Code of Conduct and Code of Ethics for Finance Professionals

Code of Conduct

Our integrity and reputation rely on our ability to do the right thing during moderate and turbulent periods. The Code of Conduct is a collection of rules and principles intended to guide employees and directors in making informed decisions about their conduct in relation to the firm’s business. The Code is based on the fundamental understanding of a collective responsibility to conducting business ethically and to uphold the firm's view that, our members should not sacrifice integrity to advance and aid the firm’s operations. Access the Ridgeway & Prospect Code Of Conduct for more information.

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Code of Ethics for Finance Professionals

The purpose of the Code of Ethics for Finance Professionals is to promote honest and ethical conduct and adherence with the law, particularly as related to the maintenance of Ridgeway & Prospect financial books and records and the preparation of the firm's financial statements. Not complying with the applicable ethics laws and regulations will result in significant legal and regulatory exposure to the firm, as well as tarnish the firm's reputation.

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The obligations outlined by this Code of Ethics are a supplement to, and do not replace employee responsibilities and obligations listed in the firm's Code of Conduct . Adherence to this Code of Ethics is a term and condition of employment for Finance Officers and Professionals. The firm will take all necessary actions to enforce it, up to and including immediate dismissal. Violations of the Code of Ethics may also constitute violations of law, which may expose both employees and the firm to civil and possible criminal penalties.

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The Code of Ethics applies to the conduct and reporting requirements of the Chief Executive Officer, Chairman, Chief Financial Officer and Principal Accounting Officer of the firm (Finance Officers) and to all other professionals of the firm worldwide serving in a finance, accounting, Line of Business Treasury, tax or investor relations duty.

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Standards of Conduct

Finance Officers and Finance Professionals must act honestly, promote ethical conduct and comply with the law, particularly as related to the maintenance of the firm's financial books and records and the preparation of its financial statements. They are specifically required to:

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• Carry out their responsibilities honestly, in good faith and with integrity, due care and diligence, exercising at all times their best independent judgment

• Comply with applicable government laws, rules and regulations of federal, state and local governments and other appropriate regulatory agencies

• Never take, directly or indirectly, any action to coerce, manipulate, mislead or fraudulently influence the firm's independent auditors in the performance of their audit or review of the firm's financial statements

• Assist in the production of full, fair, accurate, timely and understandable disclosure in reports and documents that the firm and its subsidiaries file with, or submit to, the Securities and Exchange Commission and other regulators and in other public communications made by the firm

• Take all reasonable measures to protect the confidentiality of non-public information relating to the firm and its clients

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Reporting Requirements

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Finance Officers and Finance Professionals must:

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• Address actual or apparent conflicts of interest between personal and professional relationships by disclosing to their appropriate Legal or Compliance officer any material transaction or relationship that reasonably could be expected to give rise to such a conflict, including but not limited to those with firm customers, suppliers, business associates, and employees with whom they work and/or support, and

• Promptly report (anonymously, if they wish to do so) any known or suspected violation of the Code of Ethics or any other matters that would compromise the integrity of the firm's financial statements

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Reports may be made anonymously to the Online available reporting email or in any of the ways set forth in the Code of Conduct (see below).

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The reporting requirements do not prevent employees from reporting to the government or regulators conduct that the employee believes to be in violation of law, and it does not require employees notifying the firm prior to reporting to the government or regulators.

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The firm strictly prohibits intimidation or retaliation against anyone who makes a good faith report about a known or suspected violation of the Code of Ethics, or of any law or regulation.

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Reporting Online

The online resources are available 24 hours a day, 7 days a week. Report to us at:

www.ridgewayprospect.com/report