Code of Ethics

Code of Ethics

Interfund Management Services, Inc.

Interfund Management Services, Inc. (IMS) is an investment adviser registered with the State of Washington to engage in the investment advisory business. SEC Rule 204A-1 (the Rule) under The Investment Advisers Act of 1940, as amended, requires all registered investment advisers to adopt a code of ethics that sets forth standards of conduct and requires IMS Representatives (enumerated below) to comply with all applicable federal securities laws. This document contains the Code of Ethics (the Code) for IMS. The Code is intended to reflect the fiduciary principles that govern the conduct of the Investment Adviser Representatives associated with IMS (IMS Representatives). Active IMS Representatives are John Krehbiel, owner and compliance officer (Compliance Officer), Karen Krehbiel, secretary/treasurer of IMS, and Jamie Low, branch manager and assistant to John Krehbiel in all phases of IMS operations. Inactive IMS Representatives are Mark Adams, Ron Krehbiel, Verlin Frickel, Robert Welsh and Don Anderson.

Furthermore, IMS Representatives have a fiduciary obligation to act in the best interest of the client at all times. To that end, IMS requires IMS Representatives to conduct all business dealings in an ethical fashion and to abide by not only the technical requirements of the Code, but also to the spirit in which it is intended. When in doubt, IMS Representatives should seek advice of the Compliance Officer. When dealing with investment advisory clients and services, IMS Representatives should fully disclose all material facts concerning any conflicts of interest that exist or arise. A conflict of interest may arise when a person or firm has an incentive to serve one interest at the expense of another interest or obligation. IMS Representatives are required to abide by all applicable federal and state securities laws.

Among other restrictions, IMS Representatives are not permitted to:

  • Defraud a client in any manner

  • Mislead a client, including by making any statement that omits material facts

  • Engage in any act, practice or course of conduct that operates or would operate as a fraud or deceit on a client

  • Engage in any manipulative practice with respect to a client

  • Engage in any manipulative practice with respect to securities, including price manipulation

  • Favor the interests of one client over another client

In the course of normal business activities, IMS Representatives may receive confidential information concerning clients and potential clients. To maintain client confidence and trust, this information must be handled with integrity and discretion. As a general rule, confidential information pertaining to a client of IMS should never be communicated to anyone other than the authorized individual of IMS who needs to know, and where appropriate, to the participants involved in a specific transaction. A judgment concerning who needs to know about particular client information depends on the facts and circumstances and, should a question arise, be discussed by the IMS Representative with the Compliance Officer.

Participation or Interest in Client Transactions and Personal Trading Practices

IMS manages trades in mutual fund shares exclusively and is not subject to insider trading laws or, in the course of its normal business activities, to the rules related to non-public information. IMS does not have persons who have access (access persons) to non-public information associated with its client’s investments. IMS permits IMS Representatives to maintain personal securities accounts or holdings at other financial institutions without supervision.

IMS Representatives are required to report to the Compliance Officer any holdings of securities in which they have a beneficial interest that are not exempt from the reporting requirements. Exempt securities include:

  • Direct obligations of the U.S. government

  • Money market instruments, including bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements, and other high-quality short-term debt instruments.

  • Shares issued by money market funds

  • Shares issued by open-end mutual funds (other than exchange traded funds)

  • Shares issued by open-end unit investment trusts (UITs) if the UIT is invested exclusively in unaffiliated open-end mutual funds (other than exchange traded funds) Personal Securities Accounts The following personal securities accounts are not reportable under the Code unless they hold Reportable Securities:

  • 401(k) and 403(b) retirement plan accounts that only holds open end mutual funds (other than exchange traded funds)

  • Accounts held directly at mutual fund companies (mutual fund only accounts)

  • Accounts held directly at 529 college savings plans

  • Variable annuity contracts

IMS Representatives are required to obtain pre-clearance for all non-exempt personal securities transactions. The participation of any IMS Representative, their friends or family members, in any security that is the subject of an initial public offering or a limited offering must be reported to the Compliance Officer.

If any IMS Representative has violated this Code, the making of a report will not protect them from the consequences of their actions. Material violations of the Code must be immediately reported to the Compliance Officer. Examples include material violations of applicable securities rules and regulations, fraud, or illegal acts involving any aspect of the firm’s business, material misstatements in client records, or reports of any material activity that is harmful to clients. Violations of the Code may result in disciplinary action including but not limited to warnings, fines, suspension, or termination of employment or licensing.

Acknowledgement of Receipt of the Code.

All active IMS Representative are required to acknowledge receipt of delivery of this Code annually. Furthermore, any mid-year material amendments to the Code may also require acknowledgement.

Distribution of the Code of Ethics

All active IMS Representatives will be required to sign an acknowledgement statement indicating that they have reviewed the current Code of Ethics. The Code is included as an addendum to the IMS Policies and Procedures manual and can be reviewed at the IMS website www.imsincome.com under the heading Client Center. It is the responsibility of all active IMS Representative to read, understand, and abide by all aspects of the Code.