“Generally, the individuals listed as the Health Catalyst Capital “Team” (including Managing Directors, Principals, Directors, Chief Compliance Officer and Chief Financial Officer) on this website are designated “access persons” pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, as amended, and are subject to Health Catalyst Capital’s Code of Ethics, which therefore allows them to be fully included in HCC’s investment reviews.  Based on a variety of factors, individuals with the titles of Fund Advisor and Senior Operating Partner are designated as “non-access persons” and are not subject to HCC’s Code of Ethics.”