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1)	Introduction

Test Procedure	Frequency	Assignee
For the period under review, confirm that SSC held new employee training that covered topics covered in the Code of Ethics.	Annually	Roxanne Jenkins
For the period under review, confirm that SSC received certification that each Supervised Person has re-read, understands and has complied with the Code of Ethics.	Annually	Roxanne Jenkins

2)	Standards of Business Conduct

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Clients Come First. Supervised Persons owe Clients a duty of loyalty and must avoid serving the Adviser’s or their own personal interests ahead of the Clients’. A Supervised Person may not induce or cause a Client to take action, or not to take action, for the Firm’s or the Supervised Person’s own benefit rather than for the benefit of the Client. The Firm must make full and fair disclosure of all material facts related to the investment, particularly where the interests of the Firm or a Supervised Person may conflict with those of a Client.

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Avoid Taking Advantage. Supervised Persons may not trade on the basis of inside information, usurp investment opportunities that should properly be made available to the Firm’s Clients, or otherwise use their knowledge of the Firm’s investment activities to profit on such activities at the expense of the Firm’s Clients.

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Avoid Inappropriate Relationships. In addition, Supervised Persons must avoid engaging in outside business activities and the receipt of investment opportunities, perquisites, or gifts from persons seeking to do business with the Firm that could call into question a Supervised Person’s ability to exercise independent judgment in the best interests of the Firm’s Clients.

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Compliance with Applicable Law. Supervised Persons must comply with all laws that apply to the business of the Firm.

3)	Policy Statement on Insider Trading

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trading by an insider, while in possession of MNPI;

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trading by a non-insider, while in possession of MNPI, where the information either was disclosed to the non-insider in violation of an insider’s duty to keep it confidential or was misappropriated; or

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communicating MNPI to others (i.e. “tipping”).

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merger or acquisition proposals or agreements;

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news of a significant sale of assets or the disposition of a subsidiary;

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liquidation problems;

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major contract awards;

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the gain or loss of a substantial customer or supplier;

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pricing changes or discount policies;

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notice of issuance of patents;

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significant new products, processes or discoveries;

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major litigation or regulatory inquiries;

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extraordinary management developments;

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earnings estimates (or results);

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changes in previously released earnings estimates;

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current financial performance;

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changes in dividend amounts or policies or the declaration of a stock split or the offering of additional securities; and/or

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significant write-offs or restatements.

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civil injunctions;

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treble damages (triple the amount of compensatory/actual damages);

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disgorgement of profits;

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jail sentences;

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fines for the person who committed the violation of up to three times the profit gain or loss avoided, whether or not the person actually benefited; and

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fines for the employer or other controlling person of up to the greater of $100,000 or three times the amount of the profit gained or loss avoided.

4)	Procedures To Implement Policy Against Insider Trading

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Before engaging in personal trading or trading for Funds in the securities of a company which has publicly traded securities (even if the information relates to such company’s non-publicly traded securities), Supervised Persons should ask the following questions about any information that may be MNPI prior to communicating such information to any person other than the CCO:

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Is the information material? Is this information that an investor would consider important in making his or her investment decisions? Is this information that would substantially affect the market price of the securities if generally disclosed?

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Is the information non-public? To whom has this information been provided? Has the information been effectively communicated to the marketplace (e.g., by being published in Reuters, the Wall Street Journal or other publications of general circulation or made available broadly to security holders)?

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Has this information been obtained from a company or from another source (including an immediate family member) as a result of a breach of a duty of trust or confidence by that source?

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If, after consideration of the above, there is a possibility that the information could be material and non-public, or if there are questions as to whether the information is material and non-public, the following steps should be taken:

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The matter should be reported immediately to the CCO.

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The securities should not be purchased or sold personally or on behalf of a Fund or for any of the Supervised Person’s Personal Accounts;

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The information should not be communicated inside or outside Silver Spike, other than to the CCO.

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After the CCO has reviewed the issue or consulted with counsel (as the CCO deems appropriate), the CCO will determine whether to:

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continue the restriction on trading in such securities (by placing the security on the Restricted List (as defined below);

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permit trading in such securities and communication of the information (either in Personal Accounts or Fund accounts);

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create an “ethical wall” to limit the information to certain Supervised Persons and instruct the Supervised Person that they may communicate the information only to Supervised Persons that are appropriately “walled off” by confidentiality agreement or otherwise; or

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take any other action the CCO deems appropriate.

Test Procedure		Frequency	Assignee
For the period under review:		Quarterly	Roxanne Jenkins
(1)	verify that SSC has maintained a restricted list of publicly traded investments.
(2)	verify that no Supervised Person at SSC has traded an investment that was on the restricted list.

5)	Personal Account Dealings

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report securities holdings, at the time the person becomes an access person and at least once a year thereafter; and

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disclose each quarter their personal Securities Transactions no later than 30 days after the close of the calendar quarter.

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Electronic feeds – Supervised Persons are encouraged to deal through brokers that provide Compliance with trade confirmations and holdings via electronic feed. This provides Compliance with the most timely and accurate account information.

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Broker delivery of duplicate confirmations and statements – In jurisdictions where applicable, Supervised Persons should allow for brokers to provide delivery of duplicate confirmations and statements directly to Compliance. Compliance staff will enter trade details for Supervised Persons that utilize this option.

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Supervised Person upload of confirmations and statements – If neither of the above options is possible, Supervised Persons are required to enter trade details into the Firm’s compliance management system, MyComplianceOffice (“ACA Compliance Alpha”) and upload the trade confirmation (or quarterly statement).

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Account Attestation (For Accounts that have the ability to hold Reportable Securities)

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Holdings Attestation (For Reportable Securities)

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Quarterly Trades Attestation (For Reportable Securities)

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with respect to transactions effected pursuant to an Automatic Investment Plan; or

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with respect to securities held in accounts over which the access person had no direct or indirect influence or control

Test Procedure		Frequency	Assignee
For the period under review, confirm that all Supervised Persons and their Immediate Family Members:		Quarterly	Roxanne Jenkins
(1)	reported securities holdings, at least once a year.
(2)	disclose each quarter their personal Securities Transactions no later than 30 days after the close of the calendar quarter.
For the period under review, confirm that all employees have attested to not investing in IPOs that have not been pre-approved.		Quarterly	Roxanne Jenkins
For the period under review, confirm that within 10 calendar days of a Supervised Persons start date, the Supervised Person has disclosed all brokerage accounts and all holdings in reportable securities.		Quarterly	Roxanne Jenkins
For the period under review, confirm that all Supervised Persons have attested to accounts they hold and holdings in those accounts, as well as their trade activity.		Quarterly	Roxanne Jenkins
For the period under review, confirm that all Supervised Persons have requested pre-approval prior to investing in a private placement or limited offering by submitting a request in ACA Compliance Alpha. Note that this review is completed when an employee submits their annual attestation of investments, including private placements. Any new private placements should have a corresponding approval documented. Note where the documentation is saved of non-compliance, if applicable.		Annually	Roxanne Jenkins
For the period under review, confirm that all Access Persons that have invested in an IPO have submitted a request to do so in ACA Compliance Alpha before investing.		Quarterly	Roxanne Jenkins
For the period under review, confirm that Supervised Persons have certified that they do not have ability to influence or control investment decisions made for any applicable managed accounts.		Quarterly	Roxanne Jenkins

6)	Gifts and Entertainment

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could create an apparent or actual conflict;

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is excessive or would reflect unfavorably on Silver Spike or its Clients; or

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would be inappropriate or disreputable in nature.

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Receive cash, cash equivalents, loans or personal services on behalf of Silver Spike, even if these fall within the limits outlined above. This includes gift cards or certificates if they can be redeemed for cash; or

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Receive special discounts unless they are available to all other Supervised Persons (e.g., a discount coupon from a retail store).

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Usual and customary promotional items (e.g., t-shirts, caps, or pens marked with the vendor’s logo);

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Gifts ($500 or less) or entertainment of nominal value;

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Attendance and participation at industry sponsored events; or

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Usual and customary gifts given to or by Supervised Persons based on a personal relationship (e.g., the vendor and Supervised Person have a family relationship that preceded interaction at the Firm).

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official of a foreign government;

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employee of any government-controlled foreign business;

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sovereign wealth fund, employee or representatives of a sovereign wealth fund, or third party associated with a sovereign wealth fund’s investment process or investment due diligence; or

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foreign political party or official or candidate for foreign political office.

Test Procedure	Frequency	Assignee
For the period under review, confirm that the CCO reviewed expenses for excessive or extravagant entertainment expenses. To the extent that expenses are requested for reimbursement, state where documentation of such review exists.	Quarterly	Roxanne Jenkins
For the period under review, document any known non-compliance. For the period under review, note any requests for gift limit exception entered into ACA Compliance Alpha and the confirmed approval of Silver Spike’s CCO, or Designee.	Annually	Roxanne Jenkins
For the period under review, document any exception to the no gifts to Foreign Officials rule. If applicable, state where the written approval of the CCO is located.	Annually	Roxanne Jenkins
For the period under review, if SSC utilized placement agents or other intermediaries to solicit Investors in foreign countries, verify that the CCO reviewed placement agent agreements for appropriate written representations. State where the CCO has expressly authorized the placement agents to solicit investments in foreign countries. To the extent applicable, ensure that the CCO has required such placement agents to renew appropriate representations relating to compliance with the FCPA.	Annually	Roxanne Jenkins

7)	Political Contributions

Test Procedure	Frequency	Assignee
For the period under review, note if there were any political contribution preapprovals.	Annually	Roxanne Jenkins
For the period under review, confirm that all new hires submitted their attestation of all recent political contributions of themselves and their Immediate Family in ACA Compliance Alpha.	Annually	Roxanne Jenkins

8)	Outside Business Activities

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accept, directly or indirectly, compensation of any nature as a bonus, commission, fee, gratuity, or other consideration in connection with any transaction on behalf of the Firm or a Client from any Person, firm, corporation or association, other than the Firm or an affiliate thereof; or

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acquire, directly or indirectly, any equity or other ownership or financial interest in any other organization engaged in any securities, financial or related business, except for (i) a minority equity or other ownership or other financial interest in any business that is publicly traded, or (ii) an equity or other ownership or financial interest through any account over which the Supervised Person has no direct or indirect influence or control.

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that involves a significant amount of time or provides a significant amount of income;

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that is investment-related, including activities on behalf of a non-profit;

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that involves service on the board of directors of a publicly traded company (will generally not be permitted);

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that involves serving as an employee, independent contractor, sole proprietor, officer, director or partner of a for-profit business;

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that involves serving as a director, officer or executive management of a non-profit entity or performing investment- related functions on its behalf; or

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that involves engaging in any other outside employment or activity (paid or unpaid) that may give rise to a conflict with Silver Spike, one of its Funds, or Fund Investors or other risk (e.g., operating a blog that provides financial advice).

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present a substantial risk of confusing Clients or the public as to the capacity in which the Supervised Person is acting;

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pose a reputational risk for the Firm;

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inappropriately influence a Supervised Person’s business dealings or otherwise create a conflict of interest vis-à-vis the interests of Silver Spike or its Funds, or a Fund Investor; or

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involve use of information relating to Silver Spike, any Fund or other proprietary information.

Test Procedure	Frequency	Assignee
For the period under review, note if any requests for outside business activities were granted pre-approval. For the period under review, note any instance and the conclusion of the instance, where a Supervised Person contacted the CCO because the OBA of their Immediate Family could create or appear to create a conflict of interest.	Annually	Roxanne Jenkins

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have access to non-public information regarding Silver Spike’s Funds, or non-public information regarding the portfolio holdings of any of Silver Spike’s Funds, or any Silver Spike services;

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are involved in making investment recommendations to Clients, or have access to such recommendations that are non- public;

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in connection with their regular functions or duties, make, participate in or obtain information regarding transactions in Silver Spike’s Funds or their functions relate to the making of any recommendations with respect to Silver Spike’s Funds;

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are personnel, such as client service representatives, administrative and technical staff, who may qualify as Access Persons if their job functions give them access to material non-pubic information or client or fund information;

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are any other person designated by the CCO as necessary.

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any accounts held by any Supervised Person;

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accounts of the Supervised Person’s Immediate Family members (any relative by blood or marriage) living in the Supervised Person’s household or is financially dependent;

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accounts held by any other related individual over whose account the Supervised Person has discretionary control;

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any other account where the Supervised Person has discretionary control and materially contributes; and

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any account in which the Supervised Person has a direct or indirect beneficial interest, such as trusts and custodial accounts or other accounts in which the Supervised Person has a beneficial interest or exercises investment discretion.

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You live with your parents: If you live in your parents’ house but do not financially support your parents, your parents’ accounts and securities are not beneficially owned by you and do not require disclosure.

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Your parent lives with you: If you provide financial support to your parent, your parent’s accounts and securities are beneficially owned by you and require disclosure.

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You have an adult child living in your home: If you provide financial support to your child, your child’s accounts and securities are beneficially owned by you and require disclosure.

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You have a college-age child: If your child is in college and you still claim the child as a dependent for tax purposes, you are the beneficial owner of their accounts and securities.

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Your child has an UGMA/UTMA account: If you (or your spouse) are the custodian for the minor child, the child’s accounts are beneficially owned by you. If someone other than you (or your spouse) is the custodian for your minor child’s account, the account is not beneficially owned by you.

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You have a domestic partner or similar cohabitation arrangement: If you contribute to the maintenance of a household and the financial support of a partner, your partner’s accounts and securities are beneficially owned by you and require disclosure.

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You have a roommate: Generally, roommates are presumed to be temporary and therefore you have no beneficial ownership in one another’s accounts and securities.

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You have power of attorney: If you have been granted power of attorney over an account, you are not the beneficial owner of the account until the time that the power of attorney has been activated.

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You are the trustee and/or the beneficiary of a trust: Due to the complexity and variety of trust agreements, these situations require case-by-case review by the CCO.

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any of the following persons sharing the same household with the Supervised Person (which does not include temporary house guests): a person’s child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, sister-in-law, legal guardian, adoptive relative, or domestic partner;

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any person sharing the same household with the Supervised Person (which does not include temporary house guests) that holds an account in which the Supervised Person is a joint owner or listed as a beneficiary; or

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any person sharing the same household with the Supervised Person in which the Supervised Person contributes to the maintenance of the household and material financial support of such person.

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projections of future earnings or losses;

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news of a possible merger, acquisition or tender offer;

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significant new products or services or delays in new product or service introduction or development;

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plans to raise additional capital through stock sales or otherwise;

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the gain or loss of a significant customer, partner or supplier;

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discoveries, or grants or allowances or disallowances of patents;

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changes in management;

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news of a significant sale of assets;

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impending bankruptcy or financial liquidity problems; or

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changes in dividend policies or the declaration of a stock split.

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transactions and holdings in direct obligations of the Government of the United States.

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money market instruments — bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments.

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shares of money market funds.

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transactions and holdings in shares of other types of mutual funds, unless the adviser or a control affiliate acts as the investment adviser or principal underwriter for the fund.

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transactions in units of a unit investment trust if the unit investment trust is invested exclusively in unaffiliated mutual funds.

Revision Date:	04/2023: Update to CCO
Revision Date:	12/2023: Test Procedure tables added
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