Code of Ethics

Standard of business conduct

Tuckerbrook places great value on high ethical standards and conduct. Honesty, openness, and integrity are crucial to our business success and our reputation. All partners and employees of Tuckerbrook Alternative Investments, LP, are expected to reflect these ideals, both in their work for the firm and in their personal lives.

Our interests and those of our clients are closely aligned in order to ensure a mutually beneficial relationship. Tuckerbrook will meet its fiduciary obligations and exercise reasonable care, judgment, independence, and diligence in making investment recommendations or taking investment actions.

Tuckerbrook will deal fairly with our colleagues, clients, prospects, vendors, and affiliates.

All partners and employees at Tuckerbrook have been provided with a copy of this Code of Ethics and are expected to fully comply with both the letter and spirit of the Code.

Specific obligations

All employees and limited partners of Tuckerbrook Alternative Investments, LP, will:

- Respect and obey all applicable laws, rules, and regulations of federal and state governmental agencies, regulatory organizations, licensing agencies, and professional associations.

- Take care to properly safeguard inside, confidential, and other sensitive information which may come to their attention. Securities trading on the basis of material nonpublic (i.e. inside) information is prohibited.

- Report their personal securities holdings and transactions to the Company's chief compliance officer in accordance with SEC regulations of Registered Investment Advisers.

- Fully disclose to the firm any real or potential conflicts of interest.

- Promptly report any known violation of this Code of Ethics to the chief compliance officer. If anyone is uncomfortable reporting to this person, he may report a violation to the firm's legal counsel, Bingham McCutchen.

Tuckerbrook encourages such reporting and will protect any person who reports a violation from retaliation.

- Provide a written acknowledgement confirming that he or she received a copy of, understands, and will comply with this Code of Ethics. Failure to comply with this Code may result in disciplinary action up to and including termination of employment.

Responsibility for Enforcement

Tuckerbrook's Chief Compliance Officer, David Hausler, has responsibility for distributing this Code of Ethics, enforcing it, maintaining the appropriate records, and reviewing all reporting required by the Code.