WCM Investment Management, LLC

CODE OF ETHICS

A copy of this Code of Ethics is maintained in the WCM’s Common Firm Docs and My

Compliance Office (“MCO”) and is accessible to each Supervised Person of WCM

Investment Management, LLC (“WCM”) for reference. This Code of Ethics is the

property of WCM and its contents are confidential.

WCM Investment Management, LLC

281 Brooks Street

Laguna Beach, CA 92651

949.380.0200

Reviewed and adopted: June 30, 2025

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I.STATEMENT OF BUSINESS ETHICS OF WCM INVESTMENT

MANAGEMENT1

II.ANTI-FRAUD AND FIDUCIARY OBLIGATION1

III.ANTI-CORRUPTION AND BRIBERY2

A.Foreign Corrupt Practices Act (“FCPA”)2

B.WCM’s Policy2

1.Supervised Persons2

2.Third Parties3

3.Government officials3

4.Facilitation payments4

5.Violations4

IV.INITIAL/ANNUAL ACKNOWLEDGEMENTS4

V.GENERAL STANDARDS OF CONDUCT AND WCM PROCEDURES5

A.Use of WCM Funds or Property5

1.Personal Use of WCM Funds or Property5

2.Payments to Others5

3.Improper Expenditures5

B.Conflicts of Interest and WCM Opportunities5

1.Outside Business Activities and Interest in Competitors, Clients or

Suppliers6

3.Charitable Contributions7

4.Political Contributions7

5.Interest in Transactions10

6.Acting as a Registered Representative of a Broker-Dealer10

7.Diversion of WCM Business or Investment Opportunity10

VI.GENERAL STANDARDS OF CONDUCT IN DEALING WITH CLIENTS

AND PROSPECTIVE CLIENTS10

A.Fair and Equitable Treatment of Clients10

B.No Guarantees Against Loss10

C.No Guarantees or Representations as to Performance10

D.No Legal or Tax Advice10

E.No Sharing in Profits or Losses10

F.No Borrowing From or Lending To a Client11

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G.Supervised persons May Not Act as a Custodian of a Client11

H.Orders May Not Be Placed Through Unlicensed Broker-Dealers or Agents11

I.Executing Transactions or Exercising Discretion Without Proper

Authorization11

VII.PROTECTION OF MATERIAL, NONPUBLIC AND OTHER CONFIDENTIAL

INFORMATION AND PREVENTION OF INSIDER TRADING AND TIPPING11

A.Need for Policy11

B.General Policies and Procedures Concerning Insider Trading and Tipping12

1.“Material”12

2.“Nonpublic”13

3.“Advisory Information”13

C.Prohibitions13

D.Protection of Material, Nonpublic Information13

E.Procedures to Safeguard Material, Nonpublic Information14

1.Expert Networks14

2.Interacting with Potential Insiders14

3.Alternative Data Sources15

4.“Wall Cross” Requests15

5.Review and Monitoring16

F.Protection of Other Confidential Information16

G.Procedures to Safeguard Other Confidential Information16

VIII.PROTECTION OF CONFIDENTIAL INFORMATION CONCERNING

CLIENT RECOMMENDATIONS, ADVICE, OR TRADING AND “CHINESE

WALL” PROCEDURES16

A.Designation of Advisory Persons, Access Persons, and Supervised Persons16

B.Obligations of Advisory Persons17

C.General Policy Concerning Non-Advisory Persons17

D.Monitoring Compliance with Insider Trading and Tipping Policies and

Procedures and Effectiveness of “Chinese Wall” Procedures17

IX.RULES GOVERNING PERSONAL SECURITIES ACCOUNTS, HOLDINGS,

AND TRANSACTIONS BY WCM ACCESS PERSONS18

A.Who is Covered by These Requirements18

B.What Accounts and Transactions Are Covered18

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C.What Securities are Covered by These Requirements

(“Reportable Securities”)19

D.What Transactions are Prohibited by these Requirements19

1.Front-Running or Scalping19

2.Short Sales of a Security Held by a Client19

3.Use of Confidential or Material, Nonpublic Information19

E.Personal Securities Transactions Which Must Be Pre-Cleared19

F.Obtaining Pre-Clearance21

G.Identification of Securities Accounts and Reports of Securities Holdings21

H.Reporting of Securities Transactions22

I.Confidentiality of Personal Securities Information23

J.Addressing Personal Trading Conflicts with Advisory Persons23

K.Short Term Trading Restriction and Personal Trading Cap24

L.Waivers25

X.REPORTING TO THE MUTUAL FUND BOARD25

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WCM Code of Ethics

Code of Ethics

I.STATEMENT OF BUSINESS ETHICS OF WCM INVESTMENT

MANAGEMENT

WCM is committed to maintaining the highest legal and ethical standards in the conduct

of our business. We have built our reputation on client trust and confidence in our professional

abilities and our integrity. As fiduciaries, we place our clients’ interests above our own. Meeting

this commitment is the responsibility of WCM and each and every one of our Supervised

Persons.

Failure to comply with this policy may result in significant civil and criminal penalties,

costly legal fees, and damage to the reputation of the Firm and the individuals involved and

cause disciplinary action against such individuals, up to and including termination.

The Compliance Team is responsible for investigating any potential violations, discussing

such violations with any Supervised Person believed to have committed such a violation, and

recommending a sanction, if appropriate, to the Leadership Team. The Leadership Team will

determine the appropriate sanction and have responsibility to affect the violative conduct.

Any capitalized terms used but not defined in this Code of Ethics will have the meanings

assigned to them by the applicable law or regulation.

II.ANTI-FRAUD AND FIDUCIARY OBLIGATION

WCM is registered as an investment adviser with the U.S. Securities and Exchange

Commission (the “SEC”) and has made a notice filing in its home state of California. It is

WCM’s policy to notice file in all 50 states. In conducting WCM’s investment advisory business,

WCM and its Supervised Persons must comply at all times with applicable federal securities

laws, including the provisions of the Investment Advisers Act of 1940, as amended (the

“Advisers Act”), the rules under the Advisers Act and applicable provisions and rules under the

laws of the various states where WCM does business or has clients. In addition, when managing

accounts of employee benefit plans subject to the Employee Retirement Income Security Act of

1974, as amended (“ERISA”) and Individual Retirement Accounts, WCM must comply with all

applicable provisions of ERISA, the Internal Revenue Code of 1986, as amended, and the rules

under those laws.

As a registered investment adviser, WCM and its Supervised Persons also have fiduciary

and other obligations to clients. WCM’s fiduciary duties to its clients require, among other

things, that WCM: (i) render disinterested and impartial advice; (ii) make suitable

recommendations to clients in light of their needs, financial circumstances and investment

objectives; (iii) exercise a high degree of care to ensure that adequate and accurate

representations and other information about securities are presented to clients; (iv) have an

adequate basis in fact for any and all recommendations, representations and forecasts; (v) refrain

from actions or transactions that conflict with interests of any client, unless the conflict has first

been disclosed to the client and the client has (or may be considered to have) waived the conflict;

and (vi) treat all clients fairly and equitably.

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WCM Code of Ethics

A breach of any of the above duties or obligations may, depending on the circumstances,

expose WCM and its Supervised Persons involved, to SEC and state disciplinary actions and to

potential criminal and civil liability, as well as subject the Supervised Person to WCM sanctions

up to and including termination of employment. All Supervised Persons are required to promptly

report violations of this Code of Ethics to the Chief Compliance Officer.

III.ANTI-CORRUPTION AND BRIBERY

As a global investment adviser, WCM is presented with the unique challenge of trying to

observe local business customs while still complying with applicable U.S. and other laws

prohibiting corruption. The U.S. Foreign Corrupt Practices Act (“FCPA”) and other anti-

corruption laws prohibit any payment or offer of payment to a “foreign official” for the purpose

of influencing that official to assist in obtaining or retaining business for a company. WCM has

established this policy to ensure that all Supervised Persons of the Firm are aware of the FCPA

and engage in ethical and legal practices.

A.Foreign Corrupt Practices Act (“FCPA”)

The FCPA prohibits any officer, agent, or Supervised Person of the Firm from directly or

indirectly paying or giving, offering or promising to pay, giving or authorizing or approving such

offer or payment, of any funds, gifts, services or anything else of any value to any foreign official

or other person (each, a “Covered Person”) for the purpose of obtaining business, favorable

treatment, or other commercial benefits, whether by:

•influencing any act or decision of the Covered Person in his official capacity;

•inducing the Covered Person to act or not act in violation of his lawful duty; or

•inducing the Covered Person to use his influence to that end with a foreign government

or instrumentality

The same prohibition applies to a Covered Person’s agent, intermediary (including, for

example, a Covered Person’s friend, relative, business or law firm), or other person while knowing

that all or a portion thereof will directly or indirectly be forwarded to a Covered Person for such

purpose.

For purposes of this Anti-Corruption and Bribery policy, a “Covered Person” is any foreign

official including, without limitation, any officer or employee of any foreign government or any

governmental department, agency, or instrumentality (e.g., a central bank) or any government-

owned or controlled enterprise or any person acting in an official capacity for or on behalf of any

such government, department, agency, instrumentality, or enterprise). It also includes any foreign

political party, party official or candidate for political office.

B.WCM’s Policy

Bribery and corruption are not only against WCM’s values, they are illegal and can expose

both the employee and WCM to fines and penalties, including imprisonment and reputational

damage.

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WCM Code of Ethics

1.Supervised Persons

WCM strictly prohibits bribery and other corrupt practices. Neither the Firm, nor its

Supervised Persons, will seek to influence others, either directly or indirectly, by offering,

promising, giving, or authorizing the giving or receiving of bribes or kickbacks, no matter how

small. Supervised Persons and representatives of WCM are expected to decline any opportunity

which would place our ethical principles and reputation at risk. While certain laws apply only to

bribes of government officials (domestic and foreign; see Political Contributions Policy), this

policy applies to all dealings including non-government business partners.

2.Third Parties

WCM and its Supervised Persons cannot avoid liability by using a third party to give or

receive a bribe. Third parties representing and/or acting on behalf of WCM are expected to

comply with our Anti-Corruption and Bribery Policy. In some jurisdictions, WCM can be

convicted of a criminal offense if it fails to prevent a bribery carried out on its behalf by a third

party, even if no one in the Firm had actual knowledge of the bribe. Therefore, whenever WCM

seeks to engage a third party in which the third party may interact with a Government Official

for or on behalf of WCM, the following guidelines apply:

•Due diligence should be performed to ensure that the third party is a bona fide

and legitimate entity, is qualified to perform services for which it will be retained, and

maintains standards consistent with the legal, regulatory, ethical, and reputational

standards of the Firm.

•Agreements with third parties must be in writing and should contain

provisions related to the following, based on corruption risk present in the third-party

relationship:

oA representation that the third party will remain in compliance with all relevant

anti-corruption laws, including the FCPA; and

oA provision that requires the third party to respond to reasonable requests for

information from the Firm regarding the work performed under the agreement

and related expenditures by the third party.

3.Government officials

Sales to Government Officials or government entities may present increased anti-

corruption risk. Where WCM sells investment products or services to Government Officials or

entities, such as public pensions, other state-owned financial institutions, or government

affiliated institutions, the sales/marketing efforts related to these government clients should be

clearly documented. As noted above, any expenditures made in connection with such business

(entertainment, travel, etc.) must not be for any improper purpose and must comply with local

law. Laws and regulations are strict when dealing with Government Officials. For example,

reasonable corporate hospitality that is acceptable with other business associates might not be

allowable when Government Officials are involved.

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WCM Code of Ethics

Before such expenses are incurred, Supervised Persons must obtain prior approval

from the Compliance Team.

A Government Official is any:

•individual elected or appointed to a governmental entity;

•official or employee of a government;

•official or employee of a company wholly or partially controlled by a government

(such as state-owned companies);

•candidate for political office;

•political party or official of a political party; or

•person acting in an official capacity for any of the above regardless of rank or

position.

The definition of what could constitute a bribe to a Government Official is broad and can

occur even when the benefit being offered is small, such as gifts, entertainment and even

business meals.

4.Facilitation payments

“Facilitation or grease payments” are payments that facilitate a normal governmental

function, such as to expedite processing paperwork. While these types of payments may be

accepted as “a cost of doing business” in some cultures, they are illegal and counter to our

values.

5.Violations

Supervised Persons and representatives of WCM should seek clarification on any

questions or concerns regarding activities under consideration or the interpretation of any law. If

you are offered a bribe from a person or entity doing business with or seeking to do business

with WCM, report it immediately to the Compliance Team.

Failure to comply with this policy may result in significant civil and criminal penalties,

costly legal fees, and damage to the reputation of the Firm and the individuals involved and

cause disciplinary action against such individuals, up to and including termination.

Actual or potential violation of the anti-bribery or foreign corruption laws of this policy

by the Firm, or another Supervised Person, must promptly be reported to the Compliance Team.

IV.INITIAL/ANNUAL ACKNOWLEDGEMENTS

Supervised Persons should keep this Code of Ethics (“COE”) available for easy

reference. A copy of the COE is given to each Supervised Person and is maintained in the

WCM’s Common Firm Docs and within My Compliance Office (“MCO”). Each Supervised

Person will, before starting to work at WCM and each year thereafter, read this COE and

acknowledge that they have reviewed and understand it, and will adhere to the COE by

completing the Annual Acknowledgement via MCO. From time to time, the COE will be revised

or supplemented. The CCO, or his delegate, is responsible for providing each Supervised Person

with a revised copy of this COE when material changes have occurred.

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WCM Code of Ethics

Each year, Supervised Persons must also complete the Disciplinary History questionnaire

via MCO, which requests information about whether the Supervised Person has been subject to

any disciplinary event, that is, a criminal, civil and/or regulatory action by a U.S. or foreign

court, military court or regulatory or self-regulatory body. The employment of any person who is

subject to such a reportable disciplinary event might, absent appropriate disclosures or specific

relief from the SEC, tarnish WCM’s reputation, jeopardize business relationships and

opportunities for both WCM and its Supervised Persons or expose WCM itself to potential

disciplinary sanctions or disqualifications. Accordingly, a Supervised Person must notify the

Compliance Team immediately if he or she becomes aware of anything that could result in a

change in any of this information. Failure to accurately complete the questionnaire or to notify

the Compliance Team of changes to information relating to disciplinary actions may subject a

Supervised Person to disciplinary action or be grounds for dismissal.

V.GENERAL STANDARDS OF CONDUCT AND WCM PROCEDURES

A.Use of WCM Funds or Property

WCM’s policy is to require each Supervised Person to respect the funds and property

belonging to WCM, to limit the personal use of such funds or property, and to prohibit

questionable or unethical disposition of WCM funds or property.

1.Personal Use of WCM Funds or Property

No Supervised Person may take or permit any other Supervised Person to take, for his

personal use, any funds or property belonging to WCM. Misappropriation of funds or property is

theft and, in addition to subjecting a Supervised Person to possible criminal and civil penalties,

will result in WCM disciplinary action up to, and including, dismissal.

2.Payments to Others

No WCM funds or property may be used for any unlawful or unethical purpose, nor may

any Supervised Person attempt to purchase privileges or special benefits through payment of

bribes, kickbacks or any other form of “payoff.” Customary and normal courtesies in

conformance with the standards of the industry are allowable except where prohibited by

applicable laws or rules. (See sections on Anti-Corruption and Bribery; Gifts and

Entertainment; and Political Contributions for additional information.) Particular care and

good judgment are required when dealing with federal, state or local government officials to

avoid inadvertent violations of government ethics rules. (Also, see following section on Political

Contributions regarding important rules.)

3.Improper Expenditures

No payment by or on behalf of WCM will be approved or made if any part of the

payment is to be used for any purpose other than that described in the documents supporting the

payment. Records will be maintained in reasonable detail that accurately and fairly reflect the

transactions they describe and the disposition of any funds or property of WCM.

Any questions concerning the propriety of any use of WCM funds or property should be

directed to the Compliance Team.

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WCM Code of Ethics

B.Conflicts of Interest and WCM Opportunities

It is not possible to provide a precise or comprehensive definition of a conflict of interest.

However, one factor that is common to all conflict of interest situations is the possibility that a

Supervised Person’s actions or decisions will be affected because of actual or potential

differences between or among the interests of WCM, its affiliates or clients, and/or the

Supervised Person’s own personal interests. A particular activity or situation may be found to

involve a conflict of interest even though it does not result in any financial loss to WCM, its

affiliates or its clients or any gain to WCM or the Supervised Person, and irrespective of the

motivations of the Supervised Person involved.

1.Outside Business Activities and Interest in Competitors, Clients or

Suppliers

Supervised Persons should avoid other employment or business activities, including

personal investments that interfere with their duties to WCM, divide their loyalty, or create or

appear to create a conflict of interest. In no event should any Supervised Person have any outside

business activity that might cause embarrassment to or jeopardize the interests of WCM,

interfere with its operations, or adversely affect his or her productivity or that of other

Supervised Persons.

Each Supervised Person must pre-clear all outside business activities on MCO, for profit

or non-profit. In addition, no Supervised Person or member of his or her “Immediate

Family” (including any relative by blood or marriage living in the Supervised Person’s

household), shall serve as an officer, director, general partner, advisor, or trustee of, or have a

substantial interest in or business relationship with a company (private or public), competitor,

client, or supplier of WCM without the prior approval of the Chief Compliance Officer.

Any conflict that the Chief Compliance Officer determines is harmful to the interests of

clients or the interests or reputation of WCM will be prohibited. The Chief Compliance Officer’s

determination as to whether a conflict exists or is harmful shall be conclusive.

Approval will be granted on a case-by-case basis, subject to proper resolution of

potential conflicts of interest. Outside activities will be approved only if any conflict of interest

issues can be satisfactorily resolved and all of the necessary disclosures are made on Part 2 of

Form ADV.

2.Gifts and Entertainment

Giving, receiving or soliciting gifts and/or entertainment (“G&E”) in a business setting

may create an appearance of impropriety or may raise a potential conflict of interest.

Additionally, WCM is subject to G&E-related laws and restrictions as a result of being a

fiduciary and acting as an investment adviser to government entities, ERISA and Taft-Hartley

plans, and mutual funds.

Therefore, WCM has adopted the following policies and procedures.

•Entertainment over $250 per person may be restricted; therefore, it must be

reported without undue delay via MCO and approved by the Compliance Team.

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WCM Code of Ethics

oEntertainment is an event which includes participation by both parties for

the mutual building of a business relationship. Events, such as meals,

golfing, sporting events, and the like, are considered commonly accepted

business practices and they are usually permissible.

•Gifts over $250 per person may be restricted; therefore, it must be reported

without undue delay via MCO and approved by the Compliance Team.

oGifts are things given or received by a Supervised Person. Charitable

donations are considered gifts.

•ANY G&E to or from state or city pension plan representatives or non-U.S.

government entities must be pre-cleared.

•ANY G&E to or from ERISA or Taft-Hartley plans is prohibited.

•ANY G&E to or from broker-dealers executing purchases or sales for mutual

funds advised or sub-advised by WCM is prohibited. This is required by Section

17(e)(1) of the 1940 Act, which prohibits WCM or its Supervised Persons from

accepting any sort of compensation for the purchase or sale of property to or from

any mutual fund WCM advises.

WCM expects that it will bear the costs of travel and lodging associated with

conferences, research trips, and other business-related travel. If these costs are borne by a person

or entity other than WCM, pre-approval must be sought as such travel expenses will be treated as

a gift to the Supervised Person for purposes of this policy.

WCM’s Finance Team will coordinate with the Compliance Team for the review and

reimbursement of employee expense reports to ensure compliance with this policy. If a

Supervised Person has any questions regarding what constitutes G&E or how to handle it, it is

their responsibility to ask the Compliance Team.

Note: Registered Representatives of ACA Foreside have additional requirements. Please

see your Supervising Principal and ACA Foreside Compliance Manual for more details.

3.Charitable Contributions

Charitable contributions, sponsorships and grants, including those that are solicited by

business partners and Government Officials may present increased corruption risk. Proposed

charitable contributions, sponsorships or grants must not be used to conceal a bribe or otherwise

benefit the business partner or Government Official. Charitable contributions, sponsorships and

grants must not be provided for any improper purpose. As noted above, charitable contributions

are considered Gifts and must be reported in MCO and approved by the Compliance Team.

4.Political Contributions

No Supervised Person shall make or solicit any political contribution for the purpose of

obtaining or retaining advisory contracts with government entities. Contributions by a Covered

Associate made to any elected official who, within two years of the contribution, is in a position

to influence the retention or has legal authority to retain WCM, will result in the firm’s

prohibition in receiving any adviser fees from that government entity for a period of two years.

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WCM Code of Ethics

Covered Associates are therefore not permitted to coordinate, or to solicit any person or political

action committee to make, any:

•Contribution to an official of a government entity to which the investment adviser

is providing or seeking to provide investment advisory services; or

•Payment to a political party of a State or locality where the investment adviser is

providing or seeking to provide investment advisory services to a government

entity.

For purposes of this Political Contribution policy, a Covered Associate is defined as:

•any general partner, managing member or executive officer of WCM, or other

individual with a similar status or function;

•any employee who solicits a government entity for WCM or any person who

supervises, directly or indirectly, such employee; and

•any political action committee ("PAC") controlled by WCM or by any such

persons described above.

Exceptions for De Minimis Contributions. Covered associates are permitted to make

aggregate contributions, without triggering the two-year "time out," of up to $350 per election to

an elected official or candidate for whom the Covered Associate is entitled to vote, and up to

$150 per election to an elected official or candidate for whom the Covered Associate is not

entitled to vote. These de minimis exceptions are available only for contributions by Covered

Associates, not WCM.

Exceptions for Return Contributions. This exception, created to enable Advisers to cure

an inadvertent political contribution made by a Covered Associate to an official for whom the

Covered Associate is not entitled to vote, is available for contributions that in the aggregate, do

not exceed $350 to any one official, per election. WCM must have discovered the contribution

that resulted in the violation within four months of the date such contribution was made, and

within 60 days after learning of such contribution, the contributor must obtain the return of the

contribution.

As such, all political contributions by a Covered Associate to any official, PAC or

through a third party must be pre-cleared to the Compliance Team via the Political Contribution

disclosure form in MCO prior to making the contribution. If and only if a contribution does not

present a conflict of interest or harm WCM’s ability to obtain clients will the Covered Associate

be allowed to make such a contribution. Generally, contributions made by a Covered Associate

to an official for whom the Covered Associate was entitled to vote at the time of the

Contributions and which in the aggregate do not exceed $350 to any one official, per election, or

to an official for whom the Covered Associate was not entitled to vote at the time of the

Contributions and which in the aggregate do not exceed $150 to any one official, per election,

will be approved.

Indirect actions by a Covered Associate that would result in a violation of the Political

Contribution Rule, Rule 206(4)-5, if done directly, are prohibited.

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WCM Code of Ethics

Look-Back Provisions. Advisers are required to maintain a list of government entities to

which the Adviser provides, or has provided, advisory services in the past 5 years, but not prior

to the Rule’s effective date. Furthermore, the Rule's look-back requirements continue to apply to

an Adviser that does not currently have any government entity clients. Consequently, an Adviser

that did not previously provide advisory services to a government entity and, therefore, had not

maintained records required under this Rule, would be required to determine whether any

contributions made by the firm or its Covered Associates, and any former Covered Associates,

would subject the Adviser to the two-year "time out" period prior to the Adviser accepting

compensation from a new government entity client.

The two-year time out restriction will generally apply to WCM in the event that a newly

hired Covered Associate has made a prohibited contribution prior to the commencement of his or

her employment if the Covered Associate solicits clients for the Adviser. The ban will apply for

a "look-back" period of up to two years, beginning from the date of the contribution. However, if

the new Covered Associate does not solicit clients on behalf of the Adviser, the two-year ban

period is reduced to a maximum of six months.

As such, all newly hired Covered Associates must report to the Compliance Team, upon

employment, all political contributions made two years prior to the commencement of his or her

employment.

Furthermore, the two-year or six-month ban will continue to apply to the Adviser for the

duration of the ban period if the Covered Associate who made the relevant contribution is no

longer employed by WCM. The SEC has indicated that this 'look-forward' provision is intended

to prevent a firm from channeling contributions through departing employees.

Periodically, the Compliance Team will review the list of Covered Associates, and the

list of government entity clients for accuracy and compliance with the Pay-to-Play rule.

The following will be maintained by the Compliance Team for a period of five years

from fiscal year end of last use, with at least two years on-site:

•Names, titles and address (business & home) of Covered Associates

•Clients that are government entities (past 5 years, not prior to September 13,

2010)

•All direct and indirect contributions made by adviser and Covered Associate (in

chronological order) indicating:

oName and title of each contributor

oName and title of each recipient

oAmount and date of each contribution or payment

oWhether subject to exception from returned contributions

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WCM Code of Ethics

5.Interest in Transactions

No Supervised Person, or member of his or her Immediate Family, shall engage in any

transaction involving WCM if the Supervised Person or a member of his Immediate Family has a

substantial interest in the transaction or can benefit directly or indirectly from the transaction

(other than through the Supervised Person’s normal compensation), except as specifically

authorized in writing by the Chief Compliance Officer.

6.Acting as a Registered Representative of a Broker-Dealer

A Supervised Person of WCM may only act as a Registered Representative of a Broker-

Dealer upon prior written approval from the Chief Compliance Officer. The Chief Compliance

Officer may approve such activity, only after applicable licensing requirements have been met

and appropriate disclosures have been made in Parts 1, 2A and 2B of Form ADV and the

individual’s Form U-4.

7.Diversion of WCM Business or Investment Opportunity

No Supervised Person shall acquire, or derive personal gain or profit from, any business

or investment opportunity that comes to his or her attention as a result of his or her association

with WCM, and in which he or she knows WCM or its clients might reasonably be expected to

participate or have an interest, without first disclosing in writing all relevant facts to WCM,

offering the opportunity to WCM or its clients, and receiving specific written authorization from

the Chief Compliance Officer.

VI.GENERAL STANDARDS OF CONDUCT IN DEALING WITH CLIENTS

AND PROSPECTIVE CLIENTS

Supervised Persons of WCM must adhere to the following standards at all times:

A.Fair and Equitable Treatment of Clients

All clients must be treated fairly and equitably. No client may be favored over another.

B.No Guarantees Against Loss

No Supervised Person may guarantee a client against losses with respect to any securities

investments or investment strategies.

C.No Guarantees or Representations as to Performance

No guarantee may be made that a specific level of performance will be achieved or

exceeded. Any mention of an investment’s past performance or value must include a statement

that it does not necessarily indicate or imply a guarantee of future performance or value.

D.No Legal or Tax Advice

No Supervised Person may give or offer any legal or tax advice to any client regardless of

whether the Supervised Person offering such advice is qualified to do so.

E.No Sharing in Profits or Losses

No Supervised Person may directly share in the profits or losses of a client’s account.

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WCM Code of Ethics

F.No Borrowing From or Lending To a Client

No Supervised Person may borrow funds or securities from, or lend funds or securities to,

any client of WCM.

G.Supervised persons May Not Act as a Custodian of a Client

No Supervised Person may act as custodian of securities, money, or other funds or

property of a client.

H.Orders May Not Be Placed Through Unlicensed Broker-Dealers or Agents

No Supervised Person shall place an order to purchase or sell a security for a client

through a broker-dealer or agent or any bank unless such broker-dealer or agent or bank is

properly registered or is exempt from registration in the state in which the client resides.

I.Executing Transactions or Exercising Discretion Without Proper

Authorization

No Supervised Person shall execute any transaction on behalf of a client or exercise any

discretionary power in effecting any transaction for a client account unless WCM has (i)

obtained written authority from the client and (ii) authorized the Supervised Person’s execution

of client transactions or exercises discretionary authority with respect to that client.

VII.PROTECTION OF MATERIAL, NONPUBLIC AND OTHER

CONFIDENTIAL INFORMATION AND PREVENTION OF INSIDER

TRADING AND TIPPING

A.Need for Policy

WCM and its Supervised Persons have access to confidential information about clients of

WCM, investment advice provided to clients, securities transactions executed for clients’

accounts and other sensitive information. In addition, from time to time, WCM or its Supervised

Persons may come into possession of information that is “material” and “nonpublic” (each as

defined below) concerning a company or the trading market for its securities.

It is unlawful for WCM or any of its Supervised Persons to use such information for

manipulative, deceptive or fraudulent purposes. The kinds of activities prohibited include “front-

running”, “scalping” and trading on inside information. “Front-Running” refers to a practice

whereby a person takes a position in a security in order to profit based on his or her advance

knowledge of upcoming trading by clients in that security which is expected to affect the market

price. “Scalping” refers to a similar abuse of client accounts and means the practice of taking a

position in a security before recommending it to clients or effecting transactions on behalf of

clients, and then selling out of the Supervised Person’s personal position after the price of the

security has risen on the basis of the recommendation or client transactions.

Depending upon the circumstances, WCM and any Supervised Person could be at risk of

violating federal securities laws for insider trading or tipping if they advise clients concerning, or

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WCM Code of Ethics

execute transactions in, securities with respect to which WCM possesses material, nonpublic

information (“MNPI”). In addition, WCM as a whole may be deemed to possess MNPI known

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WCM Code of Ethics

by any of its Supervised Persons, unless WCM has implemented procedures to prevent the flow

of that information to others within WCM.

Section 204A of the Advisers Act requires that WCM establish, maintain and enforce

written policies and procedures reasonably designed to prevent the misuse of MNPI by WCM

and its Supervised Persons. Violations of the laws against insider trading and tipping by WCM

Supervised Persons can expose WCM and any Supervised Person involved to severe criminal

and civil liability. In addition, WCM and its Supervised Persons have ethical and legal

responsibilities to maintain the confidence of WCM’s clients, and to protect as valuable assets,

confidential and proprietary information developed by or entrusted to WCM.

Although WCM respects the right of its Supervised Persons to engage in personal

investment activities, it is important that such practices avoid any appearance of impropriety and

remain in full compliance with the law and the highest standards of ethics. Accordingly,

Supervised Persons must exercise good judgment when engaging in securities transactions and

when relaying to others information obtained as a result of employment with WCM. If a

Supervised Person has any doubt whether a particular situation requires refraining from making

an investment or sharing information with others, such doubt should be resolved against taking

such action.

B.General Policies and Procedures Concerning Insider Trading and Tipping

WCM has adopted the following policies and procedures to: (i) ensure the propriety of

Supervised Person trading activity; (ii) protect and segment the flow of material, nonpublic and

other confidential information relating to client advice and securities transactions, as well as

other confidential information; (iii) avoid possible conflicts of interest; and (iv) identify trades

that may violate the prohibitions against insider trading, tipping, front-running, scalping and

other manipulative and deceptive devices prohibited by federal and state securities laws and

rules.

No Supervised Person of WCM shall engage in transactions in any securities while in

possession of MNPI regarding such securities (so called “insider trading”). Nor shall any

Supervised Person communicate such MNPI to any person who might use such information to

purchase or sell securities (so called “tipping”). The term “securities” includes options or

derivative instruments with respect to such securities and other securities that are convertible into

or exchangeable for such securities.

1.“Material”

The question of whether information is “material” is not always easily resolved.

Generally speaking, information is “material” where there is a substantial likelihood that a

reasonable investor could consider the information important in deciding whether to buy or sell

the securities in question, or where the information, if disclosed, could be viewed by a reasonable

investor as having significantly altered the “total mix” of information available. Where the

nonpublic information relates to a possible or contingent event, materiality depends upon a

balancing of both the probability that the event will occur and the anticipated magnitude of the

event in light of the totality of the activities of the issuer involved. Common, but by no means

exclusive, examples of “material” information include information concerning a company’s

sales, earnings, dividends, significant acquisitions or mergers and major litigation. So called

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WCM Code of Ethics

“market information,” such as information concerning an impending securities transaction, may

also, depending upon the circumstances, be “material.” Because materiality determinations

are often challenged with the benefit of hindsight, if a Supervised Person has any doubt

whether certain information is “material,” such doubt should be resolved against trading

or communicating such information.

2.“Nonpublic”

Information is “nonpublic” until it has been made available to investors generally. In this

respect, one must be able to point to some fact to show that the information is generally public,

such as inclusion in reports filed with the SEC or press releases issued by the issuer of the

securities, or reference to such information in publications of general circulation such as The

Wall Street Journal or other publisher.

3.“Advisory Information”

Information concerning: (i) specific recommendations made to clients by WCM; or (ii)

prospective securities transactions by clients of WCM (“Advisory Information”) is strictly

confidential. Under some circumstances, Advisory Information may be material and nonpublic,

for instance when an adviser manages large enough accounts and trades on such a significant

volume that the trades can have an impact on the market price and supply or demand of the

security being traded.

C.Prohibitions

In the handling of information obtained as a result of employment with WCM and when

engaging in securities transactions, WCM Supervised Persons:

•Shall not disclose material, nonpublic or other confidential information (including

Advisory Information) to anyone, inside or outside WCM (including Immediate

Family members), except to the Chief Compliance Officer or on a strict need-to-

know basis and under circumstances that make it reasonable to believe that the

information will not be misused or improperly disclosed by the recipient;

•Shall refrain from recommending or suggesting that any person engage in

transactions in any security while in possession of MNPI about that security;

•Shall abstain from transactions for their own personal accounts or for the account

of any client, in any security while in possession of MNPI regarding that security;

and

•Shall abstain from personal transactions in any security while in possession of

Advisory Information regarding that security, except in compliance with the

section for Rules Governing Personal Securities Accounts, Holdings, And

Transactions By WCM Access Persons.

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WCM Code of Ethics

D.Protection of Material, Nonpublic Information

No Supervised Person of WCM shall intentionally seek, receive, or accept information

that he or she believes may be material and nonpublic.

In the event that a Supervised Person of WCM should come into possession of information

concerning any company or the market for its securities that the Supervised Person believes may be

material and nonpublic, it is critical that such Supervised Person refrain from either disclosing the

information to others or engaging in transactions (or recommending or suggesting that any person

engage in transactions) in the securities to which such information relates. The Supervised Person

should notify the Compliance Team immediately and file a report in MCO using the “Material

Nonpublic Information” form.

E.Procedures to Safeguard Material, Nonpublic Information

While MNPI may be encountered in many ways, there are certain areas that present a

greater risk of exposure based on WCM’s business practices.

1.Expert Networks

One such area is WCM’s use of “Expert Networks”. To mitigate this risk, any new expert

network will be reviewed and approved by the Compliance Team. As part of that review and

approval, the Compliance Team will review and confirm the adequacy of the Expert Networks’

controls for the protection and handling of MNPI prior to engaging their service. Also, the

Compliance Team will track all interactions (e.g., emails, calls, meetings) between WCM and the

Expert Networks and will have the ability to chaperone calls with or without notice to the

participating analyst or expert. Unless approved by the CCO after ensuring adequate MNPI

protections are in place, Supervised Persons are prohibited from sharing their authorized access

to Expert Networks.

2.Interacting with Potential Insiders

Another area of risk occurs when Supervised Persons meet directly with personnel of

publicly and privately traded companies. The typical (and preferred) method for interaction with

a company is with C-suite or Investor Relations (“IR”) personnel, who are knowledgeable and

have been trained regarding proper handling of MNPI. Regardless, WCM’s Supervised Person

will ensure that we communicate that WCM primarily invests in public equity markets, and we

are not interested in, nor looking to receive material nonpublic information about any publicly

traded company at the start of each call or expert network interaction.

This communication is equally important when interacting with private company

personnel as they may assume based on the private engagement that WCM does not trade in

public equities. Before engaging any personnel of a privately traded company, WCM’s

Supervised Persons will disclose that WCM primarily invests in public equity markets and

confirm with the privately traded company that they do not have any known connections with

publicly traded companies for which WCM may hold a security. If any connection is discovered,

the WCM Supervised Person is prohibited from engaging any personnel in that privately traded

company without the prior approval of the CCO.

If, during a phone call or meeting with any public or private company personnel, a

Supervised Person becomes aware of any information that he or she believes, or has reason to

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WCM Code of Ethics

believe, may be MNPI – regardless of the source (e.g. clients, fund investors, consultants, etc.) –

they should promptly end the call or meeting and immediately consult with the CCO as noted

earlier. Again, the Supervised Person should not share such information with anyone else.

If a Supervised Person is contacted by an Expert, personnel of a publicly or privately

traded company, or industry analyst, via non-business channels (such as personal email or phone,

LinkedIn, or other social media) to discuss WCM’s investment-related activities, the Supervised

Person must redirect the conversation to the proper business channels (WCM email or phone,

Expert Network, etc.) Further communication with such parties on non-business channels is

strictly prohibited.

3.Alternative Data Sources

In addition to the above areas, WCM recognizes the potential risks associated with the

use of alternative data sources. Examples of “alternative data” include information gleaned from

analyses of aggregate social media and internet search data, or other data obtained from apps and

tools that consumers may use. To address these risks, the Compliance Team will conduct

thorough due diligence on these alternative data providers, as outlined in its Vendor Diligence

Policy within the Compliance Manual, to ensure that their data collection and disclosure

practices adequately mitigate the potential of disclosing MNPI.

Like when encountering any other MNPI data point, Supervised Persons are required to

follow established protocols, including the reporting procedures above, when encountering

MNPI with alternative data. The Compliance Team will also monitor and review the use of

alternative data to ensure adherence to these protocols and will update policies as needed to

address emerging risks.

4.“Wall Cross” Requests

On occasion, a company may, as a means to seek investors in restricted or private-

placement securities issued by it, want to share material, nonpublic or other confidential

information with WCM. Such “wall cross” requests may require the temporary separation of

certain Supervised Persons from normal trading activities to prevent any potential misuse of this

information and ensure that MNPI does not influence trading decisions within WCM.

As a result, the following procedures must be followed:

•Identification and Authorization: Before agreeing to a “wall cross” request and

before bringing any other Supervised Persons “over the wall”, the relevant

Supervised Person must receive written approval from the Compliance Team. The

Compliance Team will evaluate the necessity and implications of the wall cross,

considering the context and the parties involved.

•Information Barriers: Once a “wall cross” is authorized, WCM will implement

information barriers to segregate the MNPI from the rest of the firm and its

trading activities. This includes physical and electronic separation of information,

where possible, and restricting access to MNPI to only those Supervised Persons

who are authorized to possess such information.

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WCM Code of Ethics

•Restricted List Management: Until the information becomes public, companies or

securities involved in a “wall cross” will typically be placed on a restricted list for

both personal and firm trading. The restricted list will be regularly updated and

maintained on MCO and INDATA, as appropriate.

5.Review and Monitoring

All firm trading and personal trading by Supervised Persons is monitored for potential

use of MNPI in MCO. Unusual trade activity is flagged by MCO. The CCO, with assistance

from the Compliance Team, will investigate the rationale behind the trade decision, and where

applicable review Expert Network and other relevant business activity, conduct a targeted email

review, and examine trading patterns.

F.Protection of Other Confidential Information

Information relating to past, present, or future activities of WCM or clients that has not

been publicly disclosed, shall not be disclosed to persons, within or outside of WCM, except

within the guidelines of this policy. Supervised Persons are expected to use their own good

judgment in relating to others information in these areas.

In addition, information relating to another Supervised Person’s medical, financial,

employment, legal, or personal affairs is confidential and may not be disclosed to any person,

within or outside of WCM, without the Supervised Person’s consent or for a proper purpose

authorized by the Chief Compliance Officer or an officer of WCM.

G.Procedures to Safeguard Other Confidential Information

In the handling of other confidential information, including Advisory Information,

Supervised Persons of WCM shall take appropriate steps to safeguard the confidentiality of such

information. Although WCM’s offices are not generally open to the public or unannounced

visitors, Supervised Persons must still take precautions to avoid storing nonpublic personal

information in plain view in potentially public areas of WCM’s offices. Furthermore, Supervised

Persons must remove nonpublic personal information from conference rooms, reception areas

and other areas when not in use and always prior to a visit by any third party. Particular care

should be exercised when nonpublic personal information must be discussed or reviewed in

public places such as restaurants, elevators, taxicabs, trains or airplanes, where that information

may be overheard or observed by third parties. For more information and guidance see the

Privacy Policy Compliance Procedures section of the Compliance Manual and the

Information Security Program.

VIII.PROTECTION OF CONFIDENTIAL INFORMATION CONCERNING

CLIENT RECOMMENDATIONS, ADVICE, OR TRADING AND “CHINESE

WALL” PROCEDURES

WCM has adopted the following policies and procedures to limit access to Advisory

Information to those Supervised Persons of WCM who have a legitimate need to know that

information:

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WCM Code of Ethics

A.Designation of Advisory Persons, Access Persons, and Supervised Persons

The Chief Compliance Officer shall designate as “Advisory Persons” those of WCM’s

Supervised Persons who make or participate in decisions as to what advice or recommendations

should be given to clients or what securities transactions should be affected for client accounts,

whose duties or functions relate to the making of such recommendations or who otherwise have

a legitimate need to know information concerning such matters.

All Advisory Persons are Access Persons, but not all Access Persons are necessarily

Advisory Persons. An “Access Person” is a Supervised Person who has access to nonpublic

information regarding any client's purchase or sale of securities, is involved in making securities

recommendations to clients, or has access to such recommendations that are nonpublic. All of the

Company’s directors, officers, and partners are presumed to be Access Persons.

A “Supervised Person” is any partner, officer, director (or other person occupying a

similar status or performing similar functions), or employee of WCM, or other person who

provides investment advice on behalf of WCM and is subject to WCM’s supervision and control.

This may include temporary workers, consultants, independent contractors, and anyone else

designated by the Chief Compliance Officer.

B.Obligations of Advisory Persons

In the handling of Advisory Information, Advisory Persons shall take appropriate

measures to protect the confidentiality of such information. Specifically, Advisory Persons shall

refrain from:

•Disclosing Advisory Information to anyone other than another Advisory Person,

inside or outside of WCM (including any Supervised Person of an affiliate);

except on a strict need-to-know basis and under circumstances that make it

reasonable to believe that the information will not be misused or improperly

disclosed by the recipient; and

•Engaging in transactions — or recommending or suggesting that any person

(other than a WCM client) engage in transactions — in any security to which the

Advisory Information relates.

C.General Policy Concerning Non-Advisory Persons

As a general matter, Non-Advisory Persons of WCM should not seek or obtain access to

Advisory Information. If a Non-Advisory Person of WCM should come into possession of

Advisory Information, he or she should refrain from either disclosing the information to others or

engaging in transactions (or recommending or suggesting that any person engage in transactions)

in the securities to which such information relates. If a Non-Advisory Person of WCM obtains

Advisory Information, he or she should promptly notify the Chief Compliance Officer.

D.Monitoring Compliance with Insider Trading and Tipping Policies and

Procedures and Effectiveness of “Chinese Wall” Procedures

The Chief Compliance Officer or his designee shall use MCO to review initial and annual

holdings reports and quarterly transaction reports for Supervised Person accounts. This review is

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WCM Code of Ethics

designed to: (i) ensure the propriety of the Supervised Person’s trading activity (including

whether pre-approval was obtained as required by the Rules Governing Personal Securities

Accounts, Holdings, And Transactions By WCM Access Persons); (ii) avoid possible conflict

situations; and (iii) identify transactions that may violate the prohibitions regarding insider

trading and manipulative and deceptive devices contained in the federal and state securities laws

and SEC rules. MCO maintains records of review.

The Compliance Team shall report to the Leadership Team any findings of possible

irregularity or impropriety.

IX.RULES GOVERNING PERSONAL SECURITIES ACCOUNTS, HOLDINGS,

AND TRANSACTIONS BY WCM ACCESS PERSONS

The personal investing activities of all WCM Supervised Persons must be conducted in a manner

to avoid actual or potential conflicts of interest with WCM’s clients and WCM itself. No Supervised

Person of WCM may use his or her position with WCM, or any investment opportunities they learn of

because of his or her position, in a manner that creates an actual or potential conflict of interest with

WCM’s clients or with WCM.

The following policies and procedures were adopted to meet WCM’s responsibilities to

clients and to comply with SEC rules. Violations may result in law enforcement action against

WCM and its Supervised Persons by the SEC or state regulators and/or disciplinary action by

WCM against any Supervised Person involved in the violation, including termination of

employment.

All Supervised Persons should read these requirements carefully and be sure that they are

understood. It is particularly important to understand and accept that these pre-clearance

requirements may mean that a Supervised Person will be prohibited from purchasing or selling a

particular security because of client interest in that security. This restriction on a Supervised

Person’s ability to transact in a security can have a harsh impact on individual Supervised

Persons and their Immediate Family members.

A.Who is Covered by These Requirements

Apart from short term or temporary interns who are prohibited from personal trading, all

Access Persons of WCM and members of their Immediate Family who reside in their

household are subject to WCM’s policies and procedures governing personal securities

transactions, with the limited exceptions noted below. An Access Person is defined as a

Supervised Person who has access to nonpublic information regarding clients’ purchase or sale

of securities, is involved in making securities recommendations to clients or who has access to

such recommendations that are nonpublic.

B.What Accounts and Transactions Are Covered

These personal securities policies and procedures cover all personal securities accounts

and transactions for which an Access Person has, or acquires, any direct or indirect beneficial

ownership. Unless approved by the CCO, Access Persons are permitted to hold only those

personal securities accounts that have direct data feeds with MCO.

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WCM Code of Ethics

For purposes of these requirements, “beneficial ownership” has the same meaning as in

Securities Exchange Act Rule 16a-1(a)(2). Generally, a person has beneficial ownership of a

security if he or she, directly or indirectly, through any contract, arrangement, understanding,

relationship or otherwise, has or shares a direct or indirect financial interest in the security. A

transaction and holding by or for the account of an Immediate Family member (living in the

same home with an Access Person) is considered the same as a transaction and holding by the

Access Person.

According to SEC guidelines, the following exemption is permissible. The firm can trade

securities for any of the WCM Access Person accounts as long as the securities are blocked with

client trades. The securities in the trade block allocated to the Access Person are dollar-cost-

averaged or settled at the worst price of the day. All Access Person trades must bear the fiduciary

responsibility of putting the clients’ interests first.

C.What Securities are Covered by These Requirements (“Reportable

Securities”)

All securities (and derivative forms thereof including options and futures contracts) are

covered by these requirements except: (1) direct obligations of the U.S. government (e.g.,

treasury securities); (2) bankers’ acceptances, bank certificates of deposit, commercial paper, and

high quality short-term debt obligations, including repurchase agreements; (3) shares issued by

money market funds; (4) shares of unaffiliated open-end mutual funds; (5) shares issued by unit

investment trusts that are invested exclusively in one or more open-end funds; and (6) shares of

Section 529 College Savings and Prepaid Tuition plans.

D.What Transactions are Prohibited by these Requirements

1.Front-Running or Scalping

Access Persons of WCM are not permitted to “front-run” any securities transaction of a

client or WCM, or to “scalp” by making securities recommendations for clients with the intent of

personally profiting from personal holdings of or transactions in the same or related securities, as

noted in the section, Protection Of Material, Nonpublic And Other Confidential Information

And Prevention Of Insider Trading And Tipping.

2.Short Sales of a Security Held by a Client

No Access Person may sell short any security held in a client’s account managed by

WCM.

3.Use of Confidential or Material, Nonpublic Information

Access Persons may not buy or sell any security if he or she has material, nonpublic

information about the security or the market for the security obtained in the course of his or her

employment with WCM or otherwise, as noted in the section, Protection Of Material,

Nonpublic And Other Confidential Information And Prevention Of Insider Trading And

Tipping.

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WCM Code of Ethics

E.Personal Securities Transactions Which Must Be Pre-Cleared

Before placing any order to purchase or sell any security, or otherwise acquiring or

disposing of a security, including participation in initial public offerings (“IPO”) and limited or

private investments, an Access Person of WCM must pre-clear the transaction with WCM’s

Compliance Team.

Access Persons who have purchased or sold any private investments are required to pre-

clear any subsequent investment in that issuer. However, investments in private equity or private

credit funds do not require pre-clearance for each capital call once the initial investment and

commitment amount have been approved.

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WCM Code of Ethics

Temporary or short-term interns are prohibited from engaging in personal trading while

working for WCM.

Pre-clearance is not required for:

•U.S. government securities;

•U.S. government agency securities;

•Municipal bonds

•shares of any open-end mutual funds and securities of any other registered

investment company, e.g., closed-end funds, exchange traded funds or unit

investment trusts, not affiliated with or sub-advised by WCM;

•high quality short-term debt instruments, such as bankers’ acceptances,

commercial paper, repurchase agreements and bank certificates of deposit;

•purchases through automatic reinvestment of dividends pursuant to a dividend

reinvestment plan;

•involuntary acquisitions or dispositions of securities, such as by inheritance or

court-order upon divorce;

•transactions effected for any account or entity over which the Access Person does

not have or share investment control, such as a “blind trust”;

•transactions in securities through an employer sponsored or other tax qualified

employee benefit plan, such as a 401(k) plan;

•purchases or sales resulting from the exercise or assignment of options;

•purchases or sells in an Access Person’s account which is managed and directed

by WCM;

•Index Futures, Commodity Futures, Interest Rate Futures, Index Options,

Commodity Options and Interest Rate Options.

•purchases or sales in an intern’s Immediate Family Member’s account who shares

the same household as the Access Person, except trades that are in IPOs, private

placements & limited offerings.

•Cryptocurrency (Note: If you are a registered representative of ACA Foreside,

you may have separate requirements regarding digital asset reporting)

•such other securities or transactions as may be added to this list of exceptions in

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WCM Code of Ethics

writing by the Chief Compliance Officer.

F.Obtaining Pre-Clearance

To obtain pre-clearance, an Access Person must log into MCO and submit a pre-

clearance form. Most requests are automatically approved or denied based on conflicts with firm

trades. The CCO or member of the Compliance Team will manually pre-clear Access Persons’

trades that are not able to be automatically approved. A member of the Leadership Team will

pre-clear personal trades of the CCO that cannot be automatically approved by MCO (i.e.,

require manual approval). The status of a pre-clearance request is viewable in MCO under the

employee section “My -> Submissions -> Requests -> Personal Trade Pre-Clearance.”

A pre-clearance approval is valid until the subsequent close of the applicable market.

Several examples:

•Pre-clearance approval for a trade executed in the U.S. market expires at the

subsequent close of the U.S. market (typically 4PM Eastern Time).

oPre-clearance approval on Tuesday evening after the close of market on

Tuesday is valid until the close of market on Wednesday.

oPre-clearance approval on Friday evening after the close of market on

Friday is valid until the close of market on Monday (assuming the market

is open on Monday.)

oPre-clearance approval on Thursday during market hours is valid until

the close of market on Thursday.

•Pre-clearance approvals for a trade executed in a non-U.S. market expires at the

subsequent close of that market.

For trades in instruments or securities that do not adhere to market hours (such as Limited

Partnerships, etc.) pre-clearance approval is valid for 30 days.

Failure to follow the pre-clearance requirements places the firm at risk and therefore is a

consequential matter. In the event an Access Person violates the pre-clearance requirements, the

Compliance Team will email them regarding the violation and inform the Leadership Team. A

pattern of frequent offenses indicates a disregard for the Code and will result in disciplinary

action, such as the revocation of personal trading privileges, fines, and even termination.

G.Identification of Securities Accounts and Reports of Securities Holdings

Access Persons must report all securities accounts (including securities accounts of

Immediate Family members residing in the same household as the Access Person) in which the

Access Person has any direct or indirect “beneficial interest,” by filing a Personal Brokerage

Account Disclosure in MCO. These reports must be completed, as required by the Code of

Ethics Rule, Rule 204A-1, (1) no later than 30 days after the end of each calendar quarter and (2)

in the case of new Access Persons, within 10 days of the individual becoming an Access Person.

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WCM Code of Ethics

The as-of date for initial reports (i.e., when an individual first becomes an Access Person) must

not be older than 45 days.

Accounts with “reportable securities”. Reports for securities accounts holding

“reportable securities” must contain:

1.The title and type of security, and as applicable the exchange ticker symbol or

CUSIP number, number of shares, and principal amount of each reportable

security;

2.The name of any broker, dealer or bank with which the Access Person maintains

an account in which any securities are held for the Access Person's direct or

indirect benefit; and

3.The date the Access Person submits the report.

Accounts without “reportable securities”. Reports for securities accounts holding

securities excluded from the list of “reportable securities” requires only the name of any broker,

dealer or bank with which the Access Person maintains an account and the date the Access

Person submits the report.

Securities accounts linked to MCO satisfy these reporting requirements for the periods in

which the account is linked. If a securities account cannot be linked to MCO or there is a period

of time that the account is not linked, the information noted above must be manually entered into

the form within MCO, or, with approval, e-mailed to the Chief Compliance Office or their

designee.

These reports are reviewed by the Chief Compliance Officer or his designee. The reports

of the Chief Compliance Officer are reviewed by the COO and/or his designee.

If an Access Person has no securities accounts or holdings to report, they must affirm so

through a quarterly affirmation via MCO.

Late reporting is considered a violation of the Code of Ethics and SEC Rule, is not

acceptable and will not be tolerated by WCM. This can lead to disciplinary action against an

Access Person, including possible termination.

H.Reporting of Securities Transactions

SEC rules impose strict requirements on WCM and its Access Persons with respect to the

reporting of personal securities transactions. Access Persons must submit quarterly reports of all

personal securities transactions (including securities accounts of Immediate Family members

residing in the same household as the Access Person) in which the Access Person has a

“beneficial interest,” by filing a transaction report in MCO. This report must be filed no later

than 30 days after the end of each calendar quarter as required by the Code of Ethics Rule, Rule

204A-1.

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WCM Code of Ethics

Transactions of “reportable securities”. Reports for transactions of “reportable

securities” must contain:

1.the date of the transaction, the title, and as applicable the exchange ticker symbol

or CUSIP number, interest rate and maturity date, number of shares, and principal

amount of each reportable security involved the nature of the transaction (i.e.,

purchase, sale or any other type of acquisition or disposition); and

2.the price of the security at which the transaction was effected; the name of the

broker, dealer or bank with or through which the transaction was effected; and the

date the Access Person submits the report.

Transactions of non-“reportable securities”. These transactions do not need to be

reported.

Securities accounts linked to MCO satisfy these reporting requirements for the periods in

which the account is linked. If a securities account cannot be linked to MCO or there is a period

of time that the account is not linked, the information noted above must be manually entered into

the form within MCO, or, with approval, e-mailed to the Chief Compliance Officer or their

designee.

These personal securities transaction reports will be reviewed by the Chief Compliance

Officer or his designee. The reports of the Chief Compliance Officer will be reviewed by the

COO and/or his designee.

If an Access Person has no reportable securities transactions to report, they must affirm

so through a quarterly affirmation via MCO.

Late reporting is considered a violation of the Code of Ethics and SEC Rule, is not

acceptable and will not be tolerated by WCM. This can lead to disciplinary action against an

Access Person, including possible termination.

I.Confidentiality of Personal Securities Information

Access to reports of personal securities transactions, securities holdings, securities

accounts, duplicate confirmations and account statements will be restricted to the Chief

Compliance Officer and such other persons as WCM may designate to assist the Chief

Compliance Officer with review of the reports and pre-clearance. All such materials will be kept

confidential, subject to the right of inspection by the SEC or other government agencies, outside

counsel for compliance purposes, and WCM’s Leadership Team.

J.Addressing Personal Trading Conflicts with Advisory Persons

WCM’s compliance program seeks to provide the greatest amount of flexibility while

still achieving the objective of protecting clients and following rules. Although Advisory Persons

can trade in the same securities as clients, those trades are subject to the pre-clearance

requirements, as mentioned above, as well as additional controls to prevent and remediate

potential conflicts that might occur because of the advisory-related information Advisory

Persons may have access to.

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WCM Code of Ethics

One potential conflict exists when Advisory Persons profit, or perceive to have profited, from

the firm trading of our clients. WCM addresses this potential conflict by restricting Advisory

Persons’ trading within two weeks of a firm trade program in the same security, both after and before

the firm trading occurs.

An Advisory Person may not be aware of the exact timing of a firm trade program, an

Advisory Person may receive approval to trade a certain security after submitting a preclear, only

later to find out that the trade created a conflict once a firm trade program started. Rather than

require an Advisory Person to reverse the trade, this policy allows the Advisory Person to

maintain a position and compare their trade against the least-favored client execution price

(worst for front side; best for back side) in the trade program. An Advisory Person can still

choose to reverse their trade instead.

Front side

•Same side trade

•2 weeks (14 calendar days) before the beginning of client trading

Back side

•Opposite side trade

•2 weeks (14 calendar days) after the last client

trade An Advisory Person can choose one of the following

options:

1.Reverse their trade and donate profits; or

2.Maintain their position and compare their execution price against the least-

favored client execution price, donating any profitable difference.

The procedure above aims to mitigate potential conflicts that may exist with Advisory

Persons trading the same securities of our clients within a window of time where the client

trading may have a reasonably foreseeable impact on marketing pricing.

The CCO, or his designee, will ensure that the appropriate corrective action is taken by the

Advisory Person to neutralize the resulting conflict.

K.Personal Trading Cap

In line with our fiduciary duty, we want to ensure our employees prioritize managing

client accounts over their personal trading activities. To uphold our commitment to clients and

maintain the highest standards of professional conduct, each Access Person is limited to a

maximum of 100 personal trades per calendar year (excluding WCM funds and cash-based

instruments like CDs and money market funds), whether those trades require preclearance or not.

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WCM Code of Ethics

Once an Access Person reaches this cap, their personal trading activity will be restricted for

the remainder of the year.

L.Short Term and Speculative Trading Restriction

To reinforce the firm’s commitment to ethical investment practices and to avoid potential

conflicts of interest, all trading in equity options or futures tied to securities held by WCM or its

clients that have an expiry period and minimum holding period of less than six months are

strictly prohibited. This means the Access Person must not liquidate, close, or otherwise dispose

of the position before the end of the holding period, regardless of market conditions.

Those permissible options or future positions not tied to firm holdings must have at least an

expiration period and minimum holding period of 90 days from the date of purchase or initiation.

This means the Access Person must not liquidate, close, or otherwise dispose of the position

before the end of the holding period, regardless of market conditions.

Any Access Person found to be in violation of this policy must immediately close the

position in question. Any gains realized from the closing of the prohibited position must be

donated to a charitable organization approved by the Compliance Team. The Access Person will

absorb any losses incurred.

M.Waivers

The Chief Compliance Officer may, in his discretion, after consultation with the

Leadership Team, waive compliance by any person with any of the restrictions and pre-clearance

requirements set forth herein, if the Leadership Team finds that such a waiver: (i) is necessary to

alleviate hardship in view of unforeseen circumstances or is otherwise appropriate under all of

the relevant facts and circumstances; (ii) will not be inconsistent with the purposes of WCM’s

policies and procedures governing personal securities transactions; (iii) will not adversely affect

the interests of clients or WCM; and (iv) is not likely to permit a transaction or conduct that

would violate provisions of applicable laws or rules.

Any waiver shall be documented by the Chief Compliance Officer and shall state the

basis for the waiver. The Chief Compliance Officer shall promptly send a copy of the waiver to

the Leadership Team and shall maintain a copy in the Compliance program folders or MCO.

X.REPORTING TO THE MUTUAL FUND BOARD

No less frequently than quarterly, the Chief Compliance Officer or his/her designee will

furnish to the Board of Directors of all mutual funds managed by WCM, a written report that:

•Describes any issues arising under the Code of Ethics since the last report to the

Board of Directors, including, but not limited to, information about material

violations of the Code of Ethics, or procedures and sanctions imposed in response

to any material violations; and

•Certification that WCM has adopted procedures reasonably necessary to prevent

Supervised Persons, including Access Persons, from violating the Code of Ethics.

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WCM Code of Ethics

The Firm will furnish to the Board of Directors of all mutual funds managed by WCM, a

copy of the Code of Ethics and any material changes to the Code of Ethics.