**Exhibit 14.01**

**R.J. O’BrienFund Management, Inc.**

**Code of Ethics**

# **Introduction**

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

RJOFM (‘the Company”) acts as the managingowner and/or general partner of a commodity pool (the “Pool”) that is a publicreporting 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 executiveofficer, principal financial officer, principal accounting officer and personsperforming similar functions (collectively, the “Covered Officers”) to know andfollow the policies outlined in this RJOFM Code of Ethics.  Any Covered Officer who violates the letteror spirit of these policies is subject to disciplinary action, up to andincluding termination.

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

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

# **Compliancewith Laws, Rules and Regulations**

The Covered Officers must comply fully withall applicable foreign, federal, state and local laws, rules and regulationsthat govern the Company’s or the Pool’s business conduct.  Failure to comply with such laws, rules andregulations may result in disciplinary action (in addition to those imposed byany governmental, regulatory or self-regulatory body), up to and includingtermination.

# **Conflicts of Interest**

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

A “conflict of interest” occurs when aCovered Officer’s personal interests interfere or conflict in any way (or evenappear to interfere or conflict) with the interests of the Company or, asapplicable, those of the Pool.  Aconflict of interest situation can arise when a Covered Officer takes actionsor has interests (financial or other) that may make it difficult to fulfillduties owed to the equity owners of the Pool. Conflicts of interest also may arise when a Covered Officer or a memberof a Covered Officer’s family receives improper personal benefits as a resultof the Covered Officer’s affiliation with the Company, regardless of whethersuch benefits are received from the Company or a third party.  Loans by the Company or the Pool to, orguarantees by the Company or the Pool of obligations of, Covered Officers andtheir family members are of special concern and are prohibited.

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

# **Corporate Opportunities**

The Covered Officers are prohibitedfrom:  (a) taking for themselvespersonally opportunities that properly belong to the Company and/or Pool or arediscovered through the use of corporate property, information 

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or position; (b) using corporateproperty, information or position for personal gain; and (c) competingwith the Company.  The Covered Officersowe a duty to the Company and to the Pool to advance its legitimate interests when the opportunity to do soarises.

# **Public Company Reporting**

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

A.           each Covered Officer musttake all reasonable steps to ensure that these reports and other publiccommunications represent full, fair, accurate, timely and understandabledisclosure regarding the financial and business condition of the Pool;

B.             each Covered Officer mustpromptly bring to the attention of the Board of Directors any materialinformation of which a Covered Officer may become aware that affects thedisclosures made by the Company in the public filings made on behalf of thePool or otherwise would assist the Board of Directors in fulfilling itsresponsibilities to the Pools; and

C.             each Covered Officer mustpromptly bring to the attention of the Chief Compliance Officer and the Boardof Directors any information he or she may have concerning (i) significantdeficiencies in the design or operation of internal controls that couldadversely affect the Company’s ability to record, process, summarize and reportfinancial data, including on behalf of the Pool, or (ii) any fraud,whether or not material, involving management or other employees who have asignificant role in the Company’s financial reporting, including on behalf ofthe Pool, disclosures or internal controls.

# **Reporting Illegal or UnethicalBehavior**

Each Covered Officer has a duty to adhere tothis Code of Ethics.  Each CoveredOfficer must also promptly bring to the attention of the Chief ComplianceOfficer or the CEO and to the Board of Directors any information the CoveredOfficer may have concerning evidence of a material violation of the securitiesor other laws, rules or regulations applicable to the Company or the Pool, andthe 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 apparentconflicts of interest between personal and professional relationships,involving any management or other employees who have a significant role in theCompany’s or the Pool’s financial reporting, disclosures or internalcontrols.  Confidentiality will bemaintained to the fullest extent possible.

A Covered Officer will not be penalized formaking a good-faith report of violations of this Code of Ethics or otherillegal or unethical conduct, nor will the Company tolerate retaliation of anykind against anyone who makes a good-faith report.  A Covered Officer who knowingly submits afalse report of a violation, however, will be subject to disciplinaryaction.  If you report a violation and insome way also are involved in the violation, the fact that you stepped forwardwill be considered.

If the result of an investigation indicatesthat corrective action is required, the Board of Directors will decide, ordesignate appropriate persons to decide, what actions to take, including, whenappropriate, legal proceedings and disciplinary action up to and includingtermination, to rectify the problem and avoid the likelihood of itsrecurrence.  Such actions shall bereasonably designed to deter wrongdoing and to promote accountability foradherence to this Code of Ethics, and shall include written notices to theindividual indicating any action taken. In determining what action is appropriate in a particular case, theBoard of Directors or its designee shall take into account all relevantinformation, including the nature and severity of the violation, whether theviolation was a single occurrence or repeated occurrences, whether theviolation appears to have been intentional or inadvertent, whether theindividual in question had been advised prior to the violation as to the propercourse of action and whether the individual in question had committed otherviolations in the past.

# **Amendment, Modification and Waiver**

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

# **Acknowledgment**

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

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