Apollo has adopted a Code of Ethics that sets forth the basic policies of ethical conduct for each employee of the Firm.

Where Firm personnel may purchase or sell investments for their personal accounts that they have similarly recommended to clients, the Firm has an ethical obligation to ensure that trading conducted for client accounts is performed in a fair and ethical manner.

While Apollo endeavors at all times to put the interests of its clients first as part of its fiduciary duty, clients should be aware that the personal trading involving recommended securities may create a conflict of interest and may affect the judgment of the individual making the recommendation.

A copy of the Firm's code of Ethics will be provided to any client upon request.