Management  and employees of MVP have committed to a Code of Ethics (“Code”) that  adheres to the current standards set forth by the CFA Institute. MVP’s  Code defines acceptable behavior for management and employees of MVP and  addresses conflicts that may arise. The Code reflects MVP’s overriding  guiding principle that it is the Company’s responsibility to act in the  best interest of their clients. As such, investment transactions for  clients must have priority over investment transactions in MVP employee  accounts. In addition, MVP does not allow any employee to use non-public  material information for their personal profit or to use internal  research for their personal benefit in conflict with the benefit to our  clients. As MVP’s policy prohibits any person from acting upon or  otherwise misusing non-public or inside information, no advisory  representative or other employee, officer or director of MVP may  recommend any transaction in a security or its derivative to advisory  clients or engage in personal securities transactions for a security or  its derivatives if the advisory representative possesses material,  non-public information regarding the security. MVP’s  Code is based on the guiding principle that the interests of the client  are our top priority. MVP’s officers, directors, advisors, and other  employees have a fiduciary duty to our clients and must diligently  perform that duty to maintain the complete trust and confidence of our  clients. When a conflict arises, it is our obligation to put the  client’s interests over the interests of either employees or the  Company. The Code applies to “supervised” persons. “Supervised” persons are employees who  have access to non-public information regarding any client purchase or  sale of securities, or non-public information regarding the portfolio  holdings, who are involved in making securities recommendations to  clients, or who have access to such recommendations that are non-public.The firm will provide a copy of its Code of Ethics to any client or prospective client upon request.