**Exhibit 14.01**

**CIS Investments, Inc.**

**Code of Ethics**

# **Introduction**

Cargill, Incorporated has adopted the “CargillGuiding Principles” to provide Cargill employees a framework in which toexamine problems arising out of Cargill’s global business and to assist Cargillemployees to act in a fair, ethical and lawful manner.  CIS Investments, Inc. (the “Company”) is anindirect subsidiary of Cargill, Incorporated and is subject to the CargillGuiding Principles.   In addition, theCompany has adopted this Code of Ethics to address certain specific issuesrelating to its business.

The Company acts as the managing owner and/orgeneral partner of several commodity pools (the “Pools”) that are publicreporting issuers 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 Pools.

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 the Cargill Guiding Principles as well as thisCode of Ethics.  Any Covered Officer whoviolates the letter or spirit of these policies is subject to disciplinaryaction, up to and including 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 arise frequently in connection with the operation of the Pools and to themechanisms available to report illegal or unethical conduct.  It is not, however, a comprehensive documentthat addresses every legal or ethical issue that you may confront, nor is it asummary of all laws and policies that apply to the business activities of theCompany or the Pools.  For additionalinformation regarding the Company policies, you should refer to the Company’sChief Compliance Officer.  Ultimately, nocode of ethics can replace the thoughtful behavior of an ethical 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 Company’s Chief Compliance Officer or a member of the Board ofDirectors at (312) 460-4027.   No one atthe Company has the authority to make exceptions to these policies, other thanthe Company’s Board of Directors (or a committee thereof).

# **Compliance with 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 including termination.

# **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 Pools.  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 Pools.  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 Pools. 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 Pools to, orguarantees by the Company or the Pools 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)460-4027.

----

 

# **Corporate Opportunities**

The Covered Officers are prohibitedfrom:  (a) taking for themselvespersonally opportunities that properly belong to the Company or are discoveredthrough the use of corporate property, information or position; (b) usingcorporate property, information or position for personal gain; and(c) competing with the Company.  TheCovered Officers owe a duty to the Company to advance its legitimate interestswhen the opportunity to do so arises.

# **Public Company Reporting**

As a result of the Pools’ status as “publicreporting companies,” the Company is required, on behalf of the Pools, to fileperiodic and other reports with the Securities and Exchange Commission.  The Company takes its obligations withrespect to the Pools’ 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 Pools;

B.             each Covered Officer mustpromptly bring to the attention of the Board of Directors any material informationof which a Covered Officer may become aware that affects the disclosures madeby the Company in the public filings made on behalf of the Pools or otherwisewould assist the Board of Directors in fulfilling its responsibilities to thePools; and

C.             each Cover 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 could adverselyaffect the Company’s ability to record, process, summarize and report financialdata, including on behalf of the Pools, or (ii) any fraud, whether or notmaterial, involving management or other employees who have a significant rolein the Company’s financial reporting, including on behalf of the Pools,disclosures or internal controls.

# **Reporting Illegal or Unethical Behavior**

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 Pools, 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 Pools’ 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, modifiedor waived 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 Pools thatare public reporting companies 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.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

----