Attached files

Exhibit 14: Code of Business Conduct and Ethics


Introduction

This Code of Business Conduct and Ethics covers a wide range of
business practices and procedures. It does not cover every issue
that may arise, but it sets out basic principles to guide officers
and trustees of the Trust. All of our officers and trustees must
conduct themselves accordingly and seek to avoid even the appearance
of improper behavior. The Trust currently has no employees. However,
should the Trust?s operations require employees in the future, this
Code of Conduct and Ethics will apply to any and all employees.

If a law conflicts with a policy in this Code, you must comply with
the law; however, if a local custom or policy conflicts with this
Code, you must comply with the Code. If you have any questions about
these conflicts, you should ask the chief executive officer how to
handle the situation.

Those who violate the standards in this Code will be subject to
disciplinary action which may include immediate termination. If you
are in a situation which you believe may violate or lead to a
violation of this Code, follow the procedures described in Sections
11 and 12 of this Code.


1.	Ethical Conduct and Legal Compliance

Obeying the law, both in letter and in spirit, is the foundation on
which the Trust's ethical standards are built. All officers and
trustees must obey the laws of the United States and the cities and
states in which we operate. Although not all officers and trustees
are expected to know the details of these laws, it is important to
know enough to determine when to seek advice from counsel or others.

Beyond compliance with laws, the Trust requires that all its
officers and trustees act in a manner which meets the highest
standards of ethical behavior. The honesty and integrity of our
business conduct must not be compromised. The Trust will not condone
ethical violations for the sake of personal gain, personal
advantage, expediency, or perceived business advantage.

2.	Accounting and Auditing Matters

The Trust's requirement that officers and trustees follow the
highest ethical standards applies directly to all actions which
involve business accounting, financial reporting, internal
accounting controls, auditing matters, and public disclosure
obligations in filings with the Securities and Exchange Commission
and all public communications by the Trust.

The Trust requires honest and accurate recording and reporting of
information in order to make responsible business decisions.

All of the Trust?s books, records, accounts and financial statements
must be maintained in reasonable detail, must appropriately reflect
the Trust's transactions and must conform both to applicable legal
requirements and to the Trust's system of internal controls.

Business records and communications often become public, and we
should avoid exaggeration, derogatory remarks, guesswork, or
inappropriate characterizations of people and companies that can be
misunderstood. This applies equally to e-mail, internal memos, and
formal reports. Records should always be retained or destroyed
according to the Trust's record retention policies. In accordance
with those policies, in the event of litigation or governmental
investigation please consult the chief executive officer or counsel.

The Audit Committee of the Trust has adopted special procedures for
the receipt, retention, and treatment of complaints regarding
accounting, internal accounting controls, or auditing matters. These
procedures are set out in Sections 11 and 12 of this Code.

3.	Conflicts of Interest

Conflicts of interest are prohibited as a matter of Trust policy,
except as (i) waived by the Board pursuant to Section 10 below; or
(ii) in the case of transactions involving the Trust and its
directors, officers, employees or agents, those transactions that
are approved pursuant to the procedures contained in the Trust?s
Amended and Restated Articles, including any subsequent amendments
thereto.

A conflict of interest exists when a person's private interest may
or does interfere with the interests of the Trust. A conflict can
arise when an officer or trustee takes actions or has interests that
may make it difficult to perform his or her Trust work objectively
and effectively. Conflicts of interest may also arise when an
officer or trustee, or member of his or her family, receives
improper personal benefits as a result of his or her position with
the Trust.

It is almost always a conflict of interest for an officer or
director of the Trust to work simultaneously for a competitor,
customer or supplier as an employee, consultant, or board member.
The best policy is to avoid any direct or indirect business
connection with our competitors, customers or suppliers, except on
our behalf.

Conflicts of interest may not always be clear-cut, so if you have a
question, you should consult with the chief executive officer, the
Trust?s counsel or the chairman of the Audit Committee. Any officer
or trustee who becomes aware of a conflict or potential conflict
should bring it to the attention of the chief executive officer or
chairman of the Audit Committee or follow the procedures described
in Section 11 of this Code.

Officers and trustees owe a duty to the Trust to advance its
legitimate interests when the opportunity to do so arises. In
particular:

       (i) No payments, loans, employment or promises of employment,
investment opportunities, vacation trips, gifts or entertainment
(other than entertainment conforming to generally accepted business
practices or gifts of nominal value not reasonable calculated to
influence a decision) may be offered to or accepted by any officer
or trustee or a relative of such a person as a condition of the
initial or continued engagement of a consultant, broker, vendor or
third party working for the Trust.

	(ii) No payments (other than fees for services), loans,
employment or promises of employment, investment opportunities,
vacation trips, gifts or entertainment (other than entertainment
conforming to generally accepted business practices or gifts of
nominal value not reasonably calculated to influence a decision) may
be offered to or accepted by any consultant, broker, vendor,
government official or a relative of such third party in connection
with any services being performed for the Trust.

	(iii) No officer or trustee may recommend any third party for
work for the Trust where the third party's compensation is paid on
the basis of any kickback or fee sharing arrangement with the
officer or trustee, nor may an officer or trustee recommend any
third party without full disclosure and written approval by the
chief executive officer, if such third party has any familial or
pre-existing monetary relationship with the officer or trustee or if
such officer or trustee has an equity or stock ownership position in
such third party.

	(iv) No employee shall, in his capacity as an employee, make
any loan, donation, contributions or payment to a political party,
candidate, or political action committee, for or on behalf of the
Trust, nor shall an employee of the Trust reimburse any individual
who does. (Nothing contained in this tenet shall prohibit an
employee from taking any of the above actions in his or her name,
provided that the action is exclusively on the employee's own accord
and is not an indirect means of accomplishing one of the prohibited
actions)

	(v) No employee shall use or appropriate materials, property,
equipment, systems and procedures (if proprietary in nature) owned
by the Trust for his or her own personal financial gain except to
the extent necessary for the performance of his or her duties for
the Trust.

       (vi) In short, the purpose of business entertainment and gifts
in a commercial setting is to create goodwill and sound working
relationships, not to gain unfair advantage with customers. No gift
or entertainment should be offered, given, provided or accepted by
any Trust employee, family member of an employee unless it: (1) is
not a cash gift, (2) is consistent with customary business
practices, (3) is not excessive in value, (4) cannot be construed as
a bribe and is not reasonably calculated to influence a decision and
(5) does not violate any laws or regulations. Please discuss with
the chief executive officer any gifts or proposed gifts which you
are not certain are appropriate.

	(vii) No officer or trustee shall purchase or obtain any goods
or services from any of the Trust's vendors or suppliers without the
prior written approval of the chief executive officer or chairman
committee.

4.	Insider Trading

Officers, trustees and employees who have access to confidential
information are not permitted to use or share that information for
stock trading purposes or for any other purpose except the conduct
of our business and in strict conformance with all applicable laws
and SEC regulations. All non-public information for personal
financial benefit or to tip others who might make an investment
decision on the basis of this information is not only unethical but
also illegal. If you have any questions or concerns, please consult
the Company's  audit committee or the Trust?s corporate counsel.

5.	Competition and Fair Dealing

We seek to outperform our competition fairly and honestly. We seek
competitive advantages through superior performance, never through
unethical or illegal business practices. Stealing proprietary
information, possessing trade secret information that was obtained
without the owner's consent, or inducing such disclosures by past or
present employees of other companies is prohibited. Each officer and
trustee should endeavor to respect the rights of and deal fairly
with the Trust?s customers, suppliers, competitors and employees. No
unfair advantage should be taken of anyone through manipulations,
concealment, abuse of privileged information, misrepresentation of
material facts, or any other intentional unfair-dealing practice.

6.	Discrimination, Harassment and Retaliation

This policy prohibits discrimination against any person who provides
information to a federal regulatory or law enforcement agency, a
member of Congress or any committee of Congress, or to the chief
executive officer concerning conduct which the employee reasonably
believes constitutes a violation of securities laws or any provision
of federal law relating to fraud against shareholders.

No officer or trustee may retaliate against an individual for
bringing a complaint of discrimination or for participating in an
investigation or proceeding involving a complaint of discrimination.

No one may take any action harmful to any person for providing to a
law enforcement officer any truthful information relating to the
commission or possible commission of any federal offense.

7.	Confidentiality

Officers and trustees must maintain the confidentiality of the
information entrusted to them or its customers, except when
disclosure is authorized by the chief executive officer or required
by law. Confidential information includes all non-public information
that might be of use to competitors, or harmful to the Trust or its
customers, if disclosed. It also includes information that suppliers
and customers have entrusted to us. The obligation to preserve
confidential information continues even after employment or trustee
service ends.

8.	Protection and Proper Use of Trust Assets

Officers and trustees should endeavor to protect the Trust?s assets
and ensure their efficient use. Theft, carelessness and waste have a
direct impact on the Trust's profitability. Any suspected incident
of fraud or theft should be immediately reported for investigation.

The obligation of officers and trustees to protect the Trust's
assets includes the Trust's proprietary information. Proprietary
information includes business, marketing and service plans, records,
salary information and any unpublished financial data and reports.
Unauthorized use or distribution of this information would violate
Trust policy. It could also be illegal and result in civil or even
criminal penalties.

9.	Payments to Government Personnel

It is strictly prohibited to make illegal payments to government
officials of any country. In addition, the U.S. Government has a
number of laws and regulations regarding business gratuities which
may be accepted by U.S. Government personnel. The promise, offer or
delivery to an official or employee of the U.S. government of a
gift, favor or other gratuity in violation of these rules would not
only violate Trust policy but could also be a criminal offense.
State and local governments, as well as foreign governments, may
have similar rules.

10.	Waivers of the Code of Business Conduct and Ethics

Any waiver of this Code for executive officers or trustees may be
made only by the Board and will be promptly disclosed as required by
law or stock exchange regulation.

11.	Reporting/Investigation Procedures

Any officer or trustee who reasonably believes that there has been a
material violation of this Code of Conduct should report it
immediately to the chief executive officer and Audit Committee. The
investigation will be handled discreetly and appropriately, and the
information will be disclosed to others only on a need to know basis
and as required by law. There will be no adverse action taken
against anyone who reports violations of the Code of Conduct or who
participate in the investigation. If the investigation leads to a
conclusion that a material violation of the Code of Conduct has
occurred, the Trust will take appropriate corrective action which
may include removal from a position as trustee or officer.

The Trust recognizes the potentially serious impact of a false
accusation. This Code of Conduct requires officers and trustees to
act responsibly in making complaints. Making a complaint without a
good faith basis is itself an ethical violation.

12.     Special Procedures for Reporting/Investigation Complaints
Regarding Accounting, Internal Accounting Controls, and Auditing
Matters

Any officer or trustee who reasonably believes that there has been a
material violation of the Code of Conduct caused by questionable
accounting or auditing matters has the right to submit a
confidential, anonymous complaint to the Audit Committee. The
complaint should be made in written form and provide sufficient
information so that a reasonable investigation can be conducted.