EFTA Document EFTA01392276

GLDUS128 Patrick Gerschel iCapital Advisors, LLC Form ADV Part 2A consistent with the Code of Ethics: and Employees should not take inappropriate advantage of their position. Employees (and any accounts in which an employee has beneficial ownership) must obtain written authorization from the CCO prior to making a personal investment in other private investment vehicles. The Code of Ethics also provides that the CCO (or his designee) will monitor employee investments in equity securities