Code of Ethics

Effective: January 1, 2026 · Reviewed annually by the Chief Compliance Officer

The Aukeo Code of Ethics establishes the standards of business conduct required of every officer, employee, and supervised person of the firm. The Code covers personal-trading pre-clearance, gifts and entertainment, outside business activities, political contributions, information barriers, and the treatment of material non-public information. Compliance with the Code is a condition of continued employment and is reviewed annually by every supervised person under written attestation.

Standards of conduct

Every officer and employee is required to place the interests of the firm's limited partners ahead of personal interest, to treat all firm information as confidential, to respect the compliance framework governing personal trading and outside activities, and to escalate any perceived conflict of interest immediately to the Chief Compliance Officer.

Personal trading

All personal securities transactions by supervised persons must be pre-cleared through the Compliance function. Access persons hold reportable brokerage accounts subject to duplicate-statement delivery to Compliance and are required to file initial, quarterly, and annual holdings reports.

Gifts and entertainment

All gifts and entertainment given or received in connection with firm business are subject to per-instance and aggregate thresholds and must be logged with Compliance. Any gift or entertainment above threshold requires prior Compliance approval.

Reporting concerns

Concerns regarding the Code, including anonymous reports, may be raised through the firm's Whistleblower channel. Retaliation is prohibited.

Questions regarding this policy may be directed to the Chief Compliance Officer at [email protected].