Code of Ethics. I. Definitions

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1 Code of Ethics Old North State Trust, LLC (the Company ) has adopted this Code of Ethics in recognition of the principle that all Supervised Persons (as defined below) of the Company have a fiduciary duty to place clients interests ahead of their own and the Company s. Each Supervised Person of the Company is expected to follow the Standards of Professional Conduct as set forth in this Code of Ethics. In addition, this Code of Ethics sets forth certain special obligations of Access Persons (as defined below) in compliance with Rule 204A-1 promulgated under the Investment Advisers Act of 1940, as amended. I. Definitions A. Access Persons means all employees, directors, officers, partners, or members of the Company, as the case may be, who: (1) have access to nonpublic information regarding Advisory Clients purchases or sales of securities; (2) are involved in making securities recommendations to Advisory Clients; or (3) have access to nonpublic recommendations or the portfolio holdings of any Reportable Fund. All of the Company s directors, officers, members, and Financial Advisors are presumed to be Access Persons. Client services personnel who regularly communicate with Advisory Clients also may be deemed to be Access Persons. B. Advisory Client means any person or entity for which the Company serves as investment adviser, renders investment advice, or makes investment decisions or any fund for which the Company serves as a general partner. C. Beneficial Owner means a person who, directly or indirectly, through any contract, arrangement, understanding, relationship, or otherwise, has or shares a direct or indirect pecuniary interest in a security or an investment. D. Financial Advisor means any Supervised Person who, in connection with his or her regular functions or duties, makes, participates in, or obtains information regarding the purchase or sale of a security by an Advisory Client or whose functions relate to the making of any recommendations with respect to such purchases or sales. E. Reportable Fund means any fund for which the Company serves as an investment adviser or principal underwriter.

2 F. Reportable Securities means all securities of which an Access Person is a Beneficial Owner except: (1) U.S. Government securities; (2) money market instruments (e.g., 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) shares and holdings in other mutual funds unless they are Reportable Funds; and (5) units of a unit investment trust if the unit investment trust is invested exclusively in mutual funds that are not Reportable Funds. G. Supervised Person means any partner, officer, director (or other person occupying a similar status or performing similar functions), or employee of the Company or other person who provides investment advice on behalf of the Company and is subject to the supervision and control of the Company. II. Standards of Professional Conduct A. Compliance with Governing Laws and Regulations, the Code of Ethics, and the Standards of Professional Conduct 1. Required Knowledge and Compliance. All Supervised Persons shall maintain knowledge of and shall comply with all applicable laws, rules, and regulations (including the federal securities laws) of any government, governmental agency, and regulatory organization governing his or her professional, financial, or business activities, as well as with these Standards of Professional Conduct and the accompanying Code of Ethics. 2. Prohibition Against Assisting Legal and Ethical Violations. No Supervised Person shall knowingly participate in or assist any acts in violation of any applicable law, rule, or regulation of any government, governmental agency, or regulatory organization governing his or her professional, financial, or business activities, or any act that would violate any provision of these Standards of Professional Conduct or the accompanying Code of Ethics. 3. Professional Misconduct. No Supervised Person shall: (a) commit a criminal act that upon conviction materially reflects adversely on his or her honesty, trustworthiness, or fitness as an Access Person in other respects; or (b) engage in conduct involving dishonesty, fraud, deceit, or misrepresentation. 4. Prohibition Against Use of Material Nonpublic Information. All Supervised Persons shall comply with all laws and regulations relating to the use and communication of material nonpublic information. For more refer to IX- Insider Trading. All Supervised Persons must refrain from communicating, or trading while in possession of, material nonpublic information in breach of a duty or information that is misappropriated. Duties under the standard include the following:

3 a. If the Supervised Person acquires such information as a result of a special or confidential relationship with the issuer or others, he or she shall not communicate the information (other than within the relationship), or take investment action on the basis of such information, if it violates that relationship. b. If the Supervised Person is not in a special or confidential relationship with the issuer or others, he or she shall not communicate or act on material nonpublic information if he or she knows, or should have known, that such information was disclosed to him or her, or communication or action upon such information would result, in a breach of a duty or that such information was misappropriated. If such a breach of duty exists, the Supervised Person shall make reasonable efforts to achieve public dissemination of such information. 5. Responsibilities of Supervisors. A Supervised Person with supervisory responsibility shall exercise reasonable supervision over those subordinate Supervised Persons subject to his or her control to prevent any violation by such persons of applicable statutes, regulations, or provisions of the Code of Ethics or Standards of Professional Conduct. In so doing, the supervisor is entitled to rely upon reasonable procedures established by the Company. B. Priority of Transactions An Access Person shall conduct himself or herself in such a manner that transactions for his or her customers, Advisory Clients, and the Company have priority over transactions in securities or other investments of which he or she is the Beneficial Owner, and so that transactions in securities or other investments of which he or she is the Beneficial Owner do not operate adversely to their interests. If an Access Person decides to make a recommendation about the purchase or sale of a security or other investment, he or she shall give his or her customers, Advisory Clients, and the Company adequate opportunity to act on this recommendation before acting on his or her own behalf. C. Conflicts of Interest 1. Supervised Persons. The Company has an affirmative duty of care, loyalty, honesty, and good faith to act in the best interests of its Advisory Clients. This duty requires all Supervised Persons to use their best efforts to avoid conflicts of interest with Advisory Clients and to fully disclose all material facts concerning any conflict that does arise with respect to any Advisory Client.

4 In addition to conflicts of interest that may arise between a Supervised Person and an Advisory Client, conflicts of interest may arise among Advisory Clients if a Supervised Person favors the interests of one Advisory Client over another Advisory Client. No Supervised Person shall engage in such inappropriate favoritism that would constitute a breach of fiduciary duty. 2. Access Persons. No Access Person shall use his or her knowledge about pending or currently considered securities transactions for Advisory Clients to profit personally, directly or indirectly, as a result of such transactions, including by purchasing or selling such securities. D. Compensation An Access Person, when making investment recommendations or taking investment actions, shall disclose to his or her customers and Advisory Clients any material conflict of interest relating to the Access Person and any material beneficial ownership of the securities or other investments involved that could reasonably be expected to impair his or her ability to render unbiased and objective advice. An Access Person shall disclose to the Company all matters that could reasonably be expected to interfere with his or her duty to the Company or with his or her ability to render unbiased and objective advice. An Access Person shall also comply with all requirements as to disclosure of conflicts of interest imposed by law and by rules and regulations of organizations governing his or her activities and shall comply with any prohibitions on his or her activities if a conflict of interest exists. 1. Disclosure of Additional Compensation Arrangements. A Financial Advisor shall inform his or her customers, Advisory Clients, and the Company of compensation or other benefit arrangements in connection with his or her services to them that are in addition to compensation from them for such services. 2. Disclosure of Referral Fees. A Financial Advisor shall make appropriate disclosure to a prospective client or customer of any consideration paid or other benefit delivered to others for recommending his or her services to that prospective client or customer. 3. Duty to Employer. A Financial Advisor shall not undertake independent practice that could result in compensation or other benefit in competition with the Company unless he or she has received written consent from both

5 the Company and the person for whom he or she undertakes independent employment. E. Gifts 1. Accepting Gifts. No Access Person shall accept any extraordinary or extravagant gifts from Advisory Clients, brokers, vendors, or other persons. Any such gifts must be declined and returned in order to protect the reputation and integrity of the Company. Gifts of nominal value (i.e., a gift of tangible personal property whose reasonable value, alone or in the aggregate, is not more than $100 in any twelve-month period), customary business meals, entertainment, and promotional items may be accepted. All gifts received by an Access Person that might violate this Code of Ethics must be promptly reported to the Company s compliance officer. 2. Solicitation of Gifts. Access Persons are prohibited from soliciting gifts of any size under any circumstances. 3. Giving Gifts. Access Persons may not give any extraordinary or extravagant gift to an Advisory Client or persons who do business with, regulate, advise, or render professional services to the Company. F. Investment Recommendations and Actions 1. Reasonable Basis and Representations. a. A Financial Advisor shall exercise diligence and thoroughness in making an investment recommendation to others or in taking an investment action for others. b. A Financial Advisor shall have a reasonable and adequate basis for such recommendations and actions, supported by appropriate research and investigation. c. A Financial Advisor shall make reasonable and diligent efforts to avoid any material misrepresentation in any research report or investment recommendation. d. A Financial Advisor shall maintain appropriate records to support the reasonableness of such recommendations and actions. 2. Portfolio Investment Recommendations and Actions. a. A Financial Advisor shall, when making an investment recommendation or taking an investment action for a specific portfolio or Advisory Client, consider its appropriateness and

6 suitability for such portfolio or Advisory Client. In considering such matters, the Financial Advisor shall take into account: (i) the needs and circumstances of the Advisory Client; (ii) the basic characteristics of the investment involved; and (iii) the basic characteristics of the total portfolio. The Financial Advisor shall use reasonable judgment to determine the applicable relevant factors. b. A Financial Advisor shall distinguish between facts and opinions in the presentation of investment recommendations. c. A Financial Advisor shall disclose to Advisory Clients and prospective clients the basic format and general principles of the investment processes by which securities are selected and portfolios are constructed and shall promptly disclose to Advisory Clients any changes that might significantly affect those processes. 3. Prohibition Against Misrepresentation of Services. A Financial Advisor shall not make any statements, orally or in writing, which misrepresent: (a) the services that the Financial Advisor or the Company is capable of performing for the Advisory Client; (b) the qualifications of such Financial Advisor or the Company; or (c) the expected performance of any investment. 4. Prohibition Against Assurances or Guarantees. A Financial Advisor shall not make, orally or in writing, explicitly or implicitly, any assurances about or guarantees of any investment or its return except communication of accurate information as to the terms of the investment instrument and the issuer s obligations under the instrument. 5. Performance Presentation Standards. a. A Financial Advisor shall not make any statements, orally or in writing, which misrepresent the investment performance that the Financial Advisor or the Company has accomplished or can reasonably be expected to achieve. b. If a Financial Advisor communicates directly or indirectly individual or Company performance information to an Advisory Client or prospective client, or in a manner intended to be received by an Advisory Client or prospective client, the Financial Advisor shall make every reasonable effort to ensure that such performance information is a fair, accurate, and complete presentation of such performance. 6. Fair Dealing with Customers and Advisory Clients. A Financial Advisor shall act in a manner consistent with his or her obligation to deal fairly

7 with all customers and Advisory Clients when: (a) disseminating investment recommendations; (b) disseminating material changes in prior investment advice; and (c) taking investment action. G. Relationships with Others 1. Preservation of Confidentiality. An Access Person shall preserve the confidentiality of information communicated by an Advisory Client concerning matters within the scope of the confidential relationship, unless the Access Person receives information concerning illegal activities on the part of the Advisory Client. 2. Fiduciary Duties. An Access Person, in relationship with Advisory Clients, shall use particular care in determining the applicable fiduciary duty and shall comply with such duty as to those persons and interests to whom it is owned. 3. Maintenance of Independence and Objectivity. A Financial Advisor, in relationship and contact with an issuer of securities, whether individually or as a member of a group, shall use particular care and good judgment to achieve and maintain independence and objectivity. III. Special Obligations of Access Persons A. Pre-Approval of Securities Transactions All Access Persons shall obtain approval from the Company s compliance officer before purchasing, directly or indirectly, any security of which such Access Person will become the Beneficial Owner in an initial public offering or private placement. In determining whether to grant permission for such purchase, the compliance officer shall consider, among other things, whether such offering should be reserved for an Advisory Client and whether such transaction is being offered to the Access Person because of his or her position with the Company. B. Reporting Requirements 1. Holdings Reports. All Access Persons shall submit to the Company s compliance officer a report of all holdings in Reportable Securities within 10 days of becoming an Access Person and thereafter on a quarterly basis. Such holdings reports may exclude any securities held in accounts over which the Access Person has no direct or indirect influence or control. 2. Transaction Reports. All Access Persons shall submit to the Company s compliance officer quarterly transaction reports covering all transactions in Reportable Securities during the quarter in which each Access Person was, or as a result of a transaction became, a direct or indirect Beneficial

8 Owner of Reportable Securities. Such transaction reports must be submitted no later than 30 days after the end of each calendar quarter and may exclude transactions in securities held in accounts over which an Access Person had no direct or indirect influence or control and transactions effected pursuant to an automatic investment plan. 3. Review of Reports. The Company s compliance officer shall review all Access Persons personal securities transactions and holdings reports quarterly. IV. Compliance with the Code of Ethics A. Duty to Report Violations All Supervised Persons have a duty to report violations of this Code of Ethics promptly to the Company s compliance officer. Such reports will be treated confidentially to the extent permitted by law and investigated promptly and appropriately. Retaliation against a Supervised Person who reports a violation is prohibited and constitutes a further violation of this Code of Ethics. B. Sanctions If the Company s compliance officer determines that a Supervised Person has committed a violation of this Code of Ethics, the Company may impose sanctions and take other actions as it deems appropriate, including a letter of caution or warning, suspension of personal trading privileges, suspension or termination of employment, a fine, civil referral to the SEC and, in certain cases, criminal referral. The Company also may require the offending Supervised Person to reverse the trades in question and forfeit any profit or absorb any loss derived from such reversal, and such forfeiture shall be disposed of in a manner that shall be determined by the Company in its sole discretion. Failure to timely abide by directions to reverse a trade or forfeit profits may result in the imposition of additional sanctions. C. Certification of Compliance The Company shall provide to all Supervised Persons a copy of this Code of Ethics upon becoming employed by the Company and a copy of any amendments to this Code of Ethics as adopted. All Supervised Persons shall acknowledge receipt of this Code of Ethics and any amendments in writing. In addition, all Supervised Persons shall certify on an annual basis that they have read, understood, and complied with this Code of Ethics.

9 ACKNOWLEDGEMENT OF RECEIPT OF CODE OF ETHICS FOR ALL SUPERVISED PERSONS I,, certify that: 1. I have received a copy of the Old North State Trust, LLC Code of Ethics; 2. I have read and understand all provisions of the Code of Ethics; and 3. I agree to comply with the terms of the Code of Ethics. Signature: Date:

10 ANNUAL CERTIFICATION OF COMPLIANCE WITH CODE OF ETHICS All Supervised Persons (including Access Persons) I,, certify that: 1. I have read and understand all provisions of the Old North State Trust, LLC Code of Ethics and any amendments thereto; and 2. I have complied with the terms of the Code of Ethics. Signature: Date: Access Persons Only I,, certify that: 1. I have fully disclosed all Reportable Securities holdings in which I have, or a member of my immediate family has, a beneficial interest; and 2. I have reported all securities transactions in which I have, or a member of my immediate family has, a beneficial interest, except for transactions that need not be reported pursuant to the Code of Ethics. Signature: Date:

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