Monongahela Capital Management conducts its business with the highest level of ethical standards, recognizing our fiduciary role.

MCM places the interests of its clients before the interest of the firm or its employees. Monongahela Capital Management strives to act always in the best interests of the clients. This code of ethics is driven by a commitment to honesty, openness and behavior defined by integrity. It is through adherence to the highest ethical code that this company earns and retains the trust of its clients. Monongahela Capital Management is committed to the adherence by all its employees to both the letter and the spirit of all applicable laws.

This code of ethics applies to all employees of MCM and Rodgers Brothers Inc. (RBI).

Standard of Conduct and Compliance with Laws, Rules and Regulations

All employees of MCM and RBI are responsible for reviewing this code of ethics, and all company policies as outlined in the Supervisory Manuals, and for acting in compliance with these policies in daily activities. All employees acknowledge that each has agreed to review and act in compliance with all company policies guiding our securities business as a requirement of employment.

Employees will respect and obey all of the laws, rules and regulations applicable to our business, including among others, securities, banking and other federal, state and local laws. Each employee is responsible for being familiar with and complying with the procedures applicable to him or her, as outlined in the Supervisory Manuals of the company. When unclear or in doubt, the employee is to seek direction from one of the principals of the firm.

Protection of Material Non Public Information

In the course of daily activity, employees may have access to information about our clients, the recommendations of Monongahela Capital Management, and the structuring of positions within the portfolios of individual clients. It is prohibited for any employee to act upon or use this information (which is considered to be material non public information) for gain. Employee access to information is limited to a need-to-know basis.

Monongahela Capital Management and Rodgers Brothers Inc. prohibit the use of any non-public information in its daily activity by ascertaining any clients or employees who may have access to non-public information and restricting trades based on this information. A watch list is maintained for all securities in which the company or its employees may have non-public information.

Personal Securities Trading

Employees are prohibited from holding accounts at other firms, and must be familiar with and follow all employee trading policies and procedures as outlined in the company Supervisory Manuals. Monongahela Capital Management and Rodgers Brothers Inc. diligently pre-approve and review all trades of all employees.

Rule 204A-1 of the Advisers Act requires the periodic review of personal securities transactions and holdings. All employee transactions are executed through Rodgers Brothers, and pre-approved prior to execution. All transactions are reviewed daily with the review of the trading blotter.

Consequences for Failure to Comply and Reporting Certain Conduct

An employee is subject to discipline up to and including termination of employment if he or she violates this code and its component parts, including the policies and procedures outlined in the Supervisory Manuals. If an employee knows of, or reasonably believes that there is a violation of applicable laws or this code of ethics, an employee must report that information immediately to the Compliance Officer. Anyone who in good faith raises an issue regarding a possible violation of law, regulation or company policy or any suspected illegal or unethical behavior will be protected from retaliation.