GLDUS131 Bright Group iCapital Advisors, LLC Form ADV Part 2A consistent with the Code of Ethics: and Employees should not take inappropriate advantage of their position. Employees (and any accounts in which an employee has beneficial ownership) must obtain written authorization from the CCO prior to making a personal investment in other private investment vehicles. The Code of Ethics also provides that the CCO (or his designee) will monitor employee investments in equity securities or other instruments: however, because the Sub-Advisers of the Direct Investment Funds maintain investment and trading authority on behalf of the Direct Investment Funds which should minimize any conflicts of interest that may arise out of the employees' personal trading activities. Furthermore, iCapital generally provides to each Sub-Adviser a list of companies at which any of iCapital's related persons has a material financial interest (e.g., board membership) so that such Sub-Adviser may include such company on its own restricted list. The spirit of the Code of Ethics is to discourage frequent trading in personal employee accounts. Employees also may not participate in any initial public offerings or engage in any outside business activities or private placements without obtaining prior written authorization from the CCO. iCapital's Code of Ethics is available upon request Participation or Interest in Client Transactions iCapital serves as the investment adviser to the Funds. Employees, affiliates of the employees, and relatives of the employees may make investments in the Funds. iCapital may waive or reduce fees in respect of any Investor and generally intends to waive the fees in respect of any employees of iCapital and certain affiliates and estate-planning vehicles thereof. Each Underlying Manager or Sub-Adviser, as applicable, is responsible for making portfolio investments for any Fund it manages. Neither iCapital nor the Funds have any discretion or con