Beacon Policy Advisors LLC’s Policy and Procedures to Ensure Avoidance of Collection, Receipt and/or Dissemination of Material, Non-Public or Other Relevant Confidential Information

Beacon Policy Advisors LLC (Beacon) is an independent policy research firm that provides unbiased, objective research and analysis to institutional investors about public policy in the legislative, regulatory, political, and geopolitical spheres based upon Beacon’s proprietary “mosaic research” methods.

Beacon does not have any direct or indirect interest in any particular policy outcome and does not have any access to material, non-public information of any private or public sector entities that are seeking to impact particular policy outcomes. Beacon is not affiliated with any lobbying, advocacy, or governmental relations firm and does not conduct any such activities on its own. However, to avoid the creation of a conflict of interest or improper activity, or the appearance of a conflict of interest or improper activity, Beacon employees adhere to congressional and executive branch gift rules applicable to lobbyists.

Beacon understands that as part of its respective clients’ daily business, Beacon’s clients buy and sell securities. Beacon does not recommend individual investments. Although research reports and/or consultations may mention specific companies by name and/or specific industries and industry sectors, Beacon has not conducted and has not included in these consultations and/or research reports fundamental or other detailed analysis of the securities of the identified companies, industries and/or industry sectors. The decision to sell or purchase a security rests solely with the client.

Beacon does not seek to acquire material non-public information of any kind in the course of its policy research activities and only conducts its ongoing policy research efforts in accordance with all relevant laws, regulations and policies, including, but not limited to, applicable federal and state securities laws and regulations.

Beacon discloses to persons it contacts in connection with its research that Beacon has been engaged by an investment firm that buys and sells securities to assist it in its analysis and that Beacon is not seeking, and does not want to receive, any confidential information. Beacon does not seek to obtain any information from a government employee where disclosure of any such information by the government employee would violate any law, regulation or policy.

Beacon does not disseminate nor permit the dissemination by any of its employees, officers, principals or agents, of any non-public information regarding any company, or any other disclosure in violation of law or regulation or any contractual or other duty or obligation of any nature.

Beacon safeguards proprietary information received from clients and will ensure that such proprietary information is not shared with any unauthorized parties, including, but not limited to, other Beacon clients.

If Beacon becomes aware of any improper disclosure to any of its clients or any of their respective employees or agents by any employee, agent, or principal of Beacon, it will notify such client in writing as soon as reasonably practicable, and will describe with reasonable specificity the nature of the disclosure, and will use commercially reasonable efforts to cooperate with such client in any investigation of, or action against (or threatened against), such client and its employees, including portfolio or account managers of such client, or any of its affiliates relating to or arising out of such disclosure.

Beacon employees will participate in mandatory periodic training sessions with regulatory counsel to ensure compliance with this policy and the associated procedures described herein. Beacon employees will also re-affirm in writing on an annual basis their understanding and compliance with this policy and acknowledge that they and Beacon could be subject to disciplinary action, including termination, and/or legal liability for any violation thereof.