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NIA has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business <br /> conduct and fiduciary duty to its clients. The Code of Ethics includes: <br /> • Provisions relating to the confidentiality of client information; <br /> • A prohibition on insider trading; <br /> • Restrictions on the acceptance of significant gifts and the reporting of certain gifts and business <br /> entertainment items; and <br /> • Personal securities trading procedures, among other things. <br /> All supervised persons of NIA must acknowledge the terms of the Code of Ethics annually. <br /> NIA anticipates that, in appropriate circumstances, consistent with clients' investment objectives, it will cause <br /> accounts over which NIA has management authority to make, and will recommend to investment advisory <br /> clients or prospective clients, the purchase or sale of securities in which NIA, its affiliates and/or clients, <br /> directly or indirectly, have a position of interest. NIA's supervised persons are required to follow NIA's Code of <br /> Ethics. Subject to satisfying this policy and applicable laws, supervised persons of NIA may trade for their own <br /> accounts in securities that are recommended to or purchased for NIA's clients. The Code of Ethics is designed <br /> to assure that the personal securities transactions, activities and interests of NIA supervised persons will not <br /> interfere with making decisions in the best interest of advisory clients and implementing these decisions while, <br /> at the same time, allowing supervised persons to invest for their own accounts. <br /> Under the Code of Ethics certain classes of securities have been designated as exempt transactions, because <br /> these classes of securities would not interfere with the best interest of NIA's clients. In addition, the Code of <br /> Ethics requires pre-clearance of certain transactions, and restricts trading in close proximity to client trading <br /> activity. Nonetheless, because the Code of Ethics in some circumstances would permit supervised persons to <br /> invest in the same securities as clients, there is a possibility that supervised persons might benefit from market <br /> activity by a client in a security also held by a supervised person. NIA's supervised persons who have access to <br /> nonpublic information regarding clients' purchases or sales of securities, are involved in making securities <br /> recommendations to clients, or who have access to these nonpublic recommendations, have their personal <br /> trading monitored under the Code of Ethics to reasonably prevent conflicts of interest between NIA and its <br /> clients. <br /> Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis when <br /> consistent with NIA's obligation of best execution. In these circumstances, the affiliated and client accounts <br /> will share commission costs equally and receive securities at a total average price. NIA will retain records of <br /> the trade order (specifying each participating account) and its allocation, which will be completed prior to the <br /> entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. <br /> Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the order. <br /> NIA's clients or prospective clients may request a copy of the firm's Code of Ethics by sending a written request <br /> to: <br /> Nationwide Investment Advisors, LLC <br /> Attn: Investment Adviser Code of Ethics <br /> 10 West Nationwide Blvd, Mail Code 5-04-206J <br /> Columbus,Ohio 43215 <br /> It is NIA's policy that the firm will not make any principal or agency cross securities transactions for client <br /> accounts. NIA will also not cross trades between client accounts. Principal transactions are generally defined <br /> as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker- <br /> dealer, buys from or sells any security to any advisory client. A principal transaction may also occur if a <br /> security is crossed between an affiliated hedge fund and another client account. An agency cross transaction is <br /> defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the <br /> investment adviser, or any person controlled by or under common control with the investment adviser, acts as <br /> 16 <br />