RCM Code of Ethics (1)

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January 8, 2024

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Introduction-Rockefeller Capital Management Code of Ethics3

Commitment to Integrity4

The Code of Ethics Applies to All of Us5

Supervised Persons6

RCM Policies and Procedures6

Code Violations6

About Rockefeller Capital Management7

Acting with Integrity8

Avoiding Conflicts of Interest9

Gifts & Entertainment11

Outside Business Activities11

Personal Account Trading12

Political Contributions14

Charitable Contributions14

Certifications of Compliance15

Firm-Required Training15

Prohibited Practices Related to Approved, Completed, or Signed Documentation16

Work-Related Conduct17

Compliance with the Law18

Cooperation with Regulators19

Required Disclosures19

Obeying the Law and Reporting Code Violations20

Raising Concerns20

Anti-Bribery and Anti-Corruption21

Anti-Money Laundering/Sanctions21

Anti-Tax Evasion22

Maintaining Accurate Books and Records22

Business-Related Electronic Communications23

Safeguarding Information24

Protection of Client, Proprietary, and Other Confidential Information25

Material Non-Public Information and Insider Trading25

Cybersecurity, Privacy, and Data Protection26

Thank You27

Code of Ethics Resources28

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Around the world, the Rockefeller name embodies

a unique reputation to be treasured and protected.

At all times, we are committed to conducting our business

with uncompromising integrity to the

highest standards. To strengthen and deepen that

At all times, we are committed to

conducting our business

with uncompromising integrity to

the highest standards.

commitment, we must each assume responsibility for

our actions.

The Rockefeller Capital Management Code of

Ethics (“Code”) represents our individual and collective

obligation to preserve and protect the Firm’s principles,

shaped by over 140 years working alongside members of

the Rockefeller family. This

requires that we each do our part, even when not

expedient or easy to do so.

We recommend you use this Code as a resource and

compass to guide your decision-making and actions.

If you have questions about the Code of Ethics or any

related policy, seek guidance from your manager,

the Legal and Compliance

Department, or other contact referenced in this Code.

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This Code of Ethics is rooted in Rockefeller Capital

Management’s (“RCM,” “Rockefeller,” or “Firm”) core

value of Commitment to Integrity. While we strictly adhere

to the principle “Do the right thing,” our Commitment to

Integrity signifies Rockefeller’s unwavering dedication to

upholding an ethical culture.

Neither Rockefeller’s Code nor its policies can anticipate or

address every possible issue or situation that may arise, and

the proper course of action may not always be clear.

When something doesn’t feel right or there is any uncertainty

as to the appropriate decision or course of action, asking yourself

questions through the lens of the Firm’s values and standards can

help you decide how to proceed.

When in doubt about a

compliance obligation,

the propriety of a course of action,

or interpretation of this Code, seek

guidance from the

Legal and Compliance Department

before moving forward.

Decision

Making

Lens

Does my decision or action:

•Align with RCM’s Code of Ethics

and core values?

•Comply with Firm policy?

•Adhere to the letter and spirit of

applicable laws, rules, and regulations?

Could my decision or action:

•Be perceived by others or the public as

inappropriate, dishonest, or unethical?

•Harm clients, colleagues, or the public?

•Damage Rockefeller’s reputation?

•Expose Rockefeller to legal or regulatory risk?

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This Code outlines the standards of ethical conduct we

expect from ourselves and each other. Rockefeller has

adopted this Code to affirm the values and principles that guide

the business conduct of the Firm and its Supervised Persons.

Supervised Persons include any:

•Partner, officer, director (or other person occupying a

similar status or performing similar functions);

•Employee, contingent worker, and intern of Rockefeller

and its subsidiaries;

•Other person who provides investment advice on behalf of

Rockefeller; or

•Other person subject to Rockefeller’s supervision and control

who the Legal & Compliance Department determines is

subject to the Code.

Compliance with the Code is a term and condition of each

Supervised Person’s employment. While you are not expected

to know the details of every law governing the Firm’s

business, you are expected to be familiar with and adhere to the

Firm’s Code of Ethics and policies and

procedures applicable to RCM, your business line, and job

There is zero tolerance for unethical behavior at

Rockefeller, and ignorance of the Code or Firm

policy is no excuse for violating it.

responsibilities.

The Code provides an overview of expected conduct in a

number of key areas, but it does not constitute a

comprehensive set of requirements. Rather, many of the

principles and standards stated in the Code are detailed in

separate Firm policies and procedures.

Therefore, RCM’s Code of Ethics must be read along with

other applicable Compliance policies, which can be found

on RCM’s Policies & Procedures Portal.

RESOURCES AND CONTACTS

•RCM Policies and Procedures Portal

Noncompliance with Rockefeller’s Code of Ethics can put our

clients and

colleagues at risk,

result in significant

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legal and regulatory exposure for the Firm,

and subject Rockefeller’s legacy to serious reputational

harm.

Regardless of business line, position, or seniority, all

Supervised Persons must comply with the laws and

regulations governing our businesses, adhere to Firm

policies and procedures, and maintain the highest

ethical standards in all we do.

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Rockefeller Capital Management LP is the holding company of

various operating subsidiaries, including (i) Rockefeller Financial

LLC, (ii) Rockefeller & Co. LLC, (iii) Rockefeller Trust Company, N.A.,

and (iv) The Rockefeller Trust Company (Delaware)

(collectively, Rockefeller” or the “Firm”).

Rockefeller Financial LLC is dually registered with the U.S.

Securities & Exchange Commission (“SEC”) as an investment

adviser and broker-dealer.

Rockefeller & Co. LLC is registered with the SEC as an investment

adviser.

Rockefeller Trust Company, N.A. is a national trust bank

regulated by the Office of the Comptroller of the Currency, and The

Rockefeller Trust Company (Delaware) is a limited purpose trust

company regulated by the Office of the State Bank

Commissioner of the State of Delaware.

This Code requires the Firm and its Supervised Persons to comply with the

federal securities laws, and it fulfills the Firm’s obligations to its clients

under the Investment Advisers Act of 1940, as amended (the “Advisers

Act”) and Rule 17j-1 under the Investment

Company Act of 1940, as amended (the “Investment Company Act”)

with respect to registered investment companies advised by Rockefeller

& Co. LLC. The Code is intended to reflect the fiduciary principles that

govern the conduct of the Firm and its Supervised

Persons in those situations where the Firm acts as an investment advisor

as defined under the Advisers Act and is providing

investment advice to its clients.

For Rockefeller Asset Management Supervised Persons,

Rule 206(4)-8 under Section 206 generally prohibits an

investment adviser from making false or misleading statements,

omitting material facts, or engaging in

fraudulent, deceptive or manipulative conduct with respect

to investors and prospective investors in investment funds

advised by the investment adviser; and Rule17j-1 prohibits

any affiliate of a fund or its

investment adviser or principal underwriter from engaging in

fraudulent conduct in connection with the purchase or sale of

securities held or to be acquired by the fund. It is unlawful for

any investment adviser, directly or indirectly:

(i) to employ a device, scheme, or artifice to defraud any client

or prospective client; (ii) to engage in any transaction, practice

or course of business which operates as a fraud or deceit upon

any client or prospective client; (iii) acting as a principal for his

own account, knowingly to sell any security to or purchase any

security from a client, or acting as a broker for a person other

than a client, knowingly to effect any sale or purchase of any

security for the account of such client; or (iv) to engage in any

act, practice, or course of business which is fraudulent,

deceptive, or manipulative.

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A conflict may arise when the interest of the Firm, an

CONFLICT OF INTEREST DECISION GUIDE

As you consider a business decision or action, ask yourself:

Are there competing interests, influences, or

incentives at hand?

Does the relationship or arrangement present a

conflict of interest now or in the foreseeable future?

Do the Firm’s or employee’s interests conflict

with the client’s interests?

Does the action being considered provide an

unfair or unbalanced outcome for the client,

Rockefeller, or the employee?

Does the action being considered unfairly benefit

one client over another client?

Is there an appearance of a conflict of interest

and, if so, what is the potential risk impact to the

client, employee, or Rockefeller?

Employee or a Client are in actual or perceived opposition.

Conflicts pose risks that decisions or actions may be

improperly influenced by personal or other motivations

that have the potential to harm clients, colleagues, and/or

the Firm.

To ensure Rockefeller maintains its reputation and

commitment to the highest ethical standards, the Firm

has established a Conflicts of Interest Policy that requires

Rockefeller, its various business units, and Supervised persons

to:

•Identify and manage conflicts through an

established conflicts framework;

•Be vigilant about whether activities or

relationships could create an actual or potential

conflict of interest, or even the appearance of a

conflict, and avoid those activities or

relationships; and

•Adhere to the Conflicts of Interest Policy to

eliminate and/or mitigate any conflicts.

Where a conflict cannot be avoided, it must be disclosed so the

Firm can review and manage the conflict in an appropriate

manner.

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CONFLICT MANAGEMENT GUIDING PRINCIPLES

Many conflicts can be effectively managed, mitigated, or

avoided by following these guiding principles:

Be cognizant of situations that could create an

actual, potential, or perceived conflict.

Always put the best interest of the customer ahead of

your own.

If there is a conflict, disclose it.

Follow Rockefeller policies and procedures

designed to mitigate conflicts of interest.

Escalate potential conflicts.

RAM EMPLOYEES

There are potential conflicts that may arise as a

consequence of the business and other relationships of

RAM’s Supervised Persons’ immediate family and other

close, personal relationships.

RAM requires Supervised Persons to complete a

questionnaire to disclose certain family and close,

personal relationships that may give rise to actual or

potential material conflicts of interest and will seek to

identify and address any actual or potential material

conflicts of interest arising from these relationships.

•RCM Conflicts of Interest Policy

•RCM Policy on Customer Complaints

•RCM Gifts and Entertainment Policy

•RCM Outside Business Activities (OBA) Policy

•RCM Information Barriers Policy

•RCM Personal Account Trading Policy

•RFLLC Policies & Written Supervisory Procedures (WSP)

•RTCDE Policies and Procedures Manual

•RTCNA Policies and Procedures Manual

RESOURCES AND CONTACTS

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While the giving or receiving of gifts and entertainment has

become a common industry practice, it is especially important

that our actions remain consistent with

Rockefeller’s high ethical standards and commitment to

effective conflict of interest management.

The Gifts & Entertainment Policy provides guidance on gift

and entertainment limits and books and records

requirements, which may vary depending upon the

business line you work for. It also addresses

non-cash compensation requirements.

The Gifts & Entertainment policy prohibits the receipt of

cash/cash equivalents, gifts in connection with an ERISA

plan, and gifts or entertainment in connection with any

government or foreign official.

Our obligation to Rockefeller’s clients and each other to use good

judgment and maintain high ethical standards in all we do

extends to participation in any business activity outside the

scope of our relationship with Rockefeller. Examples

Include, but are not limited to, serving as a trustee, officer, or

board member to a non-profit organization, full or partial

ownership in a private operating business, and serving on the board

of a condo association.

The Outside Business Activities Policy (“OBA Policy”) requires all

OBAs must be disclosed and submitted for approval.

Supervised Persons are prohibited from engaging in an OBA prior

to obtaining the required approvals.

“Integrity is doing the right thing even when no one is looking.”~ C.S. Lewis

•RCM Gifts and Entertainment Policy

(Appendix includes a Summary of Gift & Entertainment

Requirements)

•RCM Code of Ethics FAQs

•MyApps / Protegent PTA (ECM) Dashboard)

•Email the Code of Ethics (COE) Compliance Team

RESOURCES AND CONTACTS

•RCM Outside Business Activities (“OBA) Compliance Policy

•RCM Conflicts of Interest Policy

•RCM Information Barriers Policy

•RCM Personal Account Trading Policy

•MyApps / Protegent PTA (ECM) Dashboard)

•Email the Code of Ethics (COE) Compliance Team

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Rockefeller recognizes the importance to Supervised Persons of

being able to manage and develop their own

and their dependents’ financial resources through long-term

investments and strategies. At the same time, when

conducting personal account trading, Supervised Persons must

always place the interests of RCM clients first, avoid actual,

potential, or perceived conflicts of interest, and comply with all

applicable laws and regulations.

KEY REQUIREMENTS INCLUDE:

Rockefeller is subject to various laws and/or regulations governing

the personal trading of securities that, if not adhered to, subject the

Firm to legal, regulatory, and

reputation risk. Rockefeller has established requirements

and limitations on personal account trading to minimize

potential conflicts of interest and ensure regulatory

compliance. These requirements and limits may vary

depending on the business line you work for and position within the

Firm.

•All employees are required to maintain their personal accounts at an approved broker; Managing Directors and/or

Private Advisors are required to maintain their personal accounts at RCM.

•Employees are prohibited from transacting in securities on the Firm’s Restricted List, including any derivative of such security (see

exemptions below) or any other related security. Employees are required to consult the Restricted List prior to placing any personal

trades.

•The following employees must preclear all transactions in all Personal Accounts, except for transactions in Exempt

Instruments and transactions in Managed Accounts with third-party discretionary authority:

>The President and CEO of RCM,

(including his direct reports),

>RAM,

>Corporate Finance,

>Legal & Compliance,

>Risk,

>Strategic Advisory, and

>Any other Covered Person (as defined in the Personal Account Trading Policy)

designated by senior management of the Firm because of their access to

information.

•With the exception of Private Securities purchased or sold in an RCM account, all RCM Employees and their immediate family

members are required to preclear all Private Securities Transactions (hedge funds, private equity funds, direct private equity

investments, etc.) via the Private Securities Transaction (PST) Form in Protegent PTA (ECM). Private Securities purchased or sold

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in an RCM account do not require a PST Form (unless the employee is member of the Investment Solutions Group). Compliance

performs pre-trade reviews of on-platform PSTs via the AI order system.

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PRIVATE ADVISORS AND MANAGING DIRECTORS

Supervised Persons who are Private Advisors or Managing

Directors are required to transfer their Personal Accounts

to RCM within 30 calendar days of commencing employment at

•RCM Personal Account Trading Policy (See

Exhibit A for list of approved brokers)

•Personal Account Trading Policy FAQs

•RCM Code of Ethics FAQs

•RCM Restricted List

•MyApps / Protegent PTA (ECM) Dashboard)

•Email the Code of Ethics (COE) Compliance Team

RESOURCES AND CONTACTS

RCM or change in status. Any exception request must be

submitted through Protegent PTA (ECM) and approved by the

RCM employee’s supervisor and/or line manager and RCM’s Chief

Operating Officer.

PRIVATE ADVISORS AND TEAM MEMBERS

Supervised Persons who are a Private Advisor or a team member

of a Private Advisor that has or obtains a client who is a publicly

traded company or an officer, director, or beneficial owner of

more than 10% of the voting shares of a public company must:

•Disclose and document in writing, the details of the

insider account, to a member of their Divisional

Management Team

•Work with their Divisional Management Team to notate

the relationship to the public company on applicable

Wealthscape account (suitability) profile screens

•Request and obtain pre-approval through Protegent PTA

(ECM) prior to effecting any personal transactions in the

securities of that company, and

•Effect personal transactions in the securities of the

company only within the pre-defined quarterly personal

trading window.

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There has been an increase in restrictions on political

activity by companies and their employees, and sometimes those

employees’ immediate family members, who conduct business

with government entities. Violations, even if

unintentional, can have a significant negative impact on the

Firm.

Supervised Persons must request prior review and receive

written approval from Compliance before making, soliciting,

or coordinating any political contribution. Immediate family

members of certain Supervised Persons are also prohibited from

making, soliciting, or coordinating any political

contribution in certain jurisdictions, as outlined in the Political

Contributions Policy. RCM Management Committee members are

prohibited from making, Soliciting, or

Coordinating any political contributions.

RESOURCES AND CONTACTS

Rockefeller is committed to supporting our communities.

However, (501(c)(3) charitable contributions must not be

made by any Supervised Person with the intention of

influencing such charity to become an RCM client or vendor,

or in exchange for business or services of any kind.

Supervised Persons are prohibited from soliciting charitable

contributions from clients, prospects, or vendors, and are

required to obtain pre-approval from their business line manager for

•RCM Charitable Contributions Policy

•MyApps / Protegent PTA (ECM) Dashboard)

•Email the Code of Ethics (COE) Compliance Team

RESOURCES AND CONTACTS

business-related charitable contributions, including sponsorship of

charitable events.

Violations, even if unintentional, can

have a significant

negative impact on the Firm.

•RCM Political Contributions Policy

•MyApps / Protegent PTA (ECM) Dashboard)

•Email the Code of Ethics (COE) Compliance Team

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To emphasize the importance of certain obligations and/or

meet regulatory requirements, Supervised Persons are

periodically required to complete a certification of compliance

related to one or more topics. The certification will serve as an

acknowledgement that the Supervised

Person has received, read, understood, complied with, and/or

agrees to continue to comply with, the subject of the

certification.

Certifications of compliance include, but are not limited

to:

•New Hire Code of Ethics Certification

•Broker Account and Holdings Certifications

•Disclosure Certifications re: Outside Business Activities

•Political Contributions, and Private Securities

•Annual Compliance Questionnaire

•Quarterly Electronic Communications Compliance

Certification

At Rockefeller, our steadfast commitment to excellence

guides all that we do. Continuous learning and improvement are

key contributors to our pursuit of excellence. New Hire

Compliance Training and Firm-Required Training play a

pivotal role in achieving this goal by enhancing our knowledge and

understanding of relevant laws, rules, and regulations.

•New Hire Supervised Persons are required to complete

mandatory foundational training upon joining the Firm.

•All Supervised Persons are required to complete

Certifications and Training

must be submitted by

the specified due date;

failure to complete on time may

result in disciplinary action.

Certifications and Training

must be submitted by

the specified due date;

failure to complete on time may

result in disciplinary action.

mandatory Firm-Required Training as assigned

throughout the year.

RESOURCES AND CONTACTS

•MyApps / Protegent PTA (ECM) Dashboard)

•Code of Ethics FAQs

•Email the Code of Ethics (COE) Compliance Team

•MyApps / RegEd

•RegEd Login Instructions

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Prohibited practices related to approved, completed or signed

documentation include but are not limited to the following:

Forging or otherwise completing the signature or initials

of another person in any format, including on any paper

document or in any electronic/digital format (e.g., in

DocuSign), even if a client or other authorized person

requests such activity for the sake of convenience.

Adding to, deleting from or otherwise modifying any

document provided by or previously completed by a

prospect or client, changing prospect/client instructions, or

inserting or modifying prospect/client signatures.

Adding, deleting or otherwise changing the content of any

previously generated Rockefeller or third-party documents to be

provided to prospects or clients.

This policy includes but is not limited to the following:


New Account Documentation*	Client Agreements	Client Facing Forms
Disclaimers	Disclosures	Prospectuses
Marketing Materials	Offering Memoranda	Order Memoranda Statements
Performance Reports	Financial Statements	Statements

*Such as application and enrollment documents

With respect to written prospect/client communications and

marketing materials (such as presentations and proposals),

the use of any tool or application (e.g., Adobe Acrobat,

Word, Paint, etc.) to make modifications are

prohibited, once the document has been approved for client

use, absent the prior express approval of the

Divisional Business Director and/or other designated Registered

Principal.

For ease of assisting our prospects and clients, the above

prohibitions excludes the pre-filling of blank fields in

documents other than the prospect’s/client’s signature and

date of such signature, such as a prospect’s or

client’s name, address, date of birth, and related

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prospect/client-specific information, prior to prospect/ client

distribution; in such instances, the pre-filling of such

information other than the prospect’s/client’s

signature and date of such signature is not prohibited under

RESOURCES AND CONTACTS

this policy.

•Email the Code of Ethics (COE) Compliance Team

•RFLLC Policies and Written Supervisory Procedures (WSP)

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Rockefeller prohibits unacceptable conduct not only in the

physical and virtual workplace, but also in any work-related

setting outside the workplace, such as during business trips,

business meetings and work-related social events or parties. The

Firm’s Work-Related Conduct Policy also applies to use of

Rockefeller’s email and other electronic communication

systems or devices, regardless of whether that use occurs on or

away from Rockefeller premises, on personal devices, or during

non-work hours.

Every Supervised Person is responsible for maintaining and

contributing to a safe and respectful work environment and is

expected to conduct themselves in a manner that

demonstrates professionalism and respect for others.

•RCM Work-Related Conduct Policy

•RCM Raising Concerns - EthicsPoint Reporting Site

•RCM Raising Concerns Policy

•EthicsPoint FAQs

RESOURCES AND CONTACTS

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Rockefeller is committed to cooperating fully with law

enforcement, other government authorities, and regulatory

organizations in accordance with applicable laws and

regulations and with due consideration for the privacy of

our clients. Supervised Persons must cooperate and provide

truthful and complete information in connection with any internal

or external investigation or request for information and must

immediately report to their supervisor if they are

subject to any external investigation.

Any Supervised Person who receives a written or oral request for

RESOURCES AND CONTACTS

information from the government or a regulatory agency must

immediately refer the matter to the Legal & Compliance

Department.

•

Supervised Persons have an ongoing obligation to promptly

notify their supervisor if they are involved in, or become

aware of, a reportable event. Common

reportable disclosures include a home address or office

location change, but it’s equally important to report the less

common reportable disclosures, such as a customer

complaint, compromise with creditors, bankruptcy, civil or

arbitration litigation, and judgement or lien.

Please reach out to Rockefeller’s Registration

Department for guidance if you think you may have a

less common reportable Form U4 disclosure, or any other

question related to your FINRA registrations.

Supervised Persons unsure about whether to disclose an

event should consult their supervisor and the Legal &

Compliance Department. Supervisors must notify the Legal

& Compliance Department of any reportable event brought

to their attention.

RESOURCES AND CONTACTS

•RFLLC Policies and Written Supervisory Procedures

(WSP) (Form U-4)

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Rockefeller’s business is subject to extensive regulation. To

ensure Rockefeller maintains its reputation for the highest

standards of ethical conduct, it is essential the Firm and its

Supervised Persons abide by both the letter and the spirit

of all securities laws and regulations applicable to the Firm’s

operations and business.

Supervised Persons should contact the Legal & Compliance

Department with any uncertainty regarding this Code, Firm

policies, applicable laws, rules, or regulations related to the Firm

or any specific role or entity within it.

Supervised Persons must promptly report any improper or

suspicious activities, including any suspected violations of the

Code or the federal securities laws, to their designated

supervisor and/or Legal and Compliance.

Rockefeller is committed to a culture of compliance

grounded in honesty, integrity, trust, and accountability.

As such, we offer multiple channels for Supervised Persons to

raise any concern regarding suspected violations of applicable

laws, regulations, and/or firm policies ─ confidentially,

anonymously, and without fear of retaliation.

The Firm depends on you to raise any concern regarding

possible violations of this Code. No adverse employment

DIRECT CONTACTS

Toll-free and anonymous, within the United States,

Guam, Puerto Rico, and Canada: 844-757-1211.

•

RESOURCES AND CONTACTS

•

action, including termination, corrective action or

•RCM Raising Concerns Policy

•RCM Raising Concerns - EthicsPoint

Reporting Site

•EthicsPoint FAQs

impacted performance review, may be taken against a

Supervised Person who reports a concern in good faith.

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RCM is committed to conducting business in an honest

and ethical manner at all times, including complying with

applicable anti-bribery, anti-corruption, and anti-kickback laws

in the countries where we do business. RCM

prohibits offering, promising, providing, authorizing, and

accepting improper payments. RCM also prohibits making

improper payments or engaging in similar improper

conduct through third parties.

Supervised Persons are encouraged to be aware of “Red Flags” which

might suggest a closer look at a transaction or relationship is necessary

before proceeding. Any Red Flag encountered must be promptly reported

to the Legal & Compliance Department for further review.

RCM is committed to prohibiting and actively

preventing money laundering and any activity that

facilitates money laundering or the funding of terrorist or

criminal activities.

Rockefeller is also committed to ensuring strict

compliance with all applicable sanctions programs.

The Firm’s dedication to integrity requires strict

compliance with all applicable anti-money laundering

and sanctions rules and regulations. The participation

in, or facilitation of, money laundering, even

unintentionally, could result in civil and criminal

penalties against Supervised Persons and the Firm.

Supervised Persons are responsible for reviewing,

understanding, and complying with the Firm’s Anti-Money

Laundering (“AML”) Compliance Policy (as well as the

entity-specific AML and Sanctions Programs incorporated

into that Policy).

•RCM Anti-Bribery and Anti-Corruption (“ABC”) Policy (See

Appendix-1 for lists of transaction-specific red flags and

payment red flags)

RESOURCES AND CONTACTS

•RCM Anti-Money Laundering Compliance Policy

•Rock & Co. AML and Sanctions Program

•RFLLC AML and Sanctions Program

•RTCDE AML and Sanctions Program

•RTCNA AML and Sanctions Program

RESOURCES AND CONTACTS

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Supervised Persons must maintain accurate tax records on

behalf of their clients and are prohibited from engaging in any

activities that would assist a client in committing tax evasion.

Supervised persons should be vigilant and

promptly report to the Legal & Compliance Department any

violations, potential violations, or conduct that appears to be

tax evasion or concealment of information from tax

authorities.

Questions about whether a particular act or

request constitutes tax evasion should be raised with a supervisor or the

Legal & Compliance Department at the earliest possible stage.

At Rockefeller we aim to demonstrate discipline and

excellence in all aspects of operating the business

including in the creation, management and required retention of

important documents. Furthermore, our business is

subject to recordkeeping requirements promulgated

and

enforced by the U.S. Securities and Exchange

Commission (SEC), the various states, and self-

regulatory agencies such as the Financial Industry

Regulatory Authority (FINRA).

To conduct its business successfully and meet legal and

regulatory requirements, Rockefeller requires complete and

accurate books and records of its business activities. The Firm has

policies and procedures, including specific retention periods,

designed to comply with these requirements.

Supervised Persons are responsible for maintaining the integrity

of their records and must adhere to all applicable Firm policies

and procedures.

•RCM Records Retention and Management Policy

•RFLLC Policies and Written Supervisory Procedures (WSP)

•RTCDE Policies and Procedures Manual

•RTCNA Policies and Procedures Manual

RESOURCES AND CONTACTS

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Rockefeller operates with the highest standards of professionalism and

integrity in accordance with our legal and regulatory books

and records obligations. The Firm is committed to ensuring

business-related electronic communications by Supervised

Persons are only conducted on Firm approved systems,

applications, and devices (“systems”) and retained as required by

applicable regulation.

Employees may not use personal email, text messaging, or any other non-

All business-related

electronic communications

MUST occur within

approved systems and

applications ONLY (e.g.,

RCM email, RCM

Teams, and Zoom Phone).

There are no exceptions.

approved communication application to interact with clients, prospective

clients, or any fellow RCM employee when discussing business-related

matters. Any attempt to violate, circumvent, and/or disregard these

requirements may result in disciplinary action, up to and including

termination.

•RCM Business-Related Electronic Communications

(see Appendix B for list of Approved Systems & Applications)

•Business-Related Electronic Communications FAQs

•RCM Advertising and Marketing Policy

•RCM Discrimination and Harassment Policy

•RCM Information Barriers Policy

•RCM Records Retention and Management Policy

•RCM Social Media Policy

•RCM Work-Related Conduct Policy

•RFLLC’s Policies and Written Supervisory Procedures (WSP)

RESOURCES AND CONTACTS

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Internal Use Only

Supervised Persons must protect client, proprietary,

and other confidential information. The mishandling, loss,

unauthorized disclosure, or access of such information could

result in significant legal, business, regulatory, and

reputational harm to Rockefeller.

Rockefeller has established information barriers policies

and procedures to control the dissemination and/or

misuse of confidential information, including proprietary and material

non-public information (“MNPI”). All confidential information must be

safeguarded and used solely for the intended business purposes of

Rockefeller and applicable clients.

Material non-public information (MNPI) is information that

(1) has not yet been broadly disseminated in the

marketplace and (2) a reasonable investor would

consider important in making a decision to buy, hold or

sell a security.

In certain circumstances, employees may become

aware of MNPI in their general course of business

activities or in

servicing client transactions. This information may have

been

intentionally provided by the client or inadvertently

received. If a public side employee has become aware

of MNPI, they must immediately inform the Control

Group to notify them of the facts and circumstances associated

with the information. Employees who become aware of MNPI may

be wall crossed by the Control Group and subject to the

requirements noted in this policy and other considerations.

It is illegal and in contravention of Rockefeller policy for anyone

to trade or cause the trading of a security or related financial

instrument (collectively “security”) while in

possession of MNPI relating to that security. This conduct is

referred to as insider trading and may result in civil and/or criminal

penalties. The prohibition on insider trading applies to both

personal securities transactions and to transactions entered on

behalf of clients or prospective clients of the Firm.

RESOURCES AND CONTACTS

•RCM Information Barriers Policy

•RCM Identity Theft Prevention Program

•RTCDE Policies and Procedures Manual

•RTCNA Policies and Procedures Manual

•Email the Control Group

•RFLLC Policies and Written Supervisory Procedures (WSP)

Internal Use Only

The business world grows increasingly digital every day, and

with it the volume and sophistication of threats to

cybersecurity. It’s more important than ever that we

practice vigilance against bad cyber actors in our online

communications, interactions, and transactions of every kind.

To mitigate the risk associated with the use of digital

technology, the Firm maintains a framework of safeguards to

prevent, detect, and respond to cyber threats. Supervised Persons

share responsibility with the Firm for protecting

customer information and the Firm from cyber threats.

Safeguards in Privacy, Identity Theft,

and Cybersecurity are key to

maintaining trust with our clients.

Supervised Persons must comply with the Firm’s data

protection policies and procedures and may not:

•Access confidential information remotely except

through devices that have appropriate Firm-

approved security and software

•Use Wi-Fi that is not password protected to access

confidential information

•Share their Rockefeller username or passwords with

others

•Access a client’s Rockefeller account or any client’s

external, third-party account using the client’s own

unique identifying information, even if the client has

provided authorization for such access.

•RCM Identity Theft Prevention Program

•RCM Information Security Policy

•RCM Online Privacy Policy

•RFLLC Policies and Written Supervisory Procedures (WSP)

•RTCDE Policies and Procedures Manual

•RTCNA Policies and Procedures Manual

RESOURCES AND CONTACTS

Many states have enacted security breach notification laws that

require the reporting of security breaches to regulatory

agencies and affected customers. In the event of a breach or

other cybersecurity-related incident, Supervised Persons must

immediately report the incident to the Legal & Compliance

Department, which will determine the

appropriate course of action regarding any applicable

notification requirements.

Internal Use Only

Thank you for taking the time to read through this Code. We

are all on the front lines of safeguarding Rockefeller’s reputation

and upholding our ethical standards.

If you have any questions about the Code or require additional

guidance, please speak with your manager,

Compliance, or other appropriate contact referenced in this

Code.

To achieve the remarkable, ethical behavior and personal integrity are

indispensable. By seeking advice, raising a concern, or reporting

potential misconduct, you are

embodying Rockefeller’s Code of Ethics and Commitment to

Integrity.

“Next to doing the right thing, the

most important thing

is to let people know

you are doing the right thing.”

- JOHN D. ROCKEFELLER

Internal Use Only

Rockefeller maintains policies and procedures on the Rockefeller Capital Management Policies and Procedures Portal. Additional policy

related-documents and supplemental information can be found on the RCM Legal & Compliance SharePoint site.

Below is a non-exhaustive list of policies and FAQs referenced in this Code and located on the RCM Policies & Procedures Portal.

POLICIES AND PROCEDURES

RCM Advertising and Marketing Policy

RCM Anti-Bribery and Anti-Corruption (“ABC”) Policy RCM

Anti-Money Laundering Compliance Policy RCM

Business-Related Electronic Communications RCM

Charitable Contributions Policy

RCM Conflicts of Interest Policy

RCM Customer Complaints Policy

RCM Discrimination and Harassment Policy RCM

Gifts and Entertainment Policy

RCM Identity Theft Prevention Program

RCM Information Barriers Policy

RCM Information Security Policy RCM

Online Privacy Policy

RCM Outside Business Activities (OBA) Policy

RCM Personal Account Trading Policy

RCM Political Contributions Policy

RCM Raising Concerns Policy

RCM Records Retention and Management Policy RCM

Restricted List

RCM Work-Related Conduct Policy

RCM Social Media Policy

Rock & Co. AML and Sanctions Program

RFLLC Policies & Written Supervisory Procedures (WSP) RFLLC AML

and Sanctions Program

RTCDE Policies and Procedures Manual RTCDE

FAQS

AML and Sanctions Program RTCNA Policies

and Procedures Manual RTCNA AML and

Sanctions Program

RCM Code of Ethics FAQs

Personal Account Trading Policy FAQs EthicsPoint

FAQs

Business-Related Electronic Communications FAQs

Internal Use Only

Below is a non-exhaustive list of contacts and applications referenced in this Code.

•Compliance Partner Contact List

•Email the Code of Ethic (COE) Compliance Team

•Email the Control Group

•MyApps / Protegent PTA (ECM) Dashboard)

•MyApps / RegEd

APPLICATIONS

•RegEd Login Instructions

•RCM Raising Concerns - EthicsPoint Reporting Site

RAISING CONCERNS CONTACTS

•