with Nexus, its affiliates, or their portfolio companies requires prior written CCO approval and may require tailored recusals or trading restrictions.

Conflicts of Interest: Disclose and resolve conflicts promptly.

Do not offer or accept gifts or entertainment that could appear to influence decisions.

Applies equally to interactions with affiliates (including Nexus personnel). Must follow Post’s thresholds, approvals, and logging requirements.

Bribery, facilitation payments, and manipulative trading practices are strictly prohibited.

All Employees are Access Persons (as defined in Appendix B – Glossary) unless designated Exempt by the CCO.

Board Managers who meet the definition of Access Persons are subject to the same rules unless designated Exempt by the CCO (see Section IX).

Access Persons must use gVue for reporting and pre-clearance (see Appendix A for procedures).

Initial Holdings Report: Within 10 days of becoming an Access Person (see Appendix A).

Annual Holdings Report: Due within 30 days of December 31 (see Appendix A).

Quarterly Transaction Report: Within 30 days of quarter end, covering all trades and new accounts (see Appendix A).

Annual Certification: Required acknowledgement of compliance with this Code and reporting obligations (see Appendix A).

Accounts where an Access Person or Household Member has Beneficial Ownership and can trade securities.

Includes brokerage, IRA, custodial, trust, HSA, and 529 accounts.

Excludes discretionary accounts, Post employee benefit plans, and mutual fund-only accounts.

Includes equities, ETFs, bonds, options, derivatives, closed-end funds, private placements, and private funds.

Excludes U.S. government securities, CDs, money markets, non-affiliated open-end registered funds (i.e., mutual funds), and municipal securities limited to 529 plans.

Any Reportable Security transaction, excluding ETFs;

Initial Public Offerings (IPOs);

Private Placements, including investments in Post’s funds; and

Investments in Nexus-sponsored private funds or co-investments (see Appendix A).

Trading any issuer listed on the Watch List or PIRL;

Participating in investment clubs;

Front-running client trades;

Executing personal trades within seven (7) calendar days of related client trades; or

Exceeding 200 personal trades per calendar year (see Appendix A).

Direct investments in Nexus-sponsored funds must be pre-cleared and reported (see Appendix A).

Employees may not use information about Nexus fund holdings to influence Post decisions (see Appendix A).

Co-investments and secondaries are subject to MNPI restrictions (see Appendix A).

All Supervised Persons must report actual or suspected violations of this Code promptly to Compliance.

Reports will be treated confidentially (to the extent permissible by law) and investigated appropriately.

No retaliation will be taken against good-faith reporters.

Anonymous reports may also be made through Post’s Ethics Hotline (1-844-845-5245 or https://www.clearviewconnects.com), operated by Mitratech/ClearView and available 24/7.

Upon discovering a violation, the CCO may impose sanctions, including:

Written warning,

Suspension of personal trading privileges,

Monetary fines,

Disgorgement of improper profits,

Suspension or termination of employment or contract.

Breaches involving affiliate information or MNPI may also result in immediate trading halts, recusals from coverage areas, loss of Board access, or referral to the Board of Managers.

The CCO or their designee has discretion to interpret the Code and grant exceptions, documented in writing. Where affiliate considerations are involved, the Post CCO will consult with the Nexus Compliance Officer to ensure consistent application.

Certification that Post has procedures to prevent Code violations,

Identification of material violations and sanctions imposed,

Description of issues that arose under the Code, and

Recommended changes to restrictions or procedures.

Summary of personal investing procedures,

Material violations requiring remedial action,

Recommended changes based on experience and regulatory developments, and

Certification of reasonably designed procedures.

All Access Persons must annually certify their compliance with the Code.

Board Managers and designated senior Employees must also attest annually to compliance with confidentiality, MNPI, and affiliate-related provisions.

A copy of all versions of this Code,

Records of Code violations and sanctions,

Reports and certifications from Access Persons,

List of all Access Persons over the past five years,

Decisions approving private investments by Access Persons,

Annual Code reports provided to Boards,

Watch List and PIRL change logs,

Records of Board recusals, and

Affiliate pre-clearance files.

All Board of Managers are subject to confidentiality and fiduciary duties not to misuse or improperly disclose Post’s client information. Board Managers must promptly notify the CCO of any disqualifying events as described in Appendix C.

Due to Nexus’s private equity activities, access to MNPI, and dual Code obligations of its designated directors:

May not share Post’s confidential information with Nexus or its affiliates,

May not bring MNPI from Nexus or its affiliates into Post,

May be recused from Board discussions or materials where conflicts exist,

Must comply with Clean Team and information-barrier procedures.

Subject to Post’s general confidentiality obligations.

Additional MNPI restrictions in this Code are primarily focused on Nexus due to its private equity business.

Board Managers who have been designated Access Persons must comply with the personal trading and reporting provisions of this Code (see Appendix A). Where also subject to Nexus’s Code, directors must coordinate pre-clearance and reporting with both Compliance teams; if obligations differ, the stricter standard applies.

All Board Managers must annually certify compliance with the confidentiality, MNPI, and (if applicable) personal trading provisions of this Code.

All Board Managers must also acknowledge their notification obligations for disqualifying events (see Appendix C).

Initial Holdings Report: Within 10 calendar days of becoming an Access Person, submit a complete list of all investment accounts and securities beneficially owned (as defined in Appendix B). The holdings must be current as of a date no more than 45 days before becoming an Access Person.

Annual Holdings Report: By January 30 each year, submit updated holdings as of December 31 of the prior year.

Reports are submitted through gVue unless otherwise approved by Compliance.

Due within 30 days after each calendar quarter.

Must include all securities transactions and new accounts opened during the quarter.

Even if no reportable transactions occurred, a “no activity” certification must be submitted.

Brokerage confirms/statements must be provided (either via electronic feed into gVue or directly to Compliance if not supported).

Have read and understand the Code;

Have complied with it throughout the year;

Have disclosed all accounts and transactions; and

Have responded accurately to the personal disciplinary history questionnaire.

Brokerage, IRA, custodial and trust accounts

529 College Savings Plan accounts

401(k) or HSA accounts that allow transactions in any Reportable Security

Charitable giving accounts

Certain retirement accounts limited to mutual funds

Pure cash management accounts (no trading authority)

Discretionary accounts approved by Compliance

Post employee benefit plans (401(k), deferred comp, ESPP, etc.)

Variable annuity contracts

U.S. government obligations

CDs, bankers’ acceptances, commercial paper, high-quality short-term debt

Money market funds

Open-end mutual funds not managed by Post or its affiliates

Municipal securities available only through 529 College Savings Plans

UITs (unit investment trusts) invested solely in open-end mutual funds

Any transaction in a Reportable Security, excluding ETFs;

Initial Public Offerings (IPOs);

Private placements, including investments in Post’s funds; and

Investments in Nexus-sponsored private funds or co-investments.

Trading any issuer listed on the Watch List or PIRL;

Participating in investment clubs;

Front-running client trades;

Executing personal trades within seven (7) calendar days of related client trades; or

Exceeding 200 personal trades per calendar year.

Must be pre-approved by the CCO before establishment.

Written attestation required that the account is fully discretionary.

Annually, Access Person must certify no influence or control.

Compliance may test on a sample basis.

Direct investments by Employees or Household Members in Nexus-sponsored private funds must be pre-cleared.

Co-investments/secondaries tied to specific portfolio companies are subject to MNPI restrictions.

Affiliate and employee investors will only receive standard investor communications. Any additional information they may access is solely by virtue of their employment role and may not be used to seek preferential treatment or to influence their personal investment decisions.

Violations must be reported promptly to Compliance or via the Ethics Hotline.

Sanctions may include warnings, suspension of trading, fines, disgorgement, or termination.

Affiliate-related breaches may also trigger immediate trading halts, removal from coverage, or loss of Board access.

False or misleading filings: Willfully making or causing to be made a false or misleading statement (or omitting a material fact) in any SEC application, report, or proceeding.

Convictions involving securities or fiduciary misconduct: Conviction (domestic or foreign) of a felony or misdemeanor involving purchase/sale of a security, false oath/report, bribery, perjury, theft, fraud, forgery, conspiracy, or substantially equivalent activity.

Felonies unrelated to securities: Conviction of any felony punishable by imprisonment for one year or more (domestic or foreign).

Injunctions: Being permanently or temporarily enjoined by a court from acting as an adviser, broker, dealer, underwriter, transfer agent, credit rating agency, or equivalent, or from participating in conduct related to securities or fiduciary activities.

Failure to supervise / aiding & abetting: Willfully aiding, abetting, counseling, commanding, or inducing another to violate securities laws, or failing reasonably to supervise.

Bars or suspensions: Being subject to any SEC order barring or suspending association with an investment adviser.

Foreign regulatory findings: Being found by a foreign financial regulatory authority to have filed false information, violated securities/commodity laws, aided and abetted violations, or failed to supervise.

State/federal banking or insurance orders: Being subject to a final order of a state securities commission, banking/insurance regulator, or equivalent federal agency that bars the person from regulated activities, or is based on violations involving fraud, manipulation, or deceit.

Felony involving abuse or misuse of an employee benefit plan position or labor organization role.

Felony arising out of the conduct of a broker, dealer, adviser, bank, insurance company, or fiduciary business.

Income tax evasion.

Felony involving larceny, theft, robbery, extortion, forgery, counterfeiting, fraudulent concealment, embezzlement, fraudulent conversion, or misappropriation of funds/securities.

Conspiracy or attempt to commit any of the above.

Conviction or imprisonment for robbery, bribery, extortion, embezzlement, fraud, grand larceny, burglary, arson, felony drug violations, murder, rape, kidnapping, perjury, or assault with intent to kill.

Employees: Must immediately notify the CCO of any potential or actual disqualifying event.

Board Managers: Must immediately notify both the COO and CCO of any potential or actual disqualifying event.]

If uncertain: Employees or Board Managers must consult with the CCO promptly for guidance.

Documentation: Compliance will maintain records of all notifications, assessments, and any remedial actions.

Prevent Post from continuing as a registered investment adviser with the SEC.

Disqualify Post from relying on exemptions (e.g., QPAM exemption for ERISA clients).

Trigger “bad actor” disqualification for Rule 506 private offerings.

Require disclosure and/or withdrawal from certain mandates or fund roles.