Code of Ethics

Effective Date: May 15, 2023

INTRODUCTION

This Code of Ethics ("Code") applies to all directors, officers, employees, and contractors (collectively referred to as "Employees") of Gray Digital, which includes the Gray Fund and the Gray Trading Service (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.