Code of Ethics

Verisail Partners, LLC

Code of Ethics

STANDARD OF CONDUCT AND COMPLIANCE WITH LAWS, RULES, AND REGULATIONS

The foundation of Verisail Partners’s ethical standards is compliance with the letter and spirit of the law. We will respect and obey all of the laws, rules and regulations applicable to our business, including among others, securities, banking and other federal, state and local laws.

Verisail Partners, LLC takes great pride in our commitment to serving our clients’ needs with integrity. We will conduct business honestly and ethically wherever we operate.  We will constantly improve the quality of our services, products and operations and will create a reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment.  No illegal or unethical conduct on the part of officers, directors, employees or affiliates is in the company’s best interest. Verisail Partners, LLC will not compromise its principles for short-term advantage.  The ethical performance of this company is the sum of the ethics of the men and women who work here.  Thus, we are all expected to adhere to high standards of personal integrity.

This Code of Ethics sets forth the standard of business conduct that is required of all officers, directors and employees of Verisail Partners, LLC.  All officers, directors and employees are responsible for, and have agreed as a requirement of their employment, to review this Code of Ethics for acting in compliance with these policies in daily activities.  Clients and potential clients will be provided a copy of the Code of Ethics at any time upon request.

INVESTMENT ADVISOR STANDARD OF CONDUCT

Investment advisors of Verisail Partners, LLC, shall serve their clients with integrity, competence, independence, and due care.  As a fiduciary, we shall achieve a thorough understanding of a client’s current situation, concerns, needs, and goals before providing any financial planning and/or related services.  Investment advice shall be given based on the client’s objectives, goals, risk tolerance, and time horizon, among other factors.  Investment advisors shall also process all client requests for information and resolve any client issues in a timely, complete, and truthful manner.  Serving the client is the foremost priority, always.

PROTECTION OF MATERIAL NONPUBLIC INFORMATION

Officers, directors, and employees of the company must never permit their personal interests to conflict, or appear to conflict, with the interests of the company, its clients or affiliates.  Officers, directors and employees must be particularly careful to avoid representing Verisail Partners, LLC in any transaction with others with whom there is any outside business affiliation or relationship.  Officers, directors, and employees shall avoid using their company contacts to advance their private business or personal interests at the expense of the company, its clients or affiliates.

Officers, directors and employees shall avoid gifts, gratuities, fees, bonuses or entertainment that is excessive in nature, in order to attract or influence business activity.

Officers, directors and employees of Verisail Partners, LLC will often come into contact with, or have possession of, proprietary, confidential or business-sensitive information and must take appropriate steps to assure that such information is strictly safeguarded. Proprietary, confidential and sensitive business information about this company, clients, and other entities should be treated with sensitivity and discretion and only be disseminated on a need-to-know basis.  Officers, directors and employees are reminded that they must review the Privacy Statement of Verisail Partners, LLC on a periodic basis.  Please review our Privacy Statement for a detailed report on the company’s privacy commitment to you.

OTHER DUTIES OF OFFICERS, DIRECTORS, AND EMPLOYEES

Officers, directors and employees will seek to report all information accurately and honestly, and as otherwise required by applicable reporting requirements.

OTHER DUTIES OF OFFICERS, DIRECTORS, AND EMPLOYEES CONT’D

Officers, directors and employees will obey all Equal Employment Opportunity laws and act with respect and responsibility towards others in all of their dealings.

Officers, directors and employees will remain personally balanced so that their personal life will not interfere with their ability to deliver quality products or services to the company and its clients.

Officers, directors and employees agree to disclose unethical, dishonest, fraudulent and illegal behavior, or the violation of company policies and procedures, directly to management.

All access persons will report their personal securities transactions and holdings to the Chief Compliance Officer periodically.  The SEC defines an access person as “any supervised person who has access to nonpublic information regarding any client’s purchase or sale of securities, or nonpublic information regarding the portfolio holdings of any reputable fund, or who is involved in making securities recommendations to clients, or who has access to such recommendations that are nonpublic.”  Under this Code, officers and directors are presumed to be access persons.

RECORDKEEPING

Rule 204-2(a) (12) and (13) of the Advisers Act requires advisors to keep copies of all relevant material relating to the Code of Ethics. Verisail Partners, LLC will provide each officer, director, and employee with a copy of this Code of Ethics and any amendments, and all officers, directors, and employees are required to provide Verisail Partners, LLC with a written acknowledgment of their receipt of the Code of Ethics and any amendments.

CONSEQUENCES FOR FAILURE TO COMPLY AND REPORTING VIOLATIONS

Violation of this Code of Ethics and its component parts, which includes the Privacy Statement, can result in discipline, including possible termination.  The degree of discipline relates in part to whether there was a voluntary disclosure of any ethical violation and whether or not the violator cooperated in any subsequent investigation.

If you know of, or reasonably believe there is a violation of applicable laws or this Code of Ethics, you must report that information immediately to the Chief Compliance Officer. You should not conduct preliminary investigations, unless authorized to do so by the Chief Compliance Officer. Anyone who in good faith raises an issue regarding a possible violation of law, regulation or company policy or any suspected illegal or unethical behavior will be protected from retaliation.