Exhibit
14.01




R.J.
O’Brien Fund Management, LLC.




Code
of Ethics




Introduction




R.J.
O’Brien Fund Management, LLC (“RJOFM”) adopted ethical guidelines to provide
RJOFM employees a framework in which to examine problems arising out of its
business and to assist RJOFM employees to act in a fair, ethical and lawful
manner.   In addition, RJOFM has adopted this Code of Ethics to
address certain specific issues relating to its business.




RJOFM (
the “Company”) acts as the managing owner and/or general partner of a commodity
pool (the “Pool”) that is a public reporting issuer under the Securities
Exchange Act of 1934, as amended.  As the managing owner and/or
general partner, the Company is responsible for the management and
administration of the Pool.




The
Company expects its principal executive officer, principal financial officer,
principal accounting officer and persons performing similar functions
(collectively, the “Covered Officers”) to know and follow the policies outlined
in this RJOFM Code of Ethics.  Any Covered Officer who violates the
letter or spirit of these policies is subject to disciplinary action, up to and
including termination.




Every
Covered Officer has the responsibility to obey the law and act honestly and
ethically.  To that end, this Code of Ethics is a guide that is
intended to make Covered Officers sensitive to some of the significant legal and
ethical issues that  may arise in connection with the operation of the
Pool and to the mechanisms available to report illegal or unethical
conduct.  It is not, however, a comprehensive document that addresses
every legal or ethical issue that you may confront, nor is it a summary of all
laws and policies that apply to the business activities of the Company or the
Pool.  For additional information regarding the Company policies, you
should refer to R.J. O’Brien & Associates, Inc.’s  Chief
Compliance Officer.  Ultimately, no code of ethics can replace the
thoughtful behavior of an ethical officer.




If you
have any questions about this Code of Ethics or are concerned about conduct you
believe violates this Code of Ethics, the Company’s policies or applicable laws,
rules or regulations, you should consult with the R.J. O’Brien & Associates’
Chief Compliance Officer, Steve S. Andrews at (312)
373-5000.   No one at the Company has the authority to make
exceptions to these policies, other than the Company’s Board of Directors (or a
committee thereof).




Compliance
with Laws, Rules and Regulations




The
Covered Officers must comply fully with all applicable foreign, federal, state
and local laws, rules and regulations that govern the Company’s or the Pool’s
business conduct.  Failure to comply with such laws, rules and
regulations may result in disciplinary action (in addition to those imposed by
any governmental, regulatory or self-regulatory body), up to and including
termination.




Conflicts
of Interest




Business
decisions must be made in the best interest of the Company, not motivated by
personal interest or gain.  The same principle applies to business
decisions made by the Company in respect of the investors in the
Pool.  Therefore, as a matter of Company policy, all Covered Officers
must avoid any actual or perceived conflict of interest.




A
“conflict of interest” occurs when a Covered Officer’s personal interests
interfere or conflict in any way (or even appear to interfere or conflict) with
the interests of the Company or, as applicable, those of the Pool.  A
conflict of interest situation can arise when a Covered Officer takes actions or
has interests (financial or other) that may make it difficult to fulfill duties
owed to the equity owners of the Pool.  Conflicts of interest also may
arise when a Covered Officer or a member of a Covered Officer’s family receives
improper personal benefits as a result of the Covered Officer’s affiliation with
the Company, regardless of whether such benefits are received from the Company
or a third party.  Loans by the Company or the Pool to, or guarantees
by the Company or the Pool of obligations of, Covered Officers and their family
members are of special concern and are prohibited.




It is
difficult to identify exhaustively what constitutes a conflict of
interest.  For this reason, the Covered Officers must avoid any
situation in which their independent business judgment might appear to be
compromised.  Questions about potential conflicts of interest
situations, and disclosure of these situations as they arise, should be promptly
addressed and reported to the Chief Compliance Officer at (312)
373-5000.




Corporate
Opportunities




The
Covered Officers are prohibited from:  (a) taking for themselves
personally opportunities that properly belong to the Company and/or Pool or are
discovered through the use of corporate property, information or
position; (b) using corporate property, information or position for
personal gain; and (c) competing with the Company.  The Covered
Officers owe a duty to the Company and to the Pool  to advance its
legitimate interests when the opportunity to do so arises.









Public
Company Reporting




As a
result of the Pool’s status as “public reporting company,” the Company is
required, on behalf of the Pool, to file periodic and other reports with the
Securities and Exchange Commission.  The Company takes its obligations
with respect to the Pool’s public disclosure seriously.  To that
end:




A.
            each
      Covered Officer must take all reasonable steps to ensure that these
      reports and other public communications represent full, fair, accurate,
      timely and understandable disclosure regarding the financial and business
      condition of the Pool;




B.
            each
      Covered Officer must promptly bring to the attention of the Board of
      Directors any material information of which a Covered Officer may become
      aware that affects the disclosures made by the Company in the public
      filings made on behalf of the Pool or otherwise would assist the Board of
      Directors in fulfilling its responsibilities to the Pools;
    and




C.
            each
      Covered Officer must promptly bring to the attention of the Chief
      Compliance Officer and the Board of Directors any information he or she
      may have concerning (i) significant deficiencies in the design or
      operation of internal controls that could adversely affect the Company’s
      ability to record, process, summarize and report financial data, including
      on behalf of the Pool, or (ii) any fraud, whether or not material,
      involving management or other employees who have a significant role in the
      Company’s financial reporting, including on behalf of the Pool,
      disclosures or internal controls.




Reporting
Illegal or Unethical Behavior




Each
Covered Officer has a duty to adhere to this Code of Ethics.  Each
Covered Officer must also promptly bring to the attention of the Chief
Compliance Officer or the CEO and to the Board of Directors any information the
Covered Officer may have concerning evidence of a material violation of the
securities or other laws, rules or regulations applicable to the Company or the
Pool, and the operation of its or their businesses, by the Company or any agent
thereof, or of a violation of this Code of Ethics, including any actual or
apparent conflicts of interest between personal and professional relationships,
involving any management or other employees who have a significant role in the
Company’s or the Pool’s financial reporting, disclosures or internal
controls.  Confidentiality will be maintained to the fullest extent
possible.




A Covered
Officer will not be penalized for making a good-faith report of violations of
this Code of Ethics or other illegal or unethical conduct, nor will the Company
tolerate retaliation of any kind against anyone who makes a good-faith
report.  A Covered Officer who knowingly submits a false report of a
violation, however, will be subject to disciplinary action.  If you
report a violation and in some way also are involved in the violation, the fact
that you stepped forward will be considered.




If the
result of an investigation indicates that corrective action is required, the
Board of Directors will decide, or designate appropriate persons to decide, what
actions to take, including, when appropriate, legal proceedings and disciplinary
action up to and including termination, to rectify the problem and avoid the
likelihood of its recurrence.  Such actions shall be reasonably
designed to deter wrongdoing and to promote accountability for adherence to this
Code of Ethics, and shall include written notices to the individual indicating
any action taken.  In determining what action is appropriate in a
particular case, the Board of Directors or its designee shall take into account
all relevant information, including the nature and severity of the violation,
whether the violation was a single occurrence or repeated occurrences, whether
the violation appears to have been intentional or inadvertent, whether the
individual in question had been advised prior to the violation as to the proper
course of action and whether the individual in question had committed other
violations in the past.




Amendment,
Modification and Waiver




This Code
of Ethics may be amended, modified or waived by the Board of Directors of the
Company.  Any change to, or waiver (whether explicit or implicit) of,
this Code of Ethics must be disclosed promptly to the Pool that is a public
reporting company by filing a Form 8-K on behalf of each affected Pool or by
another permitted means.




Acknowledgment




Each
Covered Officer is accountable for knowing and abiding by the policies contained
in this Code of Ethics.  The Company may require that the Covered
Officers sign an acknowledgment confirming that they have received, read and
understand this Code of Ethics and are complying with them.