Eagle Harbor Asset Management, Inc.

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Code of Ethics

Eagle Harbor Asset Management, Inc.

800 Fifth Avenue
Suite 4100
Seattle, WA 98104

206.224.4101 +800.642.5510

inquiry@ehaminc.com

Eagle Harbor Asset Management, Inc. is a registered investment adviser in the State of Washington. The adviser may not transact business in states where it is not appropriately registered, excluded or exempted from registration. Individualized responses to persons that involve either the effecting of transaction in securities, or the rendering of personalized investment advice for compensation, will not be made without registration or exemption.

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