Birch Leaf Investments

Staff Compliance/Fairness Policy:

We abide by the Code of Ethics and Standards of Practice as laid out by the CFA Institute.  We treat all clients fairly when disseminating investment recommendations, disseminating material changes in prior investment advice and taking investment action.  We conduct ourselves in such a manner that transactions for all customers and clients have priority over personal transactions.

To eliminate all conflicts of interest, employees of BirchLeaf Investments Inc. are prohibited from investing in the same companies as our clients.

Clients Compliance/Allocation Policy:

BirchLeaf Investments Inc.’s Policy for the allocation of investments is as follows:

The trading policy is an integral part of the portfolio investment management function.  Its objective is to obtain the best possible price for every transaction, minimize overall trading costs and treat every client account fairly regardless of asset size.

No preferential treatment will be given to any client over any other client when transactions are made on behalf of clients with appropriate investment objectives.

Transactions are initiated by client contributions or instructed withdrawals, changes in portfolio asset mix, adding or eliminating a particular security, increasing or decreasing the weight of a particular holding.

Fully and partially completed transactions for the same security, including allotments of new issues and secondary offerings, combined for two or more clients are allocated proportionally based on the concurrent market values of participating portfolios net of commissions if any, subject to adjustments as reasonably required to achieve a minimum size of holding necessary to justify holding the security in an account or to maintain efficient trading units.

If the client elects to direct BirchLeaf Investments Inc. to perform an investment transaction(s) that is outside of the product offerings, in acting pursuant to any such direction, BLI shall be released from any responsibility with respect to such transaction(s) and you shall assume full responsibility for the result of any such transaction(s).

BirchLeaf Investments Inc. will maintain complete and accurate trading records including those for combined transactions.  All of the staff of BirchLeaf Investments Inc. will be ensuring full compliance with this policy.