Woodlands Asset Management, Inc. ("the Company") recognizes its fiduciary responsibility to its clients. It is the duty and responsibility of the Company and Associated Persons to comply with Federal securities laws and place the interest of the Company’s clients first. Associated Persons shall refer to shareholders, officers, employees, and registered agents. All personal securities transactions are to be conducted consistent with this Code of Ethics, and in such a manner to avoid any actual or potential conflict of interest or to abuse an individual’s position of trust and responsibility. No person associated with the Company should take inappropriate advantage of his or her position and must adhere to all federal and state securities laws and these standards of business conduct. In addition, it is imperative that Associated Persons understand the value Company places on ethical behavior and strive to live up to those ideals.

Personal Transactions
Access Persons (i.e., supervised persons that have access to nonpublic information regarding recommendations to clients on the purchase or sale of securities, clients’ trading information or nonpublic information regarding the portfolio holdings of an affiliated mutual fund, or are involved in providing investment advice to clients) report their personal securities holdings within 10 days of becoming an access person and annually thereafter (if the account is held outside the Company or Woodlands Securities Corporation (WSC) or if the Company/WSC does not already receive duplicate confirmations/statements). Such filings are to be reviewed and retained by Company for a period of three years. This information must be current as of a date not more than 45 days prior to the date the individual becomes an access person or, for an annual report, the date the report is submitted. Access Persons also must report their personal trading activities, if any, quarterly to Company or other designated persons within 30 days after the close of the quarter, unless already received by the Company or WSC. Access Person’s Quarterly Trade reports and any Securities Holding reports will be maintained by Company in a central location.

Exempt from personal trading reports are 1) Transactions and holdings in direct obligations of the Government of the United States; 2) Money market instruments - bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments; 3) Shares of money market funds; 4) Transactions and holdings in shares of other types of mutual funds, unless the adviser or a control affiliate acts as the investment adviser or principal underwriter for the fund; 5) Transactions in units of a unit investment trust if the unit investment trust is invested exclusively in unaffiliated mutual funds; and 6) Interests in a 529 Plan, provided the Company, nor any companies under common control manage, distribute, market, or underwrite the 529 Plan or investments and strategies underlying the 529 Plan.

Given that Company primarily recommends and invests in mutual funds for investment advisory clients, no individuals may directly affect a mutual fund’s price. At no time should personal transactions of Company Associated Persons be of such size to affect mutual fund pricing indirectly. Therefore, Company Associated Persons may trade in mutual fund issues being traded for clients on the same day, before, or after trades are placed for clients.  Personal transactions may not involve market timing or late trading of mutual funds.

Principals and designated, authorized employees of the Company may execute orders on behalf of the Company, their own accounts or other accounts, however, it is a policy of the Company that they must avoid security transactions and activities for these accounts which might conflict with or be detrimental to the interests of clients, or which are designed to profit by market effect of the Company’s advice to its clients. These rules should not be construed in any way that would place the Company’s clients in a disadvantaged trading position.

To the extent that Company Associated Persons are aware of trades in individual issues being considered, recommended, or traded for Company clients, Associated Persons will make every effort to trade in their own accounts after trades are executed for clients. However, at no time are Company client trades or Company Associated Person trades expected to be of such volume as to affect the price of an individual issue.

Insider Information
No employee of the Company will undertake securities transactions for their own account, for accounts in which they have a beneficial interest, or for Clients accounts on the basis of insider information.

Hot Issues/IPOs
Issues that immediately trade at a premium to the IPO price or declared a "Hot Issue" by the underwriter must be allocated only to non-restricted accounts as defined by FINRA. The distribution of equity initial public offering (IPO) shares must be a bona fide public offering and fair distribution to the public. This means that sales will not be made to benefit insiders in the securities industry or to other closely-related parties that might unfairly benefit at the expense of public customers. Associated Persons of the Company are prohibited from purchasing hot issues or equity IPOs.

Commingling
Company employees are not permitted to place customers’ checks or money intended for transactions involving securities into their own bank account or insurance business account, regardless of the amount of money or the length of time involved.  Mishandling customer funds could result in prosecution by state or federal criminal agencies.

Front Running
New issues of securities that immediately begin trading at a higher price than originally offered must be distributed to the public. They may not be placed in employee accounts under any circumstances, and only under strict guidelines may they be placed in the accounts of financial services industry personnel or their immediate families.  In addition, front running involves Associated Persons who either buy for their own account before filling customer buy orders that drive up the price, or sell for their own account before filling customer sell orders that drive down the price.  Associated Persons will make every effort to trade in their own accounts after trades are executed for clients.  However, at no time are Company client trades or Company Associated Person trades expected to be of such volume as to affect the price of an individual issue or Associated Person's trades represent a material difference in price of client trades.

Conflicts of Interest
Avoid conflicts of interest in transactions with customers unless fully disclosed to clients so an informed decision can be made.  In some instances, Associated Persons may invest in the same issues as clients or if any financial interest is received from an investment, it must be disclosed to clients.   

Parking Securities and Maintaining Fictitious Accounts
Holding or hiding securities in someone else’s or a fictitious account is misleading and strictly prohibited.

Private Placements
Investing in private placements by Associated Persons must be cleared by management and disclosed in writing at the time of recommendation to a client or disclosed in the offering memorandum or the Form ADV Part 2A given to the client.

Gifts or Gratuities
No Company Associated Person may give or accept gifts of more than $100 per year in value from any person or entity conducting business with or on behalf of Company.

Personal Trading Review
Trades through the Company are reviewed for violations of any industry or Company rules as well as outside securities accounts are reviewed monthly or quarterly depending on frequency of statements.

Outside Activities
No Company Associated Person may serve on the board of directors of a publicly traded company without written permission from management. All outside activities must be disclosed to management or Compliance prior to or promptly after affiliation with Company.

Violations
Any violations of this Code should be reported to management or compliance. Supervised and Access Persons are encouraged to report any violations and will be protected from retaliation. Any individual of the Company who is the subject of a Code of Ethics violation report and who retaliates against the reporting employee shall be subject to sanctions, including termination of employment.  Reports of violations will be investigated and appropriate actions will be taken by Company.  When investigating a possible violation of the Company's personal trading rules, the CCO will give such person an opportunity to supply additional information regarding the transaction(s) in question.

Recordkeeping
Pursuant to SEC Rule 204A-I, Company will maintain a copy of its Code of Ethics in the Compliance Manual, maintain a record of any violations and any actions taken in reponse to any violations in the Company records, and a copy of the supervised person's acknowledgment and receipt of the Code of Ethics.

Review of the Code of Ethics
The Code will be reviewed at least annually by management and/or Compliance with any applicable changes adopted at that time. All new supervised or Access persons will sign the Code of Ethics Acknowledgment at the time they become supervised or Access Persons. In addition, any amendments will be signed as well with the date of the amendment noted on the acknowledgment.  Any Acknowledgements will be maintained for a period of three years after applicable persons' termination.