EFTA Document EFTA01374130

AGP LP 519 Alpha Group Capital Paul Barren Item 11. Code of Ethics, Participation or Interest In Client Transactions and Personal Trading Employees of Alkeon and their immediate family members may, from time to time, make investments for their own accounts that differ from the investments that Alkeon makes for its clients. These individuals may also have a pre-existing interest or position in securities Alkeon also invests in for its clients. The investment objectives of Alkeon employees