Code of Ethics

Last updated Mar 15, 2023

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INTRODUCTION

This Code of Ethics ("Code") applies to all directors, officers, employees, and contractors (collectively referred to as "Employees") of Gray Market, which includes the Gray Fund and the Algo Trading Bot (collectively, the "Company"). The purpose of this Code is to promote honest and ethical conduct, appropriate use of the Company's assets, and compliance with applicable laws, rules, and regulations.

1. HONEST AND ETHICAL CONDUCT: Employees shall act in an honest and ethical manner in all dealings related to the Company. This includes the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.

2. COMPLIANCE WITH LAWS, RULES, AND REGULATIONS: Employees shall comply with all applicable governmental laws, rules, and regulations. Employees shall also comply with all internal policies and procedures of the Company.

3. CONFLICTS OF INTEREST: Employees must avoid any personal activity, investment, or association that could interfere with their objective judgment, influence their decisions, or compromise the performance of their duties.

4. FAIR DEALING: Employees shall deal fairly with the Company's customers, suppliers, competitors, and employees. No Employee shall take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice.

5. PROTECTION AND PROPER USE OF COMPANY ASSETS: Employees shall protect the Company's assets and ensure their efficient use. All Company assets should be used for legitimate business purposes.

6. CONFIDENTIALITY: Employees must maintain the confidentiality of information entrusted to them by the Company or its customers, except when disclosure is authorized or legally mandated.

7. REPORTING OF ILLEGAL OR UNETHICAL BEHAVIOR: Employees should promptly report any observed illegal or unethical behavior to management or other appropriate personnel.

8. COMPLIANCE WITH CODE OF ETHICS: Any Employee who violates this Code may face disciplinary action, up to and including termination of employment or contractual relationship. The Company will not allow retaliation against an Employee for good faith reporting of any violations.

By continuing their association with the Company, Employees affirm that they have read, understood, and accepted the principles outlined in this Code of Ethics. Each Employee has a responsibility to adhere to these principles, as they form the foundation of our corporate culture and reputation.

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© Copyright 2024 Gray Digital Capital Management, Inc. All Rights Reserved.

Services are provided by Gray Digital Capital Management, Inc.; Gray Digital Capital Management USA, LLC and Gray Digital Technologies, LLC ("Gray Digital"), collectively "The Company",

Investors and other participants in the Gray Digital ecosystem should carefully consider their financial circumstances, risk tolerance, and investment objectives before deciding to invest in the Company or interact with the ecosystem in any way. The risks outlined in the risk disclosure are not exhaustive, and potential investors and participants should review the Company's offering documents and terms of use for a more complete discussion of the risks associated with investing in the Company and participating in the Gray Digital ecosystem. By investing in Gray Digital or participating in the Gray Digital ecosystem, you acknowledge that you have read, understood, and accepted the risks detailed in this legal risk disclosure.

Nothing on this website should be considered an offer, solicitation of an offer, or advice to buy or sell securities or investment products. Past performance is no guarantee of future results. Any historical returns, expected returns, or probability projections are hypothetical in nature and may not reflect actual future performance. Account holdings and other information provided are for illustrative purposes only and are not to be considered investment recommendations. The content on this website is for informational purposes only and does not constitute a comprehensive description of Gray Digital's advisory services.

The performance discussed herein is historic and reflects an investment for a limited period of time. It should not be assumed that future investors would experience returns, if any, comparable to those illustrated herein. Past performance is not indicative of future returns. Investment results will fluctuate. Returns are not guaranteed. All investments are subject to the risk of loss, including the loss of principal. No representation is being made that an investment account has, will, or is likely to achieve profits or losses equal to the profits or losses shown. Actual returns will vary greatly and depend on personal and market conditions. Before investing, consider your financial goals and the costs of using the program.

Furthermore, the information set forth has been obtained from sources that the Firm believes to be reliable; however, these sources cannot be guaranteed as to their accuracy or completeness. The information contained herein is not, and should not be construed as, an offer to sell or the solicitation of an offer to buy any securities.

This information contains certain “forward-looking statements,” which may be identified by the use of such words as “believe,” “expect,” “anticipate,” “should,” “planned,” “estimated,” “potential” and other similar terms.

Examples of forward-looking statements include, but are not limited to, estimates with respect to financial condition, results of operations, and success or lack of success of the depicted investment strategy. All are subject to various factors, including, but not limited to general and local economic conditions, changing levels of competition within certain industries and markets, changes in interest rates, changes in legislation or regulation, and other economic, competitive, governmental, regulatory and technological factors affecting operations that could cause actual results to differ materially from projected results.

Targeted returns (e.g., forward-looking statements of performance up to a stated return) reflects the returns that the Company is seeking to achieve over a particular period of time. Projected returns reflect the Company's performance estimate - i.e., the returns that the Company believes can be achieved using the advertised investment services. Target returns are presented to inform clients or potential clients about the Company's risk tolerances when managing investments and to provide information useful to a client or potential client when assessing how the the Companys strategy fits within the investor's overall portfolio. Target returns are not guarantees or promises of future return.

Please refer to Gray Digital's documentation for important additional information. Certain investments are not suitable for all investors. Before investing, you should consider your investment objectives and any fees charged by Gray Digital. The rate of return on investments can vary widely over time, especially for long term investments. Investment losses are possible, including the potential loss of all amounts invested, including principal.

Contact Gray Digital at[email protected]  167 Madison Avenue, New York, NY, 10016.