CODE OF CONDUCT AND ETHICS (CODE)

Each director should seek to use due care in the performance of his / her duties, be loyal to the Trust, act in good faith and in a manner such director reasonably believes to be not opposed to the best interests of the Trust. A director should seek to also:

make reasonable efforts to attend Board and committee meetings;

dedicate time and attention to the Company;

seek to comply with all applicable laws, regulations, confidentiality obligations and Trust policies.

In carrying out their duties and responsibilities, employees and directors are prohibited from:

appropriating Trust business opportunities for themselves that are discovered through the use of Trust resources or information or their position as directors or employees;

using Trust resources or information, or their position as directors or employees, for personal gain; and

competing with the Trust, directly or indirectly.

A Trust business opportunity is an opportunity:

which is in the Trust's line of business or proposed expansion or diversification,

which the Trust is financially able to undertake and

which may be of interest to the Trust. A director or employee who learns of such a trust business opportunity and who wishes to avail of it should first disclose such opportunity to the Board of Trustees. If the Board of Trustees determines that the Trust does not have an actual or expected interest in such opportunity, then, and only then, may the director or employee avail of it, provided that the director or employee has not wrongfully utilized the Trust's resources in order to acquire such opportunity.

A "conflict of interest" occurs when the private interest of an employee, officer or director interferes in any way - or even appears to interfere - with the interests of the Trust. A conflict situation can arise when an employee, officer or director takes actions or has interests that may make it difficult to perform his or her work objectively and effectively. Conflicts of interest also arise when an employee, officer or director, or a member of his or her family, receives improper personal benefits as a result of his or her position in the Trust. Each employee and director should avoid having his or her private interests interfere with

the interests of the Trust or

his or her ability to perform his or her duties and responsibilities objectively and effectively.

Employees and directors should avoid receiving, or permitting members of their immediate family to receive, improper personal benefits from the Trust, including loans from or guarantees of obligations by the Trust. A director should make a full disclosure to the Board of any transaction or relationship that such a director reasonably expects could give rise to an actual conflict of interest with the Trust and seek the Board's authorization to pursue such transactions or relationships.

In carrying out their duties and responsibilities, all employees and directors should endeavor to protect the Trust's assets and proprietary information, and ensure that the same are being used by the Trust and its employees only for legitimate business purposes of the Trust. Any suspected incident of fraud, mismanagement of Trust assets or theft should be immediately reported for investigation to the Chairman of the Board or such other person as designated in this regard. 

Employees and directors should maintain the confidentiality of confidential information entrusted to them in carrying out their duties and responsibilities, except where disclosure is approved by the Trust or legally mandated or if such information is already in the public domain. Confidential information includes all non public information that might be of use to competitors, or harmful to the Trust or its customers, if disclosed. The Trust's confidential information shall not be inappropriately disclosed or used for the personal gain or advantage of anyone other than the Trust. These obligations apply while employed or serving as a director of the Trust even after employment or the director's term with the Trust ends. 

In carrying out their duties and responsibilities, employees and directors should endeavor to deal fairly, and should promote fair dealing by the Trust, its employees and agents, with customers, suppliers and competitors.

No employee or director should seek to take unfair advantage of anyone (including the Trust) through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice.

In carrying out their duties and responsibilities, directors and employees must comply with applicable laws, rules and regulations. In addition, if any director or employee becomes aware of any information that he or she believes constitutes evidence of a violation of any securities or other laws, rules or regulations applicable to the Trust or the operation of its business, by the Trust, any employee or director, then such employee or director should bring such information to the attention of the Chairman of the Board or such other person as designated in this regard.

The Trust holds information and training sessions to promote compliance with applicable laws, rules and regulations, including insider trading laws and it is the responsibility of each director and employee to attend such training sessions.

Employees and directors should observe all applicable laws and regulations including the Trust's policies and codes as applicable to them with respect to the purchase and sale of the Trust's securities.

All non public information about the Trust should be considered confidential information. To use non public information for personal financial benefit or to "tip" others who might make an investment decision on the basis of this information is not only unethical but also illegal. A more detailed discussion of the insider trading laws can be found in the Trust's Code of Conduct for prevention of Insider Trading.

It is the responsibility of each employee and director to become familiar with and understand these laws, regulations, policies and codes, and to seek further explanations and advice concerning their interpretation, if required.

Directors and employees should endeavor to promote ethical behavior and to encourage employees to report evidence of illegal or unethical behavior to appropriate Trust personnel. It is the policy of the Trust to not allow retaliation against any employee who makes a good faith report about a possible violation of this Code.

Suspected violations of this Code may be reported to the Chairman of the Board. All reported violations will be appropriately investigated. When in doubt of the best course of action in a particular situation, employees are encouraged to talk promptly to their supervisor, managers or the Head of Human Resources. Employees are expected to fully cooperate in internal investigations of misconduct.

A director charged with a violation of this Code should not participate in a vote of a Committee or the Board concerning his/her alleged violation, but may be present at a meeting of the Board or of a Committee convened for that purpose.

Special Reporting Obligations and Procedures Relating to Concerns Regarding Accounting or Auditing Practices

Employees should bring to the attention of the Audit Committee of the Board of Trustees any questions, concerns or complaints they may have regarding accounting, internal accounting controls or auditing matters. The Audit Committee will shortly notify the procedures for:

The receipt, retention and treatment of complaints received by the Trust regarding accounting, internal accounting controls and auditing matters; and

The confidential, anonymous submission by employees of concerns regarding what they may perceive as questionable accounting or auditing matters.

The Trust requires honest and accurate recording and reporting of information in order to make responsible business decisions. All of the Trust's books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately reflect the Trust's transactions and must conform both to applicable legal requirements and to the Trust's system of internal controls. Records and documents should always be retained or destroyed according to the Trust's record retention policies. The Trust shall provide full, fair, accurate, timely, and understandable disclosure in all reports and documents that it files with, or submits to, any governmental agency or securities exchange, and in other public communications made by the registrant. 

This Code sets forth guidelines for conduct of the employees, officers and directors of the Trust. This Code is not an expressed or implied contract of employment and does not create any contractual rights of any kind between the Trust and its employees. In addition, all employees should understand that the Code does not modify their employment relationship, whether at will or governed by contract. All references in this Code to employees shall include officers. 

Any amendment to this Code must be approved by the Board of Trustees and publicly disclosed as required by any applicable law or regulation.

Any waiver of this Code for the benefit of any employees, officer or director of the Trust may be made only by the Board of Trustees.

We must all work to ensure prompt and consistent action against violations of this Code. However, in some situations there may be "grey areas" for which it may be difficult to know the right thing to do. Since we cannot anticipate every situation that will arise, it is important that we have a way to approach a new question or problem. These are some steps to keep in mind:

Make sure you have all the facts. In order to reach the right solutions, we must be as fully informed as possible.

Ask yourself: What specifically am I being asked to do? Does it seem unethical or improper? This will enable you to focus on the specific question you are faced with, and the alternatives you have. Use your judgment and common sense; if something seems unethical or improper, it probably is.

Clarify your responsibility and role. In most situations, there is shared responsibility. Are your colleagues informed? It may help to get others involved and discuss the problem.

Discuss the problem with your supervisor. This is the basic guidance for all situations. In many cases, your supervisor will be more knowledgeable about the question, and will appreciate being brought into the decision making process. Remember that it is your supervisor's responsibility to help solve problems.

Seek help from the Trust's resources. In the rare case in which it may not be appropriate to discuss an issue with your supervisor or where you do not feel comfortable approaching your supervisor with your question, discuss it with the Head of human resources.

Your report of violations of this Code is in confidence and without fear of retaliation. If your situation requires that your identity be kept secret, your anonymity will be protected. The Trust does not permit retaliation of any kind against employees for good faith reports of violations of this Code or questionable accounting or auditing matters. "Good faith" does not mean that you have to be right - but it does mean that you believe that you are providing truthful information. The important thing is that you bring your question or concern to our attention through one of the available channels.

Always ask first, act later. If you are unsure of what to do in any situation, seek guidance before you act.