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as revenue sharing payments, in connection with the investments made pursuant to our recommendation or investment management. Other Business Activities Certain senior managers and officers of AAG may also serve as executive officers of AAG's parent company,GWLA and other affiliates of AAG. Item 11—Code of Ethics,Participation or Interest in Client Transactions and Personal Trading AAG's Code of Ethics AAG has adopted a written Code of Ethics(the"Code")in compliance with Rule 204A-1 of the Investment Advisers Act of 1940 ("Advisers Act").The Code sets forth standards of business conduct expected of advisory personnel.It requires AAG's advisory personnel (referred to as "Supervised Persons") to report their personal securities holdings and transactions in accordance with the Advisers Act. AAG's Supervised Persons are required to comply with the Code.A copy of the Code will be provided to current or prospective clients upon request.The Code includes provisions related to: • Fiduciary responsibility to clients; • Compliance with federal securities laws; • Protection and safeguarding of confidential information; • Giving and receiving gifts,gratuities and entertainment; • Political contributions; • Reporting and monitoring personal securities transactions; • Avoiding and disclosing conflicts of interest;and • Reporting violations of the Code. Personal Trading The Code requires pre-clearance of certain securities transactions. Officers, managers, and certain employees of AAG (collectively, "Access Persons") may trade for their own personal accounts in securities which are recommended to and/or purchased for AAG's advisory clients. However,because the Code would permit Access Persons to invest in the same securities as clients in some circumstances,there is a possibility that employees could benefit from market activity by a client in a security held by an Access Person.As a result,trading is continually monitored in accordance with the Code and federal securities laws. The Code is intended to ensure that the personal securities transactions and the outside business activities of AAG's Access Persons do not interfere with making decisions in the best interest of advisory clients. Principal Trading AAG has adopted a policy and practice not to engage in any principal transactions. AAG holds no investments for its own accounts which could be bought from,or sold to,an advisory client. In the event of any change in AAG's policy,any such change must be approved by management.Any principal transactions would be permitted only after meeting the review andapproval requirements described under the anti-fraud section of the Advisers Act. Participation or Interest in Client Transactions Affiliate GWFS Effects Securities Transactions for Advisory Clients Registered representatives of GWFS may provide wholesaling, direct sales, enrollment, and/or communication services to retirement plans and their participants for which AAG may also provide its services. In return, GWFS may receive fees from either the plan or the investment provider(fund families).All securities transactions which occur as a result of AAG's services, as described in this Brochure, are executed by GWFS. GWFS may receive compensation in the form of 12b-1 fees or other compensation from mutual fund companies or from the other investments that may be available as plan or IRA investment options. In all instances, AAG's affiliation with these entities is disclosed. Allocations in the investment options are solely determined and based on Morningstar Investment Management's software and not determinations made by AAG. The compensation paid by AAG to Morningstar Investment Management for Morningstar Investment Management's proprietary software advice program does not vary based on the allocations made or recommended by Morningstar Investment Management. Because Morningstar Investment Management is unaffiliated with AAG and GWFS,AAG does not believe there is a conflict of interest. 16