This Code of Ethics ("Code") has been adopted by by Northern Capital Management, Inc.

and is designed to comply with Rule 204A-1 under the Investment Advisers Act of 1940 (“Advisers Act”).

This Code establishes rules of conduct for all employees of Northern Capital Management, Inc. and

is designed to, among other things, govern personal securities trading activities in the accounts of

employees. The Code is based upon the principle that Northern Capital Management, Inc. and its

employees owe a fiduciary duty to Northern Capital Management, Inc.'s clients to conduct their

affairs, including their personal securities transactions, in such a manner as to avoid (i) serving their

own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the

firm and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and

responsibility.

The Code is designed to ensure that the high ethical standards long maintained by Northern Capital

Management, Inc. continue to be applied. The purpose of the Code is to preclude activities which

may lead to or give the appearance of conflicts of interest, insider trading and other forms of

prohibited or unethical business conduct. The excellent name and reputation of our firm continues to

be a direct reflection of the conduct of each employee.

Northern Capital Management, Inc. will provide a complete copy of our Code of Ethics to any current or prospective client upon request.