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(TPYP) Tortoise North American Pipeline Fund
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(TPAY) Ecofin Digital Payments Infrastructure Fund

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Code of Ethics

TIS Advisors provides research-driven indices that can be used as a realistic basis for exchange-traded products and thought leadership in the universe of essential assets. Its indices are intended to fill a void in the market and provide benchmarks and investable asset class universes for use by investment professionals, research analysts and industry executives to analyze relative performance as well as to provide a basis for passively managed exchange-traded products. For additional information, please call 844-TR-INDEX (844-874-6339) or email info@tortoiseecofin.com.

Before investing in the funds, investors should consider their investment goals, time horizons and risk tolerance. The funds’ investment objective, risks, charges and expenses must be considered carefully before investing. The statutory prospectuses and the summary prospectuses (click here) contain this and other important information about the funds. Copies of the funds’ prospectus may be obtained by calling 844-TR-INDEX. Read it carefully before investing.

Shares of exchange-traded funds (ETFs) are not individually redeemable and owners of the shares may acquire those shares from the ETF and tender those shares for redemption to the ETF in Creation Units only, see the ETF prospectus for additional information regarding Creation Units. Investors may purchase or sell ETF shares throughout the day through any brokerage account, which will result in typical brokerage commissions.

Investing involves risk. Principal loss is possible. TPYP and EBLU are non-diversified, meaning they may concentrate their assets in fewer individual holdings than a diversified fund. Therefore, the funds are more exposed to individual stock volatility than a diversified fund. Investing in specific sectors such as energy pipelines may involve greater risk and volatility than less concentrated investments. The ETF funds (TPYP, EBLU, TPAY) are not actively managed and therefore the funds generally will not sell a security due to current or projected underperformance of a security, industry or sector, unless that security is removed from the index or the selling of the security is otherwise required upon a rebalancing of the index. There is no guarantee that the fund will achieve a high degree of correlation to the index and therefore achieve its investment objective. Shares may trade at prices different than net asset value per share.

TPYP:
Risks include, but are not limited to, risks associated with companies owning and/or operating energy pipelines, as well as master limited partnerships (MLPs), MLP affiliates, capital markets, terrorism, natural disasters, climate change, operating, regulatory, environmental, supply and demand, and price volatility risks. The tax benefits received by an investor investing in the fund differ from that of a direct investment in an MLP by an investor. The value of the fund’s investment in an MLP will depend largely on the MLP’s treatment as a partnership for U.S. federal income tax purposes. If the MLP is deemed to be a corporation then its income would be subject to federal taxation, reducing the amount of cash available for distribution to the fund which could result in a reduction of the fund’s value. Investments in non-U.S. companies (including Canadian issuers) involve risk not ordinarily associated with investments in securities and instruments of U.S. issuers, including risks related to political, social and economic developments abroad, differences between U.S. and foreign regulatory and accounting requirements, tax risk and market practices, as well as fluctuations in foreign currencies. The fund invests in small and midcap companies, which involve additional risks such as limited liquidity and greater volatility than larger companies.

EBLU:
Investment in the water infrastructure and management industry may significantly affect the value of the shares of the fund. Companies in the water industry are subject to environmental considerations, taxes, government regulation, price and supply fluctuations, competition and water conservation influences. Investments in non-U.S. companies (including Canadian issuers) involve risk not ordinarily associated with investments in securities and instruments of U.S. issuers, including risks related to political, social and economic developments abroad, differences between U.S. and foreign regulatory and accounting requirements, tax risk and market practices, as well as fluctuations in foreign currencies. The fund invests in small and mid-cap companies, which involve additional risks such as limited liquidity and greater volatility than larger companies. The fund has elected to be, and intends to qualify each year for treatment as, a regulated investment company (RIC). To maintain the fund’s qualification for federal income tax treatment as a RIC, the fund must meet certain source-of-income, asset diversification and annual distribution requirements. If for any taxable year the fund fails to qualify for the special federal income tax treatment afforded to RICs, all of the fund’s taxable income will be subject to federal income tax at regular corporate rates (without any deduction for distributions to its shareholders) and its income available for distribution will be reduced. Derivatives involve risks different from, and in certain cases, greater than the risks presented by more traditional investments.

TPAY:
Risks include, but are not limited to, risks associated with investing in digital payments industry including major changes in technology, security considerations, taxes, government regulations, economic conditions, competition, political influences, the cyclical nature of the industry, and consumer preferences. Investments in non-U.S. companies (including Canadian issuers) involve risk not ordinarily associated with investments in securities and instruments of U.S. issuers, including risks related to political, social and economic developments abroad, differences between U.S. and foreign regulatory and accounting requirements, tax risk and market practices, as well as fluctuations in foreign currencies. The fund invests in small and mid-cap companies, which involve additional risks such as limited liquidity and greater volatility than larger companies.

The Tortoise Water Index^® is a float-adjusted, modified market capitalization-weighted index comprised of companies that are materially engaged in the water infrastructure or water management industries. The Ecofin Global Water ESG Index^SM is a proprietary, rules-based, modified capitalization-weighted, float-adjusted index comprised of companies that are materially engaged in the water infrastructure or water management industries. The Tortoise North American Pipeline Index^SM is a float-adjusted, capitalization-weighted index of pipeline companies headquartered in the U.S. and Canada. A pipeline company is defined as a company that either 1) has been assigned a standard industrial classification (SIC) system code that indicates the company operates in the energy pipeline industry or 2) has at least 50% of its assets, cash flow or revenue associated with the operation or ownership of energy pipelines. The Ecofin Global Digital Payments Infrastructure Index^SM is a proprietary, rules-based, modified market capitalization-weighted, float-adjusted index comprised of companies that are materially engaged in digital payments, including merchant processing and settlement, real time record keeping, settlement networks, and fintech products/services that facilitate the ease, efficiency and speed of electronic transactions. This includes companies whose primary business is comprised of one or a combination of the following categories: credit card networks, electronic transaction processing and associated products/services, credit card issuers, electronic transaction processing software (payments fintech) or online financial services market places.

The Tortoise North American Pipeline Index^SM, Tortoise Water Index^® and the Ecofin Global Water ESG Index^SM (the "Indices") are the exclusive property of TIS Advisors, which has contracted with S&P Opco, LLC (a subsidiary of S&P Dow Jones Indices LLC) to calculate and maintain the Indices. The Indices are not sponsored by S&P Dow Jones Indices or its affiliates or its third party licensors (collectively, "S&P Dow Jones Indices"). S&P Dow Jones Indices will not be liable for any errors or omission in calculating the Indices. "Calculated by S&P Dow Jones Indices" and its related stylized mark(s) are service marks of S&P Dow Jones Indices and have been licensed for use by TIS Advisors and its affiliates. S&P^® is a registered trademark of Standard & Poor's Financial Services LLC ("SPFS"), and Dow Jones^® is a registered trademark of Dow Jones Trademark Holdings LLC ("Dow Jones"). The Ecofin Global Digital Payments Infrastructure Index^SM (the “Index”) is the exclusive property of TIS Advisors. The Index is calculated by Solactive AG (“Solactive”). The financial instruments that are based on the Index are not sponsored, endorsed, promoted or sold by Solactive in any way, and Solactive makes no express or implied representation, guarantee or assurance with regard to: (a) the advisability in investing in the financial instruments; (b) the quality, accuracy and/or completeness of the Indices or the calculations thereof; and/or (c) the results obtained or to be obtained by any person or entity from the use of the Index. No portion of this publication may be reproduced in any format or by any means including electronically or mechanically, by photocopying, or by any other form or manner whatsoever, without the prior written consent of TIS Advisors. It is not possible to invest directly in an index.

Diversification does not assure a profit or protect against a loss in a declining market.

Nothing on this website should be considered a solicitation to buy or an offer to sell any shares of the portfolio in any jurisdiction where the offer or solicitation would be unlawful under the securities laws of such jurisdiction. Nothing contained in this communication constitutes tax, legal or investment advice. Investors must consult their tax advisor or legal counsel for advice and information concerning their particular situation.

TIS Advisors is the advisor to the Tortoise North American Pipeline Fund, Ecofin Global Water ESG Fund and the Ecofin Digital Payments Infrastructure Fund. Vident Investment Advisory, LLC serves as sub-adviser to the Tortoise North American Pipeline Fund, Ecofin Global Water ESG Fund and the Ecofin Digital Payments Infrastructure Fund.

Quasar Distributors, LLC, distributor

NOT FDIC INSURED · NO BANK GUARANTEE · MAY LOSE VALUE

Mutual Fund Industry & ETF Award Methodology

The shortlists and winners are comprised of individuals and firms who submit entries or are nominated via the online submission process, as well as through recommendations from leading market participants. Judges use the submitted application material, as well as any uploaded supplemental information, to determine which firm, individual or product they believe to be the most suitable and deserving winners for each category. Judges have the discretionary power to move nominations into alternative categories that they think may be more suitable.

The asset manager sales, marketing and leadership awards and the fund director awards are adjudicated by a panel of industry experts convened by the Fund Intelligence and Fund Directions editorial teams. The industry judges, who must declare any conflict, contribute their sector expertise to assess the shortlist of candidates and come to a decision on the winners. A separate panel of industry experts judge the ETF categories. Additional information may be obtained at https://www.mutualfundindustryawards.com/home

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