Ethical Standards

NORTHLAND has established standard of conduct for its advisory personnel, which address areas where conflicts of interest may arise from the personal trading of the advisory personnel. NORTHLAND has put in place the following restrictions in order to ensure its fiduciary responsibilities:

NORTHLAND emphasizes the unrestricted right of the Client to specify their investment objectives, guidelines and/or conditions on the overall management for their portfolio;

Associated persons or their immediate family members shall not buy or sell securities for their personal portfolio(s) where their decision is derived in whole or in part, by reason of the associated person's employment, unless the information is also available to the investing public on reasonable inquiry;

No associated person of NORTHLAND shall prefer his or her own interest to that of an advisory Client. Investment opportunities must be offered first to Clients before NORTHLAND or its associated persons may participate in such transactions;

NORTHLAND and its employees may not participate in private placements or initial public offerings (IPOs) without prior written approval from NORTHLAND's compliance officer;

NORTHLAND requires that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisory practices;

Records will be maintained of all securities bought or sold by NORTHLAND, its associated persons and related entities. A qualified representative of NORTHLAND will review these records on a regular basis; and

Any individual not in observance of the above may be subject to termination.

The full text of NORTHLAND's Code of Ethics is available to you upon request.