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We invest with integrity and intelligence; we seek rational investment behaviors at all times.
Coastwise Capital Group, LLC's goal is to do what is right—for its clients, its employees, its members, the securities industry, and the community. Following the policies and procedures described in this Code of Ethics and in our Compliance Manual—and acting ethically, exercising good judgment and using common sense—will assist us in achieving that goal.

Sarbanes-Oxley Code of Ethics
Code of Ethics for Covered Officers of Coastwise Capital Group
January 2008
The Boards of Directors/Trustees of Coastwise Capital Group, have adopted the following Code of Ethics (the "Code") applicable to its Covered Officers of Coastwise Capital to ensure the continuing integrity of financial reporting and transactions.

Separate Code
This Code is the sole code of ethics adopted by the Funds for purposes of Section 406 of the Sarbanes-Oxley Act of 2002. Any conduct by Covered Officers required by specific Investment Company Act or Advisers Act provisions or the rules thereunder is presumed to be in compliance with this Code. Each Covered Officer is accountable for his or her adherence to this Code. Any violation of this Code by a Covered Officer may result in disciplinary action, including immediate dismissal.

Requirements
All Covered Officers must:
  1. Engage in and promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships

  2. Act responsibly in producing and produce, full, fair, accurate, timely and understandable disclosure in reports and documents that the Funds file with, or submit to, the Securities and Exchange Commission (the "SEC") and in other public communications made by each of the Funds

  3. Comply with applicable governmental laws, rules and regulations

  4. Promptly report suspected material violations of this Code, including violations of securities laws or other laws, rules and regulations applicable to a Fund, to CW's General Counsel and the Fund's Audit Committee
Each Covered Officer must act with integrity, including being honest and candid while still maintaining the confidentiality of information where required by law, and place the interests of Coastwise Capital before the Covered Officer's own personal interests.

Each Covered Officer is required to familiarize himself or herself with the disclosure requirements applicable to each of the Funds and must not knowingly misrepresent or fail to disclose, or cause others to misrepresent or fail to disclose, material facts about a Fund to others, including but not limited to officers of and counsel to Coastwise Capital, and their respective independent directors, independent auditors and governmental regulators.

Firm Name: Coastwise Capital Group, LLC

Firm IARD/CRD Number: 139564

Click here for a PDF Version of Part II Schedule F

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Please give us a call at (858) 454-6670 if you have any questions or would like to request a written copy of Coastwise Capital Group's ADV.


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