A message from our CEO

Standards of conduct ....................................................

Who is subject to the Code of Ethics?.............................

Personal investing ........................................................

Gifts and entertainment................................................

.

WHICH INVESTMENT ACCOUNTS MUST BE REPORTED?

AND

WHAT ARE THE REPORTING RESPONSIBILITIES FOR ALL PERSONNEL?

WHAT ARE THE PRECLEARANCE RESPONSIBILITIES FOR ALL PERSONNEL?

Please note that preclearance approval does not alter your responsibility to ensure that each personal securities transaction complies with the general standards of conduct, the reporting requirements, the restrictions on short-term trading,or the special rules for investment professionalsset out in ourCode of Ethics.

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WHAT ARE THE ADDITIONAL REQUIREMENTS FOR INVESTMENT PROFESSIONALS?

INVESTMENT PROFESSIONAL BLACKOUT PERIODS

	14 calendar days before or after
later of	one calendar year
90 calendar days

SHORT SALES BY AN INVESTMENT PROFESSIONAL

ACCEPTING GIFTS

ACCEPTING BUSINESS MEALS

ACCEPTING ENTERTAINMENT OPPORTUNITIES

LODGING AND AIR TRAVEL

SOLICITING GIFTS, ENTERTAINMENT OPPORTUNITIES, OR CONTRIBUTIONS

SOURCING ENTERTAINMENT OPPORTUNITIES

No Preclearance or Reporting Required:

Reporting of Securities Transactions Required (no need to preclear and not subject to the 60-day holding period):

Preclearance and Reporting of Securities Transactions Required:

Prohibited Investments and Activities:

This appendix is current as of 21 September 2022 and may be amended at the discretion of the Ethics Committee.

1A list of funds advised or subadvised by Wellington Management ("Wellington-Managed Funds") is available online via the Code of Ethics System. However, you remain responsible for confirming whether any particular investment represents a Wellington-Managed Fund.

2If the instrument is unrated, it must be of equivalent duration and comparable quality.