edgecofe02-242011.htm - Generated by SEC Publisher for SEC Filing

This Code of Ethics (the “Code”) has been adopted by Edge Asset Management, Inc. (the

“Advisor”) effective February 24, 2011. The principal objectives of the Code are: (i) to provide

policies and procedures consistent with applicable law and regulation, including Rule 17j-1

under the Investment Company Act of 1940, as amended, and Rule 204 A-1 under the

Investment Advisers Act of 1940, as amended, and (ii) to prevent conflicts of interest or the

appearance of such conflicts including activities related to personal securities transactions or

engaging in outside business activities.

Access Persons of the Advisor are also subject to the Principal Financial Group Corporate Code

of Ethics, which can be found at the Inside the Principal ® intranet site. Access Persons are also

subject to additional policies including but not limited to insider trading, proprietary and

confidential information, and information barriers.

The maintenance and accuracy of this Code is the responsibility of the Chief Compliance Officer

of the Advisor. However, all Access Persons have the responsibility for observing and

complying with the Code on a day-to-day basis. Access Persons are strongly urged to consult

with the Compliance Department should they have any questions about the Code or its content.


	TABLE OF CONTENTS
I.	Policy Highlights	3
II.	General Principles	4
A.	Shareholder and Client Interests Come First	4
B.	Avoid Actual and Potential Conflicts of Interest	4
III.	Definition of Terms	4
IV.	Personal Securities Transactions	6
A.	Prohibited Conduct	6
B.	Restrictions and Limitations on Personal Securities Transactions	6
C.	Exempt Securities	8
D.	Exempt Transactions	9
E.	Pre-Clearance Requirement	10
V.	Reporting Requirements	11
A.	Report of Transactions & Holdings	11
B.	PFG Employee Benefit Plans	13
C.	Responsibility to Report	13
D.	Where to File Report	13
D.	Responsibility to Review	14
VI.	Insider Trading	14
VII.	Confidentiality	14
VIII.	Anti-Money Laundering	14
IX.	Service as a Director and Outside Business Activities	14
A.	Approval to Serve as a Director	14
B.	Approval to Engage in Outside Business Activities	15
X.	Gifts & Entertainment	15
A.	Gifts Given	15
B.	Gifts Received	15
C.	Exceptions	16
D.	Entertainment	16
XI.	Political Activity & Government Relations	16
XII.	Exemptions	17
A.	Exempt Access Persons	17
B.	Requests for Exemption	17
XIII.	Copyright Laws	17
XIV.	Media Relations & Third Party Inquires	17
XV.	Reporting Violations	18
XVI.	Sanctions	18
XVII.	Reports and Certifications of Adequacy	18
XVIII.	Client Notification	18
XIX.	Access Person Training and Certification	18

I. Policy Highlights

The Code is designed to ensure that all applicable acts, practices and courses of business engaged

in by Access Persons (all capitalized terms are defined herein) are conducted in accordance with

the highest possible standards, and to prevent conflicts of interest or even the appearance of

conflicts by Access Persons when conducting their personal trading and other business activities.

This section sets forth selected rules that frequently raise questions. This is by no means a

comprehensive list of all the applicable rules and requirements. Access Persons must examine

the specific sections of the Code for more details and are strongly encouraged to consult

applicable policies and procedures or the Advisor’s Compliance Department when questions

arise:


·	All Personal Securities Transactions must be pre-cleared through the Compliance
	Department, unless specifically exempted by the Code.

·	Access Persons are required to have duplicate account statements and trade confirmations
	sent to the Advisor’s Compliance Department for any Covered Account in which the
	Access Person(s) may obtain Beneficial Ownership of a Covered Security.

·	Access Persons are required to report new Covered Accounts within 30 days after the
	calendar quarter end.

·	Affiliated Mutual Funds are exempt from pre-clearance requirements of the Code but are
	subject to its holding and reporting requirements.

·	Purchases and sales of shares in money market funds are exempt from the pre-clearance,
	holding period and reporting requirements of the Code.

·	Exchange traded funds (“ETFs”) and closed-end mutual funds must be pre-cleared and
	are subject to all holding and reporting requirements.

·	Access Persons are prohibited from acquiring any equity or fixed income security in an
	initial public offering (“IPO”) or secondary public offering.

·	Limited offerings (e.g., private placements) must be pre-approved by the Advisor’s
	Compliance Department.

·	Outside business activities, including service as a director or trustee of a company, must
	be pre-approved by the Chief Compliance Officer, or its designee.

·	Access Persons may not sell Covered Securities under any circumstances unless they
	have been held for at least 30 days.

·	An Access Person may not repurchase any security it has sold within the previous 30
	days.

·	No Access Person may purchase or sell a Covered Security for a period of 7 calendar
	days after the Covered Security has been traded by the Advisor on behalf a client
	account.


·	No Access Person may purchase or sell any security, which to their knowledge at the
	time of the intended trade is being considered by the Advisor for purchase or sale on
	behalf of a client account.

·	Access Persons are required to submit an Initial Holdings Report within ten days of
	becoming an Access Person, Quarterly Transactions Reports within thirty days of each
	calendar quarter end, and Annual Holdings Reports and Certifications of Compliance
	within thirty days of each calendar year end.

II. General Principles

	A. Shareholder and Client Interests Come First

	Access Persons of the Advisor must comply with all applicable federal securities laws.
	This Code is designed to assist Access Persons in fulfilling their regulatory and fiduciary
	duties.

	Every Access Person owes a fiduciary duty to each of the Advisor’s clients and their
	shareholders. Access Persons must always recognize the needs and interests of the
	Advisor’s clients and be certain that, at all times, the interests of the Advisor’s clients are
	considered ahead of any personal interest.

	B. Avoid Actual and Potential Conflicts of Interest

	The restrictions and requirements of the Code are designed to prevent behavior, which
	actually or potentially conflicts, or raises the appearance of an actual or potential conflict,
	with the interests of the Advisor’s clients. It is imperative that the Personal Securities
	Transactions of Access Persons are conducted in a manner consistent with both the letter
	and spirit of the Code to avoid any such conflict of interest and to prevent abuse of an
	Access Person’s position of trust and responsibility.

III. Definitions

“Access Persons” shall include all of the Advisor’s supervised persons including any director,
officer, partner, employee or other related person as designated by the Firm who are:

	i. Supervised personnel and have access to:
	a.	Nonpublic information regarding any purchase or sale of securities by any
		client of the Advisor; or
	b.	Nonpublic information regarding the portfolio holdings of any account the
		Advisor manages.

	ii. Any person who is involved in making securities recommendations to clients or has
	access to such recommendations that are nonpublic.

iii Any other persons falling within such definition under Rule 17j-1 under the

Investment Company Act of 1940 or Rule 204A-1 under the Investment Adviser Act

of 1940.

iv. Any person who primarily works within the main office of the Advisor.

All employees of the Advisor are deemed to be Access Persons under this Code, unless

designated by the Chief Compliance Officer to be an Exempt Access Person.

“Affiliated Mutual Funds” shall include a series of open-end investment companies that are

advised or sub-advised by the Advisor as well as those funds within Principal Funds, Inc. and

Principal Variable Contracts Fund, Inc. (collectively, the “Principal Funds”) that are not sub-

advised by the Advisor.

“Beneficial Ownership” shall include an Access Person having beneficial interest of securities

held in an account in the name of: (1) the individual; (2) a husband, wife or minor child; (3) a

relative sharing the same house; (4) another person if the Access Person (i) obtains benefits

substantially equivalent to ownership of the securities; (ii) can obtain ownership of the securities

immediately or at some future predetermined time; or (iii) can have investment discretion or

otherwise can exercise control.

“Code of Ethics Review Committee” consists of the Advisor’s Chief Compliance Officer, and

President (or chief executive officer). The purpose of the committee is to: (1) review

recommendations of the Compliance Department regarding requests by Access Persons for relief

or exemption from any restriction or requirement of this Code; (2) consider requests by Access

Persons to serve as a director of an unaffiliated organization or engage in outside business

activities which may represent a potential conflict with their employment with the Advisor; (3)

determine appropriate sanctions to be imposed upon Access Persons determined to have

committed a material violation of this Code; and (4) discuss and review other matters related to

this Code as deemed appropriate by the Chief Compliance Officer.

“Covered Accounts” shall include any account in which an Access Person has or acquires any

direct or indirect Beneficial Ownership in a security held in the account. Common examples of

accounts representing Beneficial Ownership include joint accounts, spousal accounts, UTMA

accounts, partnerships, trusts and controlling interests in corporations. Any uncertainty as to

whether an account represents a Covered Account should be brought to the attention of the

Compliance Department. Such questions will be resolved in accordance with, and this definition

shall be subject to, the definition of “beneficial owner” found in Rules 16a-1(a)(2) and (5)

promulgated under the Securities Exchange Act of 1934.

“Covered Securities” shall include all securities, any option or future to purchase or sell, and any

security convertible into or exchangeable for such securities. For example, Covered Securities

also include, but are not limited to, individual securities, open-end mutual funds, ETFs, closed-

end funds and unit investment trusts. Exemption from certain requirements of the Code may

apply to designated Covered Securities, as set forth below. In addition, certain securities, such as


money market funds, are exempt from the definition of “Covered Security” as explained in the
Code.

“Exempt Access Person” shall mean any Access Person who has received a written exemption
from the Chief Compliance Officer from the restrictions and requirements of this Code. Exempt
Access Persons are subject to all other sections of the Code. Generally, Exempt Access Persons
may be temporary or part-time employees, or contractors without access to applicable
confidential and/or tactical trading, holding or account information.

“Insider Access Person” shall mean any employee of Edge or an affiliate located at Edge who, in
the regular course of their business activities, has access to certain non-public proprietary
information related to the Principal Funds not sub-advised by Edge.

“Investment Personnel” shall mean any employee who, in connection with his or her regular
functions or duties, makes or participates in making recommendations regarding the purchase or
sale of securities, or anyone who, in connection with their job functions, has real-time knowledge
of such recommendations or supervises of those making recommendations regarding the
purchase or sale of securities. This includes, but is not limited to, portfolio managers, research
analysts, and personnel in the trading department, among others.

IV. Personal Securities Transactions

A. Prohibited Conduct

No Access Person shall buy or sell any Covered Security, with the exception of those
described in sub-section C. below titled Exempt Securities (referred to herein as a
"Personal Securities Transaction") unless:

1	.	Pre-clearance approval of the transaction has been obtained from the Compliance
		Department; and
2	.	The transaction is reported to the Compliance Department in accordance with the
		requirements below.

B. Restrictions and Limitations on Personal Securities Transactions

Except where otherwise indicated, the following restrictions and limitations govern
Personal Securities Transactions:

1	.	Covered Securities purchased may not be sold until at least 30 calendar days from
		the purchase trade date. Covered Securities sold may not be repurchased until at
		least 30 calendar days from the sale trade date. A violation may result in
		disgorgement of all profits from the transactions as well as other possible
		sanctions.

2	.	Affiliated Mutual Funds (excluding money market funds), whether purchased in a
		brokerage account, directly through a transfer agent or in a 401(k) or other


		retirement plan, may not be sold, redeemed or exchanged until at least 60 calendar
		days from the purchase trade date. They may not be repurchased until at least 60
		calendar days from the sale trade date.

3	.	No opening transactions in options or futures may be executed if the expiration
		date is less than 30 calendar days from the date the transaction was executed.

4	.	No Access Person may acquire any equity or fixed income security in an initial
		public offering (“IPO”) or secondary public offering.

5	.	Access Persons shall obtain approval from the Compliance Department prior to
		the acquisition of securities issued pursuant to a "private offering" (as that term is
		generally recognized as an exemption from registration under Section 4(2) of the
		Securities Act of 1933) ("Private Offering Security") in which they, their families
		(including those immediate family members sharing the same household as the
		Access Person) or trusts of which they are trustees or in which they have a
		beneficial interest are parties. The Compliance Department shall promptly notify
		the person of approval or denial for the transaction. Notification of approval or
		denial for the transaction may be given verbally; however, it shall be confirmed in
		writing within 72 hours of verbal notification. In reviewing the request, the
		Compliance Department shall consult with the President, the Chief Compliance
		Officer and the applicable Asset Class Heads or Chief Investment Officer, and
		shall take into account, among other factors, whether the investment opportunity
		should be reserved for the Advisor’s clients, and whether the opportunity is being
		offered to such person as a result of his or her position with the Advisor.
		Investment Personnel who are Beneficial Owners of any Private Offering Security
		shall be required to disclose such ownership to the Compliance Department prior
		to making any recommendation regarding the purchase or sale of the Private
		Offering Security by a client or participating in the determination of which
		recommendations shall be made to a client. Under such circumstances, the
		Advisor's decision to purchase the Private Offering Securities shall be subject to
		an independent review by Investment Personnel with no personal interest in the
		Private Offering Securities.

6	.	No purchase or sale transaction may be made in any Covered Security by an
		Access Person for a period of 7 calendar days after that Covered Security is
		purchased or sold by the Advisor on behalf of any client account. Any profits
		realized on these trades may be subject to disgorgement.

7	.	No Access Person shall purchase or sell any Covered Security, which to their
		knowledge at the time of such purchase or sale is being considered for purchase or
		sale by a client account¹.


8	.	If a Personal Securities Transaction is not executed on the day pre-clearance
		approval is granted, it is required that pre-clearance approval be obtained again on
		the subsequent day (i.e., open orders, such as limit orders, good until cancelled
		orders and stop-loss orders, must be pre-cleared each day until the transaction is
		effected).

9	.	Access Persons shall not participate in investment clubs.

C. Exempt Securities

1	.	The following securities are exempt from: (i) the pre-clearance requirement of
		Section IV.(A); (ii) the holding period and other restrictions of this Section
		IV.(B); and (iii) the initial, quarterly and annual reporting requirements of Section
		V.(A):
		a)	Direct obligations of the United States Government²;
		b)	Bank Certificates of Deposit;
		c)	Bankers' Acceptances;
		d)	Commercial Paper;
		e)	High Quality Short-Term Debt Instruments³;
		f)	Shares held in money market funds;
		g)	Shares held in open-end Mutual Funds other than Affiliated Mutual
			Funds⁴.

2	.	Transactions in redeemable Unit Investment Trusts are exempt from the holding
		period restrictions contained in this Section IV.(B)(1) and the pre-clearance
		requirement of Section IV.(A), but are subject to the initial, quarterly and annual
		reporting requirements reporting requirements of Section V.(A).
3	.	Affiliated Mutual Funds are exempt from the pre-clearance requirement of this
		Section IV.(A), but are subject to the initial, quarterly and annual reporting
		requirements of Section V.(A), and the holding period restrictions contained in
		Section IV.(B)(2).
4	.	Affiliated Mutual Fund transactions that are made through an automated
		systematic purchase/redemption plan are exempt from the pre-clearance
		requirement of this Section IV.(A), and the holding period restrictions contained

the security’s average trading volume to determine if the trades impacted each other. If it is determined that no impact occurred,

the Compliance Department may deem the infraction to be a technical non-volitional violation.

²Includes securities that carry full faith and credit of the U.S. Government for the timely payment of principal and interest, such

as Ginnie Maes, U.S. Savings Bonds, and U.S. Treasuries.

³These include repurchase agreements or any instrument that has a maturity at issuance of fewer than 366 days that is rated in

one of the two highest categories by a Nationally Recognized Statistical Rating Organization.

⁴Includes purchases of applicable 529 plans which may technically represent municipal securities but for which the underlying

investment options are limited to open-end mutual funds or securities designed to mirror the structure of open-end mutual funds.


		in Section IV.(B)(2), but are subject to the initial, quarterly and annual reporting
		requirements of Section V.(A).
5	.	Notwithstanding anything to the contrary within the Code, securities that are not
		eligible for purchase or sale by the Advisor are exempt from pre-clearance
		requirement of Section IV.(A) and from the holding period restrictions contained
		in this Section IV.(B)(1), but are subject to initial, quarterly and annual reporting
		requirements of Section V.(A).
6	.	Securities issued by the Principal Financial Group® or its subsidiaries (“PFG”),
		including PFG common stock, are exempt from the pre-clearance requirement of
		Section IV.(A) and the holding restrictions contained in Section IV.(B)(1) but are
		subject to the initial, quarterly and annual reporting requirements of Section
		V.(A). Access Persons are responsible for understanding whether they are subject
		to the PFG corporate policy and rules on trading in PFG common stock. All
		Access Persons are prohibited from purchasing PFG stock on margin, trading in
		put or call options on PFG stock or entering into short sales of PFG stock.

D. Exempt Transactions
1	.	The transactions listed below are exempt from the pre-clearance and holding
		requirements of this Section IV., but are subject to the quarterly reporting
		requirements of Section V.(A)(2):
		a)	Purchases which are part of an automatic dividend reinvestment plan.
		b)	Purchases or sales, which are non-volitional on the part of the Access
			Person.
		c)	Purchases effected upon the exercise of rights issued by an issuer pro
			rata to all holders of a class of its securities, to the extent, such rights
			were acquired from such issuer, and sales of such rights so acquired.
		d)	Maturity of a fixed income security.

2	.	All Access Persons wishing to directly participate in or obtaining Beneficial
		Ownership through an issuer’s automated direct stock purchase plan or an
		employee stock purchase plan must submit a memorandum to the Compliance
		Department stating the name of the security and the amount to be invested, in
		frequency of the transactions, the method of payment (i.e. ACH, bank wire drafts
		etc.) and the institution where the transaction will be processed. Please note that
		only automatic purchases may be approved under this provision. Upon review, the
		Compliance Department will approve or decline the investment plan in writing.
		Once approved all subsequent trades made in conjunction will be considered
		approved unless otherwise notified by the Compliance Department. However,
		any change made to the security, purchase amount, or frequency will be
		considered a deviation from the approved investment plan and will require
		subsequent pre-approval. Automated systematic purchases under an issuer’s
		direct stock purchase plan or employee stock purchase plan that adhere to the
		above reference provisions are exempt from the restrictions contained in this
		Section IV.(B)(1), (B)(6) and (B)(7), but are subject to all other provisions
		including initial, quarterly and annual reporting requirements. Please note that


		these provisions are applicable to purchase only. Liquidations from a direct stock
		purchase plan or employee stock purchase plans must adhere to standard
		requirements.

3	.	Access Persons are permitted to make regular purchases in Covered Securities
		when participating in an employer-sponsored 401(k) plan, for which the Access
		Person is making automatic payroll deductions. Such purchases are exempt from
		the pre-clearance requirement of Section IV.(A) and the holding requirements of
		Section IV.(B)(1), (B)(2), (B)(6) and (B)(7). Unless specifically exempted in the
		Code, any sell transactions in Covered Securities within a 401(k) plan are subject
		to the pre-clearance requirement of Section IV.(A). The initial, quarterly and
		annual reporting requirements of Section V.(A) apply.

4	.	All Non-Investment Personnel wishing to establish a non-controlled/non-
		volitional account must submit a written request to and receive approval from the
		Advisor’s Chief Compliance Officer prior to the establishment of the account.
		Each account request will be reviewed on a case-by-case basis and written
		approval will be provided by the Chief Compliance Officer. Once the account is
		established, the Access Person will be exempt from the pre-clearance
		requirements of Section IV.(A) and the holdings requirements of Section
		IV.(B)(1), (B)(2), (B)(6) and (B)(7). However the Access Person will be subject
		to the reporting requirement outlined in Section V.(A), as well as completing, on a
		quarterly basis, a Non-Controlled Account/Non-Volitional Transaction
		Certification. Investment Personnel are not permitted to establish non-
		controlled/non-volitional accounts.

E. Pre-Clearance Requirement

1	.	Personal Securities Transactions

		The Compliance Department will process Personal Securities Transaction
		requests on a daily basis and will notify the Access Person whether the request
		has been approved or denied. If a Personal Securities Transaction request is
		approved, the specified transaction must be completed prior to the close of
		business on the day the request was approved. Any transaction not completed
		prior to the close of business will require a new approval.

		Personal Securities Transaction Approval Process

		Access Persons are required to obtain pre-clearance approval of a Personal
		Securities Transaction by completing a Confidential Personal Securities
		Transaction Request Form and receiving an approval email of their transaction
		request from the Advisor’s Compliance Department. Access Persons are required
		to complete the following information on the Confidential Personal Securities
		Transaction Request Form: trade date, security name, trading symbol, security


type, transaction type, estimated number of shares/or value and identification of
any known conflicts of interest.

Insider Access Persons must also obtain pre-approval from PGI Compliance in
addition to approval from Edge Compliance Department prior to executing
personal securities transactions.

2. Factors Considered in Pre-Clearance of Personal Securities Transactions

When evaluating a Personal Securities Transaction for pre-clearance, the
following factors, among others, may generally be considered:

·	Whether the requested security: (i) is currently held in any client accounts; (ii)
	has been purchased or sold by a client account in the past seven days; or (iii)
is being considered for purchase or sale by a client account.
·	Whether the Access Person will improperly benefit from purchases or sales,
	which have been executed or are being considered by a client account.
·	Whether the proposed transaction will be conducted in a manner that is
	consistent with the requirements of the Code.
·	Whether the proposed transaction would impact the price of the security,
	considering the number of shares being traded in relation to the issuer’s
	market cap and the security’s average daily volume.

In addition to the requirements set forth in the Code, the Advisor’s Compliance
Department and/or, if applicable, designated Portfolio Manager and/or Asset
Class Head, in keeping with the general principles and objectives of the Code,
may refuse to grant pre-clearance of a Personal Securities Transaction if it is
determined that it may present a material conflict of interest.

V. Reporting Requirements

A. Reports of Transactions & Holdings
Under the Code, Access Persons are subject to several reporting requirements. At the
beginning of their employment, or upon determination of being an Access Person, each
Access Person is required to complete an Initial Holdings Report. Access Persons are
also required to complete Quarterly Transactions Reports and an Annual Holdings Report
& Certification of Compliance. It is the responsibility of each Access Person to submit
their reports to Compliance in a timely manner. Compliance will notify Access Persons
of their quarterly and annual reporting obligations under the Code.

At the beginning of their employment or upon determination of being an Access Person,
each Access Person shall immediately provide to the Compliance Department duplicate
copies of all periodic statements issued by Covered Accounts and arrange for future
statements to be provided to the Compliance Department.

1. Initial Holdings Report


		Not later than 10 days after becoming an Access Person, he or she must provide
		an Initial Holdings Report to the Advisor’s Compliance Department, (which
		information must be current as of a date no more than 45 days prior to the date the
		person becomes an Access Person), disclosing:

		(i)	All Covered Securities, including Affiliated Mutual Funds and
			Private Offering Securities beneficially owned by the Access Person,
			listing the title and type of the security, and as applicable the
			exchange ticker symbol or CUSIP number, number of shares held,
			and principal amount of the security.

		(ii)	The name of the broker, dealer, bank or financial institution where
			the Access Person maintains a Covered Account.

		(iii)	The date the report is submitted by the Access Person.

2	.	Quarterly Transactions Reports

		Access Persons must submit Quarterly Transactions Reports within 30 calendar
		days after the end of each calendar quarter. Any new brokerage account, or any
		account opened for the purchase of Affiliated Mutual Funds must also be reported
		within 30 calendar days after the end of each calendar quarter.
		All Personal Securities Transactions in Covered Securities, and all securities
		transactions in Affiliated Mutual Funds must be reported in the next quarterly
		transaction report for the quarter in which the transaction was effected. Please
		note that there are only two exceptions: the first one is for Access Persons who
		are providing the Advisor’s Compliance Department with duplicate copies of all
		periodic statements issued by Covered Accounts. The second exception is for
		Access Persons with non-controlled/non-volitional accounts who are also
		providing the Compliance Department with duplicate copies of all periodic
		statements issued by Covered Accounts and who do not have to report any of
		these account transactions in the quarterly transaction report after the transaction
		was effected. The quarterly report shall contain the following information:

		(i)	The date of the transaction, the title and type of the security, and as
			applicable the exchange ticker symbol or CUSIP number, interest
			rate and maturity date (if applicable), number of shares and principal
			amount of each security involved.

		(ii)	The nature of the transaction (i.e., purchase, sale, or any other type
			of acquisition or disposition).

		(iii)	The price at which the purchase or sale was effected.

		(iv)	The name of the broker, dealer, bank or other financial institution
			with, or through which, the purchase or sale was effected.


	(v)	The date the report was submitted to the Advisor’s Compliance
		Department by such person.

3. Annual Holdings Report & Certification of Compliance

The Annual Holdings Report & Certification of Compliance requires all Access
Persons to provide an annual listing of holdings of:

	(i)	All Covered Securities beneficially owned, including all Affiliated
		Mutual Funds (excluding money market accounts), listing the title
		and type of the security and as applicable the exchange ticker,
		symbol or CUSIP number, number of shares held, and principal
		amount of the security as of December 31 of the preceding year.

	(ii)	The name of any broker, dealer, bank or financial institution where
		the account(s) in which these Covered Securities were maintained, as
		of December 31 of the preceding year.

	(iii)	The date the report is submitted. This report must be provided no
		later than 30 calendar days after December 31 each year.

B. PFG Employee Benefit Plans

The following PFG employee benefit plans are considered Covered Accounts; however,
Access Persons are not required to report these accounts or transactions executed therein.
The Compliance Department may obtain holdings and transaction information for these
accounts directly from PFG Human Resources.

·	PFG Employee Stock Purchase Plan

·	PFG Excess Savings Plan
·	PFG 401(k) Plan

Please note, PFG restricted stock, stock options, or performance share awards held within
a personal brokerage account (and no longer a plan administrator) must be reported.
Duplicate account statements for such accounts should be provided to Compliance.

C. Responsibility to Report
The responsibility for reporting is imposed on each Access Person required to make a
report.

D. Where to File Report
All reports must be filed by Access Persons with the Advisor’s Compliance Department.

E. Responsibility to Review

The Advisor’s Compliance Department will review in a timely manner all initial,

quarterly and annual reports submitted by Access Persons, as well as all duplicate

account statements and trade confirmations to verify that Access Persons have complied

with the pre-clearance, holding and reporting requirements of this Code.

VI. Insider Trading

The Advisor has developed policies and procedures to detect and prevent insider trading. The

Advisor seeks to foster a reputation for integrity and professionalism. That reputation is a vital

business asset. The confidence and trust placed in the Advisor by its clients is something it

values and endeavors to protect. To further that goal, procedures have been implemented to

deter the misuse of material, nonpublic information in securities transactions. Please see the

Advisor’s Insider Trading Policy for a complete explanation of the policy.

VII. Confidentiality

No Access Person shall disclose portfolio holdings information, investment recommendations or

pending securities transactions or non public portfolio holdings to any third party unless such

parties have agreed in writing, or are legally obligated, to maintain the confidentiality of the

information and to refrain from using such information to engage in securities transactions.

Edge has taken steps to ensure confidential information is appropriately safeguarded. Such

safeguards would include but are not limited to restrictions on Access Person personal trading

activity, restricted treatment and access to client information, and establishment and enforcement

of a portfolio holdings disclosure policy. Additionally, access to confidential information

including both soft and hard copy files are generally limited and information is maintained in

secure locations.

VIII. Anti-Money Laundering

All Access Persons must recognize the importance of guarding against the use of client accounts

for money laundering activities. The Advisor has adopted policies to conduct business in a

manner consistent with all applicable requirements of the Bank Secrecy Act as such pertains to

its business.

IX. Service as a Director and Outside Business Activities

A. Approval to Serve as a Director

No Access Person may serve as a director or trustee on the board of any organization,

partnership, corporation or non-profit agency without prior approval from the Chief

Compliance Officer or its designee. An Access Person may obtain approval to serve as a

director or trustee by submitting a written request to the Compliance Department. If such

approval is granted, it may be subject to the implementation of information barrier

procedures or additional restrictions and it is the responsibility of the Access Person to

notify Compliance immediately if any conflict or potential conflict of interest arises in


the course of such activity. If it is determined that such service would create a conflict of
interest and the request is therefore denied, the determination may be reviewed and
confirmed by the Code of Ethics Committee.

B. Approval to Engage in Outside Business Activities

No Access Person may engage in any outside business activity without prior approval of
the Compliance Department. An outside business activity is generally considered any
activity, including but not limited to employment, consulting, contracting or otherwise
providing services for direct or indirect compensation. An Access Person may obtain
approval to engage in an outside business activity by submitting a written request to the
Compliance Department. If such approval is granted, it may be subject to the
implementation of information barrier procedures or additional restrictions and it is the
responsibility of the Access Person to notify Compliance immediately if any conflict or
potential conflict of interest arises in the course of such activity. If it is determined that
such activity would create a conflict of interest and the request is therefore denied, the
determination will be reviewed and confirmed by the Code of Ethics Review Committee.

X. Gifts & Entertainment

A. Gifts Given

No Access Persons may give gifts in excess of $100 per person per year to any client,
prospective client or any entity that does business with the Advisor without prior
approval from the President (or chief executive officer) and Chief Compliance Officer.
Access Persons are required to promptly report to the Compliance Department gifts given
that are not promotional items of nominal value.

B. Gifts Received

No Access Person shall accept directly or indirectly anything of value, including gifts and
gratuities, in excess of $100 per year from a client, prospective client, or any entity that
does business with the Advisor, not including occasional meals or tickets to theater or
sporting events or other similar entertainment that is neither excessive nor frequent.
Client entertainment expenses generally are not considered gifts if: (i) Firm personnel are
present; (ii) a Firm client is present; and (iii) the entertainment is not so regular or
frequent that it creates the appearance of impropriety.

Unless reporting is specifically exempted by the Code Access Persons are required to
promptly report to the Compliance Department:

·	Any gift received.

·	Any entertainment received.
·	Any meal or meals received in a calendar year in aggregate are valued in
	excess of $300.


No Access Person may solicit gifts from anyone in return for any business, service or
confidential information.

No Access Person may give or accept cash gifts or cash equivalents from a client,
prospective client, or any entity that does business with the Advisor. Access Persons are
also subject to Principal Financial Group’s Gifts & Gratuity Policy.

C. Exceptions

No prior approval or reporting is required for gifts given or received as described below,
and does not count toward the $100 limit on individual gifts.

·	Personal gifts (wedding, birthday, etc.) provided (i) the Access Person pays
	for the gift with his or her own money; and (ii) the gift is not related to the
	Advisor’s business (i.e. would the Access Person otherwise give the gift or
	receive the gift if there were no business relationship?).

·	Promotional materials (logo golf balls, pens, etc.) of nominal value (under $50
	in approximate value).

·	Personal political contributions whereby Access Persons support the political
	candidates of their choice, independent of any influence from the Company or
	any of its executives.

D. Entertainment

If the third party hosting the entertainment is not present and the Access Person attends
the event, the entertainment is considered a gift subject to the Gifts Received
requirements. Entertainment may be acceptable if accompanied by third party hosting
the entertainment and prompt notification is provided to the Compliance Department.

Entertainment must not be lavish or so excessive as to appear to unduly influence the
judgment of the Access Person or of the client or prospect, or otherwise appear improper
under these requirements. There is no specific dollar amount that represents “lavish or
excessive entertainment” and must be determined on a case-by-case basis.

XI. Political Contribution & Government Relations

The Advisor has developed policies and procedures to address pay-to-play practices. Pay-to-
play is the practice of making campaign contributions and related payments to elected officials in
order to influence the awarding of lucrative contracts for the management of public pension plan
assets and similar government investment accounts. The Advisor has adopted a policy, which
attempts to deter such activity. Please see the Advisor’s policy for engaging in political activity
on behalf of the firm and for Access Persons, which addresses restricting political contributions;
banning solicitation of contributions; banning certain third party solicitors and restricting indirect
contributions and solicitations.

XII. Exemptions

A. Exempt-Access Persons

The Advisor’s officers, directors, employees and other related persons are presumed to be

Access Persons subject to this Code. However, certain persons, such as certain officers

and directors of the Advisor, as well as other persons such as temporary or part-time

employees, often do not have actual access to nonpublic information regarding portfolio

holdings or investment recommendations. In cases where the Chief Compliance Officer

determines that a presumed Access Person does not have access to nonpublic information

with respect to portfolio holdings, transactions, or securities recommendations and is not

involved in the recommendation process, the Chief Compliance Officer may declare such

person to be an Exempt Access Person and therefore not subject to of this Code. The

Chief Compliance Officer will provide each Exempt Access Person written notification

of their status and specify those sections of the Code from which they are exempt.

B. Requests for Exemption

In special circumstances, an Access Person may request and obtain relief or an exemption

from any restriction, limitation or procedure contained herein this Code. The Access

Person shall submit a written request for an exemption to the Compliance Department for

initial review. The Compliance Department shall forward the request to the Code of

Ethics Review Committee with its recommendation to approve or deny the request. The

Committee will consider the request and make a final determination to approve or deny

it. Such determination will be communicated to the Access Person by the Compliance

Department in writing.

XIII. Copyright Laws

All Access Persons must adhere to all copyright laws. Copyright is a protection that covers

published and unpublished articles or other forms of expression, meaning the law grants the

creator the exclusive right to reproduce, and distribute. Article regarding any of our personnel or

our business that have been published may not be reproduced without the creator’s approval

because he owns the exclusive rights which means he is the only one who can reproduce and

distribute the materials. Please contact the Compliance Department with any questions in

regards to Copyright Laws.

XIV. Media Relations & Third Party Inquiries

Given the sensitive nature of media inquiries in general, it is necessary that all Access Persons

refrain from responding to media or third party inquires without consulting with applicable

management. An Access Person should refer the Firm’s policies and procedures to determine an

appropriate response.


XV. Reporting Violations

All Access Persons are required to promptly report any violation of the Code of Ethics they
become aware of to the Compliance Department.

XVI. Sanctions

All violations of this Code will be reported promptly to the Chief Compliance Officer. If the
Chief Compliance Officer determines a violation to be material, the Chief Compliance Officer
shall forward the reported violation and such determination to the Code of Ethics Review
Committee. Upon review, the Committee may impose such sanctions as they deem appropriate,
including a reprimand (orally or in writing), disgorgement, monetary fine, demotion, suspension
or termination of employment and/or other possible sanctions. All material violations of this
Code and any sanctions imposed with respect thereto shall be reported to the Advisor’s Board of
Directors.

XVII. Reports and Certifications of Adequacy

On an annual basis, the Advisor’s Chief Compliance Officer shall provide a report to
management, which includes the following:

·	A statement that the Code of Ethics procedures have been designed to prevent Access
	Persons from violating the Code.
·	A summary of any changes in procedures made during the past year.
·	Identification of any violations that required significant remedial action during the past
	year.
·	Identification of any recommended changes based upon the Advisor's experience under
	the Code, evolving industry practices, or developments in applicable laws or regulations.

XVIII. Client Notification
The Advisor shall provide a revised version of the Code within 60 days of adopting any material
revisions or within 60 days of implementing any material revisions of the Code if such revisions
have been implemented by the Advisor prior to formal adoption to all clients of the Advisor that
have requested notification associated with material changes to the Code.

XIX. Access Person Training and Certification

All new Access Persons will receive training on the policies and procedures of this Code. New
Access Persons are required to provide a written certification attesting to their understanding of,
and their agreement to abide by the terms of this Code. In addition, Access Persons are required
to certify annually or at any time they receive amendments to this Code that: (i) they have read
and understand the terms of the Code and recognize the responsibilities and obligations incurred
by their being subject to the Code; and (ii) they are in compliance with the requirements of the
Code.