Code of Ethics of Allianz Global Investors Europe.

• Signature of the individuals that are closely connected with the employee, as well as of the individuals who are the owners of the accounts with respect to which the employee has a proxy

Name and surname

Chapter VIII: Training, Certification of Compliance & Supervision of the Code of Ethics

Allianz Global Investors is faced with numerous challenges in developing its business and in a rapidly changing market. Central to the efficient and legitimate development of our business is effective corporate governance, which is inevitably founded upon a robust compliance infrastructure that ensures adherence with relevant legislation, regulation and policies.

A number of recent high-profile corporate scandals and increase in financial crime globally, has resulted in heightened focus on the effectiveness of corporate governance. Hence, in the current climate it is important to be able to demonstrate that Allianz Global Investors has an effective compliance management framework in place.

This Code of Ethics sets out the guiding principles and rules for managing compliance risk here at Allianz Global Investors.

We are committed to ensuring that the activities of the firm and its employees are conducted in accordance with all applicable laws and regulations, and all relevant internal rules, policies and procedures and to the highest ethical standards.

Allianz Global Investors requires all staff to maintain the highest standard of conduct. This obligation brings with it a responsibility on the part of all staff to act honestly and with integrity, and to observe both the letter and spirit of all internal rules, policies, procedures and ethical standards.

A high-level summary of the regulatory requirements for our business, and the associated conduct expectations for our staff, are set out in this Code of Ethics. The Code not only helps us to comply with the law, but also establishes us as a good corporate citizen, proud of our reputation and integrity. In addition, the principles detailed in the Code are consistent with our core values. We are passionate about our business and committed to delivering excellence to our clients, acting with integrity and respect.

In order to foster a good compliance culture, employees are required to read and understand this Code and to contact the Compliance department for guidance on any compliance issues. Allianz Global Investors aims to ensure that each employee understands that compliance is ‘owned’ by everyone in the business; it is not just the responsibility of the Compliance department. All staff have a responsibility to immediately report and address breaches as far as practicable and anyone who does not comply, or who knowingly and recklessly breaches this Code, or the law, will be subject to disciplinary action.

I am absolutely committed to this Code of Ethics. It has the complete support of the Allianz Global Investors Board, European Executive Committee and our senior management team, and all employees are obliged to comply with this Code.

Code of Ethics

Introduction

1. Overview and Scope

Allianz Global Investors is committed to professionalism and ethical conduct in all of its activities. Meeting Allianz Global Investors’ professional and ethical standards and complying with applicable laws and regulations is the responsibility of each employee.

Our image is shaped by every employee – irrespective of their position in the company. We all carry a particular responsibility – vis-à-vis the public and our clients, as well as the Allianz Group and our colleagues.

Thus, this Code is designed to ensure that all employees live up to their responsibility and it spells out fundamental principles and highlights resources available to help employees understand and uphold these principles. These are based on Allianz Global Investors’ values which form the foundations of expectations regarding the behaviour of Allianz Global Investors’ employees:

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Excellence is about identifying opportunities to be ahead of the curve and always trying your very best to improve your performance. It is about being professional, persistent and diligent in what we do to consistently deliver quality work.

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Integrity is about going beyond driving ethical behaviour to include sincerity, commitment, honesty and fairness. Integrity is being open and transparent with our clients and each other. All these elements are required to deliver trust.

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Passion is about loving what you do, having the client, the business and your interests align and going above and beyond your expectations in a way that inspires those around you.

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Respect is about being considerate of people and ideas, being open and actively listening. It means being fair in how we treat others and accepting difference as a source for reflection.

The Code of Ethics applies to all executives, directors, officers, and employees of Allianz Global Investors in Europe, including interns and temporary employees if the employment contract lasts longer than one month (“Employee“ or collectively, “Employees”). The Code is provided to every Employee upon beginning of employment. The standards set forth herein serve as minimum standard. We expect that all Employees follow the Code of Conduct both in letter and in spirit.

All Employees should therefore become familiar with this Code of Ethics and abide strictly by its provisions. In the event Employees suspect or are witness to any violations of its provisions they should promptly report concerns to their supervisor or to Compliance. Allianz Global Investors strictly prohibits retaliation against anyone who reports in good faith a possible violation of the Code, no matter whom the report involves.

Some Employees may, however, due to their specific terms of employment also be or become subject to the policies and procedures of other Allianz or Allianz Global Investors companies. Amongst other things, this can be of particular importance in respect of the Personal Account Dealing rules applicable to the respective individual Employee. In the event that you identify some variation between two sets of rules, contact Compliance for guidance on which set of rules to follow.

As all Employees have to follow this Code of Ethics both in letter and in spirit, managers and senior personnel are - in particular - responsible for actively fostering a strong compliance culture and embedding the values reflected in this Code of Ethics (Tone at the Top). Each manager has organizational and supervisory duties to fulfil. Consequently, each manager has to ensure that no violations of this Code of Ethics take place where these could have been prevented by adequate supervision. Managers also retain their responsibility when delegating individual tasks.

Compliance oversees and monitors compliance with this Code of Ethics and will give guidance to all Employees regarding this Code. Employees should discuss with Compliance any suspicion of non-compliance with the rules and regulations of this Code.

2. General Principles

Maintaining the highest standards of conduct is integral to Allianz Global Investors. Hence, the general principles to be observed by each Employee while conducting business for Allianz Global Investors may be summarized as follows:

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We will at all times conduct ourselves with integrity and distinction, putting first the interests of our clients. We comply with all applicable law, rules, standards and good market practice and apply the internal policies and procedures that are relevant to our activities.

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Violating the rules may appear to bring short-term success, but in the long term such behaviour is injurious both to ourselves and to those around us. Any results achieved by dishonest means will not be endorsed. Avoid taking inappropriate advantage of your position at Allianz Global Investors. Avoid dishonest transactions. Do not jeopardise the reputation of Allianz Global Investors.

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Long-term trust is only enjoyed by those who conduct themselves fairly. Potential conflicts of interest must be identified at the earliest reasonable opportunity, avoided if possible and action taken to manage them in the best interest of our clients if they occur.

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Confidentiality of information including data protection must be maintained at all times. Client information, price sensitive information and other confidential information that Employees may receive in the course of their business must only be acted on as necessary or appropriate to their respective job function.

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The commitment of all Employees is a key factor for our success. Any work undertaken outside your employment with Allianz Global Investors or any other business activities you undertake must not jeopardise your performance either for Allianz Global Investors or for our clients. You must obtain approval from your supervisor and the Human Resources Department and inform Compliance before engaging in such activities. Do not enter into any form of business participation or accept any mandate if you have reason to believe that it could compromise the interests of our clients, of Allianz Global Investors, the Allianz Group or your professional independence and integrity.

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We communicate in a clear and fair manner. Our clients, business partners and colleagues, as well

as other Allianz Group companies and the financial markets expect clear and articulate communication. All our communication should be complete, timely, fair and not misleading, containing all relevant information, and no significant aspect should be omitted that might lead to a misrepresentation of plans or circumstances.

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We must not mislead our clients or the financial markets as to the value of any assets by our actions, statements or by refraining from taking necessary actions or making such statements or by making incomplete statements.

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Personal Account Dealings must only be executed in accordance with the rules set forth in this Code of Ethics.

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Our behaviour towards one and another is based on mutual respect and trust. We make every effort to ensure that nobody within Allianz Global Investors is sexually harassed or discriminated against on the basis of race, religion, nationality, gender, origins, political or trade union activities or convictions, or sexual orientation.

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Maintaining our professional independence is a cornerstone of our success. Professional independence and integrity shall be maintained and not compromised by the offer or receipt of incentives, benefits or gifts.

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You should protect the firm’s assets and ensure their efficient use. All company assets should be used for legitimate business purposes only. As our assets are pre-requisite for our success we must ensure that they are used effectively.

Chapter I: Our Clients

At Allianz Global Investors, we act as a partner to our clients in order to capitalize on the opportunities offered by the capital markets. As a fiduciary, we have a duty to act in the best interest of our clients. Consequently, transparency and integrity must be at the core of all our business dealings to avoid any improper advantage or the appearance of questionable conduct by our Employees.

We are all in a position of trust, and as such, are expected to adhere to the highest professional and ethical standards and to put our client’s interests first at all times.

1. Confidential Information

In the normal course of business you may, from time to time, come into possession of confidential information relating to clients. You have a duty to respect the confidential nature of such information and to use such information solely for the purpose of the relationship to the respective client. Keeping such information confidential and thus complying with laws and regulations is essential for maintaining the trust of our clients.

This applies not only to confidential information which could affect the value of traded securities and to Inside Information which is subject to specific statutory provisions (see chapter II.2. “Inside Information“), but also to (stored) data relating to individual and institutional clients which require Employees to act in line with data protection legislation and contractual confidentiality obligations.

As a result:

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Confidential information should only be discussed internally on a ‘need to know’ basis and both statutory and contractual restrictions on forwarding and using such data must be observed at all times.

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Do not use confidential information either for personal gain or for the advantage of any other person.

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Take care that unauthorized persons do not gain access to any client’s documents or records.

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Never discuss confidential matters in places, including the offices, where the conversation could be overheard by third parties.

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When making telephone calls or holding meetings outside your own office or off-site, e. g. in restaurants (including the staff canteen), trains, aircraft, taxis and other public places, care should be taken to ensure that confidential information is not inadvertently disclosed to unauthorized persons.

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Information about holdings of our investment funds is proprietary information of Allianz Global Investors and must be kept confidential. You must observe the specific procedures regarding the disclosure of portfolio holdings.

In certain areas Information Barriers have been established to ensure that Employees have adopted procedures to safeguard the confidentiality of

information (see chapter I.3. “Observance of Information Barriers“). You must observe such Information Barriers at all times.

2. Principle of Investment Independence

The Principle of Investment Independence applies to all Allianz Global Investors companies:

Each company and each team should act solely in the interests of its clients. If a company assumes a mandate or executes a transaction for a client, this mandate or transaction must be performed with the sole focus on the client’s best interests and irrespective of all other company or third-party interests.

This can result in the establishment of particular protected zones of confidentiality. This can also mean that employees or teams working in the same business unit or department are separated in spatial terms when handling a mandate.

This principle applies, in particular, to investment decisions. Such decisions must be isolated from the business considerations of other units of Allianz Global Investors and the Allianz Group.

In order to support the Investment Independence Principle, you must observe the Information Barriers established by Allianz Global Investors.

3. Observance of Information Barriers

An Information Barrier is a barrier that controls or restricts the flow of confidential information. It is essentially designed to isolate information and to prevent the communication of that information between certain people or operating areas.

To observe those Information Barriers and to maintain confidentiality, you have to observe the following principles:

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Do not communicate confidential information through an Information Barrier unless prior permission is obtained from Compliance.

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Documents and records in electronic format shall be password protected or otherwise protected.

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Paper documents and records shall be kept in locked drawers and/or restricted areas.

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Conference or meeting rooms will be cleared of confidential information prior to meetings with

other Employees or employees of other entities to ensure that no confidential information has been left in the room.

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Even within areas restricted by information barriers the access to confidential information shall be limited to the extent operationally required.

4. Inquiries from Clients

Unless you know the client personally, you must ensure that the person you are dealing with is the account holder or an authorised representative before revealing or handing over any information. The person requesting information should present a valid ID card or some other form of identification, or a comparison of the signatures should be performed.

Do not provide any information to family members of a client unless you are certain that the client has issued a corresponding power of attorney.

Telephone inquiries pose a particular risk. If you cannot clearly identify the client or authorised representative by their voice, you should involve colleagues who know the caller. Otherwise, arrange to call the person back. This will allow you to check the telephone number. This is the only way of ensuring that the information reaches the authorised recipient.

Do not allow yourself to be distracted by inappropriate comments, time pressure, threats or attempts at persuasion. Involve your supervisor where necessary.

5. Complaints

At Allianz Global Investors we aim to provide our investors and clients with a high standard of service. However, from time to time clients may complain. When this happens, this should be communicated as soon as possible so any issue may be addressed in an appropriate manner.

Thus, as part of our commitment to client-centricity and quality, Allianz Global Investors will encourage feedback on the services provided to clients.

All Employees must deal with complaints promptly and fairly and in accordance with the provisions of the Customer Complaint Policy attached as Module 1

to this Code of Ethics. Those involved in the handling of complaints must use all efforts to ensure satisfactory resolution within the time frame set forth in this Policy.

6. Financial Promotion

a. Sales and Marketing Materials

As a general rule, all communication by Allianz Global Investors to its business partners and clients must be clear, fair and not misleading. In many the jurisdictions where Allianz Global Investors operates, incomplete or misleading communication may also constitute a regulatory offence.

Therefore, all marketing materials (regardless of the support, i.e. printed media or the Internet), client presentations and press releases must be submitted to Compliance for review and approval at least three business days before anticipated use together with supporting documentation.

Compliance will check whether any appropriate disclaimer is included and whether there are any additional disclosure requirements. It is, however, the responsibility of the originator of the material to ensure the content is accurate and complete and meets the general requirement of being clear, fair and not misleading.

Promotional materials which are product specific - i.e. in respect of investment funds - must typically include further information, if such funds are authorised for public distribution in foreign jurisdictions. Compliance maintains a database which contains all relevant information regarding those requirements; such database is accessible to the Marketing Department.

b. Investment Funds not authorized for public distribution

As a consequence of the regime established by the EU Undertakings for Collective Investment in Transferable Securities (UCITS) and the Alternative Investment Fund Management (AIFM) Directives, it is forbidden to engage into active financial promotion of investment funds which are not authorised for public distribution in a given jurisdiction.

7. Gifts and Entertainment

Maintaining our professional independence is a cornerstone of our success. Hence, Employees may only accept or offer personal gifts, benefits, special favours or hospitality according to the Anti – Bribery and Gifts & Entertainment Policy attached as Module 2 to this Code of Ethics.

Chapter II: The Financial Markets

As an industry leader, we want to set an example in the financial markets. In addition, AllianzGI fully supports the EU Market Abuse Regime. Therefore we do not allow any illegal trading practices whether for clients or for Employees. We also must safeguard information which is deemed to have an influence on market prices and do not allow the use of such information for an unfair advantage to the detriment of third parties.

1. Prohibition of Market Manipulation

Any information we disclose towards the financial markets must be communicated in good time and in a clear, comprehensive and comprehensible manner. It should not be misleading and must comply with the principles of fair, proper, professional and transparent communication.

Employees are not permitted to take any action or provide information that could mislead either the market or our clients and that consequently could be considered as market manipulation. “Market manipulation” can be defined, amongst others as:

(I) Entering into a transaction, placing an order to trade or any other behaviour which (a) gives, or is likely to give, false or misleading signals as to the supply of, demand for, or price of, a financial instrument or (b) secures, or is likely to secure, the price of one or several financial instruments at an abnormal or artificial level (unless shown to have been carried out for legitimate reasons and in conformity with accepted market practice) (c) affects, or is likely to affect, the price of one or several financial instruments and which employs a fictitious device or other form of deception or contrivance

(II) Disseminating information (in any way) in a manner which (a) gives, or is likely to give, false or misleading signals as to the supply of, demand for, or price of, a financial instrument or (b) secures, or is likely to secure, the price of one or several financial instruments at an abnormal or artificial

level (including the dissemination of rumours, where the disseminator knew, or ought to have known that the information was false or misleading).

Such action could result in prosecution. Even accusations of such misconduct will have a negative impact on Allianz Global Investors and all Employees concerned.

Particular care must be exercised when dealing with announcements, advertising and the publication of research, prospectuses and informational material in order to eliminate the possibility of misleading information.

If you feel that you may have engaged in, caused or otherwise discovered misleading or manipulative activities, you must inform Compliance immediately. Under no circumstances should you make further statements or take action on your own initiative in an effort to correct the initial effect.

Amongst others, the following actions may be regarded as market and price manipulation and may result in prosecution:

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“Wash sales” – securities transactions where the buyer and seller are legally identical, meaning that the securities transaction does not result in a change of ownership;

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“Pre-arranged trades” – key transactions details (e. g. price, number of units) were the subject of prior agreement between the parties;

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“Painting the tape” – securities transactions that mislead the public by artificially boosting trading volumes;

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“Marking the close” – exploiting trading hours (e. g. close of trading) to manipulate the closing price of shares, with the intention of misleading other market participants;

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“Cornering” – gaining control over demand for a security in order to create the impression that it is in short supply;

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Spreading rumours in order to urge market participants to act in a certain way (buy, sell, hold).

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When orders to trade given or transactions undertaken represent a significant proportion of the daily volume of transactions, in particular when those activities lead to a significant change in the price.

2. Inside Information

a. Material, non-public information

By the nature of our work, you may come into possession of Inside Information. “Inside Information” is information relating directly or indirectly to one or more issuers or to one or more financial instruments which:

(I) is of a precise nature – i.e. it: (a) indicates a set of circumstances which exists or which may reasonably be expected to come into existence, or an event which has occurred or which may reasonably be expected to occur; and (b) is specific enough to enable a conclusion to be drawn as to the possible effect of that set of circumstances or event on the prices of the financial instrument or the related derivative,

(II) has not been made public and

(III) if it were made public, would be likely to have a significant effect on the prices of those financial instruments or on the price of the related derivative. This is the case if a reasonable investor would likely use this information as part of the basis of his investment decision

The following examples are considered Inside Information:

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Buying or selling of business units.

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Mergers or acquisitions.

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Buying or selling of major holdings.

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Restructuring matters.

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Capital restructuring.

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Earning expectations.

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Future dividend payments.

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Block orders.

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Investment decisions of fund managers.

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Investment strategies of insurance finance departments.

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Research due to be published.

b. Notice to Compliance of Inside Information

For your own protection, as well as that of Allianz Global Investors, you shall inform Compliance immediately in the event you have obtained Inside Information. Such notification should be submitted to Compliance in writing where possible, and should specify whether the information has been made known to other colleagues. Please also contact Compliance if you are unsure whether information is Inside Information or not.

Compliance will put the relevant security on the ’Watch List‘, including details of Employees who have access to the Inside Information. Compliance will monitor the transactions of that security to ensure that Inside Information is not being used in an unauthorised manner and also to take preventative action in good time, in order to prevent situations whereby Allianz Global Investors could be suspected of having abused Inside Information.

Please also inform Compliance immediately when Inside Information which you have reported to Compliance becomes public knowledge or is resolved in such a way that it is no longer needed to be treated as Inside Information.

c. Ban on Insider Dealing

It is unlawful to obtain an unfair advantage from Inside Information to the corresponding detriment of third parties who are unaware of such information. In particular, you must not:

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buy or sell (trade) any securities on the basis of any Inside Information (dealing prohibition);

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recommend or encourage third parties to transact in respect of any securities on the basis of Inside Information (recommendation prohibition);

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unlawfully disclose inside information to another person e Information beyond the scope of your professional duties (dissemination prohibition).

The violation of insider dealing laws and regulations constitutes a criminal offence which may have implications for you, personally, as well as for the reputation of Allianz Global Investors and the Allianz Group.

d. Restricted List – Information on particular Compliance Restrictions

In the case of capital market transactions involving Allianz Global Investors or any affiliated company, particular statutory or official requirements and reporting obligations may restrict the execution of investment decisions or personal account dealings.

The Allianz Global Investors Restricted List sets out the restrictions that apply only to investment funds and direct mandates, not personal account dealings.

The Restricted List is for internal use only and may be forwarded to third parties only in exceptional circumstances and with the approval of Compliance. The Allianz Global Investors Restricted List is maintained, updated and made available to the relevant departments by Compliance and may be provided in the Intranet.

3. Prevention of Late Trading, Market Timing and Frequent Trading

With regard to our investment funds, we do not allow any dealing activities which are associated with Late Trading, Market Timing or Frequent Trading, as such practices may adversely affect the interests of all our fund investors.

For the purposes of this section:

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Late Trading refers to the acceptance of a subscription, conversion or redemption order into an investment fund after the time limit fixed for accepting orders (cut-off time) on the relevant day and the subsequent execution of such order at a price based on the Net Asset Value applicable to such same day. However, orders received after the cut-off time may be accepted on an exceptional basis with the approval of Compliance when a technical dysfunction can be demonstrated to have occurred that prevented an order from being received or processed before the cut-off time.

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Market Timing refers to an arbitrage method through which an investor systematically subscribes and redeems or converts units or shares of the same investment fund within a short time period, by taking advantage of time differences and/or imperfections or deficiencies in the method of determination of the Net Asset Value of this fund.

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Frequent Trading refers to subscriptions into, conversions between or redemptions from units or shares of the same investment fund that by virtue of their frequency or size cause the fund’s operational expenses to increase to an extent that could reasonably be considered detrimental to the interests of the fund’s other investors.

Accordingly, we may implement or require service providers to such funds to implement protective measures, such as rejecting applications for subscriptions, conversions or redemptions from investors to avoid any impact on our funds.

Please inform Compliance if you have identified such practices.

4. Financial Crimes

We are an active participant in international efforts to combat fraud, corruption and the funding of terrorist and criminal activities. Our commitment is matched by the maintenance of on-going controls to detect and prevent any such illegal practices.

a. Corruption and Bribery

Any attempts to illegally influence the decisions of clients and other individuals such as business partners by means of corruption and bribery will not be tolerated.

Combating corruption and bribery and protecting ourselves from them is a major concern for Allianz Global Investors. Corruption and bribery in business dealings are illegal and have to be stopped.

Investigations arising from the suspicion of corruption or bribery have considerable consequences for a company. It suffers not only from constraints placed on its business dealings but also from the fact that it can incur considerable losses through public knowledge of an investigation and the accompanying press reports.

The dishonest influencing of decisions by granting benefits of whatever kind is forbidden. This applies at home and abroad, and not only where public officials are concerned but also individuals such as employees of privately owned companies.

In particular, Employees may not in the course of business offer, promise, demand, grant or accept any gifts, payments, invitations or services that have been intentionally offered with the aim of influencing a business relationship in an unauthorized way, or wherever there is a danger of compromising or jeopardizing the independence of the business partner.

We also prohibit the offering of anything in value to public officials that could be construed as requiring or influencing any official decision (or attempting to).

Thus, Employees must observe the procedures set out in the Anti-Bribery and Gifts & Entertainment Policy attached as Module 2 to this Code of Ethics to avoid any improper conduct of business in this respect.

All Employees are called upon to prevent corruption and bribery. Please inform Compliance should you have come across any such practices.

b. Money Laundering and Terrorist Financing

Globally, the attempted use of financial institutions and instruments to launder money is a significant problem that has resulted in strict laws in many countries.

Money laundering is the attempt to disguise money derived from or intended to finance illegal activity including drug trafficking, terrorism,

organized crime, fraud, and many other crimes. Money launderers go to great lengths to hide the sources of their funds. Among the most common strategies are placing cash in legitimate financial institutions, layering between numerous financial institutions, and integrating the laundered proceeds back into the economy as seemingly legitimate funds.

The financing of terrorism is the act where a person by any means, directly or indirectly, wilfully provides or collects funds with the intention that they be used, in full or in part, in order to carry out a terrorist act or is related thereto.

All Employees must be vigilant in the fight against money laundering or terrorist financing activities. With good knowledge of our customers, we will in general be able to identify unusual or suspicious behaviour, including false identities, unusual transactions, changing behaviour, or other indicators that money laundering or terrorist financing may be occurring.

Allianz Global Investors has developed an Anti-Money Laundering Policy and KYC Guidelines and each Employee must comply with the procedures set out in Module 3 of this Code of Ethics.

c. Fraud

Fraud can cause significant damage. It provokes a loss of trust by clients and places the competitiveness of Allianz Global Investors at risk. For purposes of this Code, “Fraud” is any intentional act or omission, either internally by Employees or externally by third parties, which (i) is illegal under applicable laws or regulations, and (ii) has resulted or may result in an actual or potential loss of company assets or revenue or harm of reputation.

Both, management and staff are responsible for the prevention and detection of Fraud. We require the prompt reporting of any suspected fraudulent activity to Compliance.

Employees who submit a report (including reports made via Speak Up facilities) on suspected Fraud in good faith are protected against any retaliation or other form of discrimination. For further details please see the Anti-Fraud Policy which is attached as Module 4 of this Code of Ethics.

Chapter III: Conflicts of Interest

In order to provide the best service to our clients, Allianz Global Investors pursues an effective management and fair handling of the potential conflicts of interests that may arise in the course of providing investment services.

A potential conflict of interest arises when

1.	the interests of different clients do conflict with each other, or

2.	the interests of Allianz Global Investors conflict with the interest of a client, or

3.	private or personal interests of an Employee conflict with his or her official responsibilities as an Employee, or

4.	the interests of Allianz Global Investors conflict with those of other Allianz Group companies.

There are three guiding principles that will help Employees to avoid conflicts of interest:

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Do not use your position within our company for personal gain for yourself or any person with whom you have personal, business, or financial ties.

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Avoid any outside activity that could interfere with the timely and effective performance of your job.

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Do not participate in any action, whether for Allianz Global Investors or another Allianz company, which involves a company in which you or your family has significant financial interests or other business or personal connections.

If you think there is even a chance that you or another Employee might have a conflict of interest, you are responsible for disclosing the matter and seeking advice from your line manager or Compliance.

1. Personal Account Dealing

Allianz Global Investors has adopted rules for the Personal Account Dealings of its Employees in Financial Instruments. These rules are designed to ensure that Personal Account Dealings do not conflict with (or appear to conflict with) the interests of our clients or the Allianz Group, or violate insider trading laws.

These rules are not mere restatements of minimum legal requirements. They embody our commitment to high ethical standards. They also ensure that personal conduct is consistent with our obligation to conduct our business properly, and shield Allianz Global Investors and its Employees from allegations of improper conduct.

In case of any conflict of interest, the interests of our clients shall predominate. Each Employee must bear in mind that the reputation of Allianz Global Investors and Allianz, as well as the Employee ś own standing and that of other colleagues can be irreparably harmed by even an appearance of misconduct.

If, at any time, an Employee is in doubt as to whether they are in compliance with these Personal Account Dealing rules, they should contact Compliance for advice. It is the responsibility of every Employee to ensure that they are familiar with these Personal Account Dealing rules and are aware of their own personal obligations in connection with such dealings. Each Employee is responsible for ensuring that all transactions and associated risks are commensurate with their personal income and assets.

a. Extended Personal Scope

In addition to transactions initiated or executed by Employees, the Personal Account Dealings rules also cover transactions that are initiated or executed

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by Employees for individuals closely associated with them, e.g. spouses, registered partners, children entitled to care and other relatives living in the same household;

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by Employees on behalf of, or for the account of, third parties, including trusts or companies, whose investment decisions are made by Employees or influenced as a result of business or private relationships;

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by individuals who have such a close relationship with the Employee that the Employee is likely to be able to influence them and takes a joined investment decision with that individual, e.g. spouses, registered partners, children entitled to care and other relatives living in the same household; and

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by third parties for the account, or in the interests, of Employees.

The rules governing Personal Account Dealing will apply without limitation to the transactions more fully described below. For the avoidance of doubt, Personal Account Dealings are meant to include all transactions initiated by Employees outside of their professional activities.

b. Definition of Financial Instruments

The Personal Account Dealing rules relate to the purchase or sale of the following Financial Instruments:

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securities, i.e. equities, certificates and bonds;

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options, warrants and other derivatives/futures on securities, precious metals, commodities, rights of issuance, freight rates, loans, interest rates, currencies and indices (as well as the active exercise of related contractual rights)

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investment fund units (Allianz Global Investors funds as well as third party funds);

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contracts for difference (CFD ś)

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new issues (subscription and disposal);

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any other agreement which intends to generate profit from the performance of Financial Instruments set out above.

c. Beneficial Interest

Personal Account Dealing procedures are aimed at capturing all transactions in Financial Instruments in which an Employee has a direct or indirect beneficial interest. An Employee has a beneficial interest in a transaction if they have the opportunity to benefit from, or share in, any profit derived from such transaction.

Whether an Employee has a beneficial interest should be determined on the facts and circumstances of a particular transaction, and not simply on the basis of the legal form of the interest derived from such transaction.

d. Pre – Clearance

All transactions in Financial Instruments by or on behalf of an Employee (directly or through third parties) require pre-clearance by Compliance, unless they fall under an exemption given herein.

A transaction is considered to be effected by or for an Employee (Personal Account Dealing) if

1.	it is for the account of the Employee;

2.	the Employee conducts such transaction for or on behalf of a third party (outside the scope of his or her employment); or

3.	the Employee has a beneficial interest in the transaction as described above.

Pre-clearance applications must contain the following information:

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Name of security,

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Security identification number (ISIN),

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Quantity

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Purchase/sale

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Details of limit order

Pre-clearance requests should be submitted through the pre-clearance system in the Allianz Global Investors Intranet. In case an Employee does not have access to that system, a pre-clearance request can also be addressed by telephone using the dedicated Compliance Service Line (++49 69 24431-4537) or by email (co@allianzgi.com). All pre-clearance applications made by telephone will be recorded. In acknowledging this Code Employees provide their express consent to the recording of conversations held on the Compliance Service Line.

The approval of Compliance for a transaction is valid only for the day of approval. Therefore Employees have to submit their order to their broker or bank by the end of the day of approval (24:00 hrs) at the latest.

e. Disclosure of Transactions

Employees are obliged to provide Compliance with comprehensive information on all relevant Personal Account Dealings. Compliance may only use the information provided in order to monitor Personal Account Dealings and will not make it accessible to other Employees (with the exception of the Employee’s line manager, members of the board, Audit, or the Human Resources Department, in order to identify or inform about conflicts of interest or breaches of these guidelines, in which case the Employee will be duly informed) or third parties unless obliged to do so by any applicable law or regulation, e.g. at the request of regulatory authorities.

Personal Account Dealings must always be executed in the name of the person for whose account they are to be performed. Employees are therefore not permitted to execute transactions for their own account in the name of other individuals, nor may they be involved in third party transactions by means of profit sharing agreements. If Employees are not permitted to trade directly in a financial instrument, neither are they to trade in the same instrument in an indirect way, e.g. in the form of derivatives, ADRs or GDRs.

Employees will disclose to Compliance any bank/brokerage accounts that they maintain in connection with their Personal Account Dealings. To this effect, Employees will use the Account Disclosure Form provided by Compliance. Each Employee must disclose to Compliance any new bank/brokerage account they intend to open for the purpose of dealings in Financial Instruments (no such disclosure is required for current or savings accounts). Compliance reserves the right to refuse such account openings where these are deemed inappropriate.

Employees carrying out transactions related to their own accounts, as defined above, or other such accounts in which they have a beneficial interest or for which they have a proxy will authorise their bank or broker to systematically report any and all transactions in these accounts to Compliance.

Where this is not possible, Employees will report such transactions immediately after execution to Compliance and provide Compliance with an annual list of transactions issued by their bank or broker.

After joining Allianz Global Investors, all Employees have to disclose their bank, brokerage or custody accounts within 10 days to Compliance.

In addition, employees will annually certify their compliance with the provisions contained herein by returning the completed “Annual Certification of Compliance” provided by Compliance.

f. Holding Periods

Personal Account Dealings should focus on long-term investment and not on reaping the benefits of short-term price fluctuations by frequently executing transactions and counter transactions.

As a general rule, a period of 30 calendar days must be observed between purchase and sale of any given Financial Instrument (in accordance with the ’last in, first out’ principle). Accordingly, same-day transactions (i.e. purchase and sale of the same Financial Instrument) are prohibited – irrespective of the volume or the sequence of execution – unless such action is due to extraordinary personal circumstances and has been approved by Compliance in advance. It should be noted that the holding period applies to the underlying of any given Financial Instrument and not to the individual ISIN.

The minimum holding period does not apply in case Financial Instruments are sold at a loss (calculated on market price). However, pre-clearance of such a transaction is still required according to the rules of this Code.

Furthermore, the minimum holding period does not apply to transactions which are not subject to the pre-clearance requirements (“Limited Exempt Transactions”).

Active management by employees of their assets and transactions in derivative instruments do not generally contravene the principle of long-term investment, provided that the above minimum holding period is observed for all transactions.

g. Unauthorized Personal Account Dealings / blackout period

You are not permitted to buy, sell or recommend transactions in Financial Instruments if you have access to price-sensitive information that is not yet in the public domain (Inside Information, please see chapter II.2. for more detailed information). It is also not permitted to execute any Personal Account Dealings in Financial Instruments if you are aware that investment decisions, research reports or investment recommendations concerning these Financial Instruments are being prepared, and such decisions have not been implemented.

Do not place any orders if you are aware that fund orders in the same security have yet to be executed or if you have received notification of certain new fund orders.

Additionally, in order to reduce the potential for conflicts of interest and the potential appearance of impropriety that can arise in such situations, this Code prohibits Investment Professionals from trading in a Financial Instrument during the “blackout period” which is the period of seven calendar days before and after a relevant transaction on behalf of a client account has been executed. With regard to stocks that are included in any of the following indices, this blackout period will not be applied:

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Top 250 constituents (by market capitalization) of the S&P 500 Stock Index,

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TFTSE 100 constituents,

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Hang Seng constituents,

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HDAX constituents,

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Euro Stoxx 50 and Stoxx Europe 50 constituents.

Further blackout periods may be implemented for all employees, including blackout periods on Allianz SE securities or blackout periods triggered by significant client orders.

h. Initial Public Offerings and other similar Offerings

Employees are generally permitted to subscribe to Financial Instruments in the context of an initial public offering (‘IPO’) or other similar offerings (such as secondary offerings, public offerings of debt securities) as long as such a subscription does not result in any potential conflict with our clients’ interests. A potential conflict generally occurs if an Allianz Group affiliate is represented in the consortium of financial institutions handling such offering, or if a client of Allianz Global Investors or of another Allianz Group affiliate is acting as the issuer, or if such subscriptions are being made for

the benefit of a client of Allianz Global Investors or of another Allianz Group affiliate (such as an investment fund).

In addition, employees may not participate in transactions on the ‘Grey Market’, i.e. the purchase or sale of Financial Instruments in the context of IPOs and other similar offerings prior to the official issue allocation.

i. Membership of Investment Clubs

Membership of investment clubs is only permitted with the prior approval of Compliance. This also applies to membership of betting associations or the placing of bets on the performance of Financial Instruments.

j. Disclosure of Proxies

Employees who hold proxies or similar rights with respect to Financial Instruments or accounts of third parties must promptly notify Compliance of such proxies or rights. This also applies to Employees who are acting as executors.

k. Limited Exempt Transactions

Limited Exempt Transactions are transactions in the following Financial Instruments that are not subject to pre-clearance requirements:

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Securities and derivatives on major indices like: AEX, AllOrds, ATX, BEL20, PSI20, CAC40, DAX30, Dow Jones Stoxx 50, Dow Jones Stoxx, Dow Jones Euro Stoxx 50, Dow Jones Euro Stoxx, Dow Jones Industrial Average, FTSE100, FTSE Eurotop 100, FTSE mid-250, HangSeng, HEX20, IBEX35, MDAX, MIB30, NASDAQ 100, Nikkei225, OMX, REX, SMI, S&P 500, S-DAX, Strait-Times, Tec-DAX, TSE35;

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Purchases and sales of affiliated Open-End funds. Affiliated Open-End funds include all mutual funds that are launched or managed by group companies of Allianz Global Investors;

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Purchases and sales of unaffiliated funds. Unaffiliated funds include all mutual funds (incl. ETFs) that are neither launched nor managed by Allianz Global Investors;

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Securities, options, warrants and derivatives on commodities, precious metals, interest rates and currencies;

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Instruments issued by the national governments of the G8 member countries (Germany, France, UK, Italy, Japan, USA, Canada and Russia).

Please Note: These transactions are nevertheless subject to the disclosure requirement.

The minimum holding period does not apply to Limited Exempt Transactions, however, same-day transactions (i.e. purchase and sale of the same Financial Instrument) are prohibited – irrespective of the volume or the sequence of execution – unless such action is due to extraordinary personal circumstances and has been approved by Compliance in advance.

For the avoidance of doubt: Transactions in UK Investment Trusts managed by Allianz Global Investors are subject to pre-clearance.

l. Fully Exempt Transactions

In addition to the foregoing, the following transactions are exempt from all requirements under this section III.1, including pre-clearance, holding periods and disclosure:

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The purchase of life insurance policies,

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The purchase of Allianz SE shares based on employee share programs (but the sale of Allianz SE shares purchased in an employee share program are subject to the requirements of this section III.1.). Please note: Sales of the French Fund (FCPE) invested exclusively in Allianz SE shares acquired in the context of a “Plan d’Epargne Entreprise” (PEE) are subject to pre-clearance and disclosure,Buy / sell transactions executed within the framework of contractually agreed savings and asset accumulation plans / pay-out plans,

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Automated reinvestment of mutual fund distributions

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The exercise of contractual rights (e.g. exercising rights in a convertible bond),

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The exercise of subscription rights (within the limits of shares already held),

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The purchase and sale of money market funds,

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The purchase and sale of money market instruments (i.e. any debt instrument with a residual maturity of less than 12 months),

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The purchase and sale of physical commodities,

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The purchase and sale of currencies,

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Transactions in respect of bank/brokerage accounts where the Employee has given discretionary management authority to an independent third party and does not participate in the management of, or investment decisions for, the account, provided that:

i.	The details of such accounts are disclosed to Compliance.

ii.	The account is managed on the basis that transactions cannot be directed by the respective Employee and the Employee’s authority is limited in giving guidance as to the overall strategy to be applied to the management of the account.

iii.	A copy of the discretionary management agreement is provided to Compliance; and

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Purchases and sales of products offered as part of the “Allianz Fund Invest” program.

m. Allianz Blackout Periods

Trading in Allianz SE securities, those of other listed Allianz Group companies, as well as derivatives based on these shares (collectively referred to as “Allianz securities“) are subject to the same general restrictions as Personal Account Dealings.

Please note that a blackout period is imposed on all Employees of Allianz Global Investors for Allianz securitiess at certain times of the year. Compliance will issue a separate notification of the exact dates during which the lockup applies. This information is also available on the Compliance intranet homepage.

n. Breaches of the Personal Account Dealing Rules

In case of breaches of the Personal Account Dealing rules, Compliance will initially contact the Employee, drawing their attention to the rules, unless the issue constitutes a serious violation.

Serious or repeated violation of the rules governing Personal Account Dealings may result in disciplinary measures being taken and regulatory sanctions being imposed. In case of transactions, which violate these rules, the Employee will be directed to reverse or unwind the transaction. Costs arising from such a transaction will be the responsibility of the Employee and profits arising from such a transaction will be required to be paid to a recognized charity.

Documentation related to personal account dealings (including any authorisation or prohibition in connection with such a transaction) will be kept at least for five years after creation or longer if required by local law.

2. Outside Business Activities

The services and loyalty of Employees should, in the first instance, be directed at Allianz Global Investors, as the company that employs them. Where secondary employment or external transactions, i.e. transactions executed in a non-professional capacity, are undertaken, a conflict of interest may arise.

Secondary employment covers any services provided by the Employee that do not fall within his primary contract of employment with Allianz Global Investors. Remuneration is not the deciding factor. Secondary employment can also apply to freelance, independent or voluntary activities, as well as to activities performed within the framework of a contract for work and services (Werkvertrag). Secondary employment and external transactions include, in particular, financial interests, mandates (e.g. in supervisory, administrative or advisory boards, or as managing directors), and real estate transactions, or similar.

Employees must obtain prior approval from the Human Resources Department before entering into secondary employment. The secondary employment will be approved if it does not affect Allianz Global Investors legitimate interests. Part-time Employees must immediately declare any existing or new forms of secondary employment.

Private real estate transactions that are related to the Allianz Global Investors’ business activities must be disclosed to Compliance.

Employees are not permitted to work for third parties in a private capacity on matters that fall within the scope of Allianz Global Investors’ business, even in if the individual concerned believes that he is acting in the interests of Allianz Global Investors and its clients.

Essays, presentations and other publications in any kind of media which are related either directly or indirectly to the Allianz Global Investors’ business activities require the prior approval of the Employee’s line manager. This regulation shall not affect the Employee’s general obligation to confidentiality.

3. Honorary Posts

Employees must inform their line manager / supervisor, as well as the Human Resources Department and Compliance immediately if they take up any public honorary posts. The Employee may attend to matters relating to public honorary posts to no more than a reasonable extent during his or her normal working hours. The Human Resources department above must be notified without delay of (i) any inability to attend work, together with its expected duration, which might result from the employee’s duties in respect of a public honorary post, as well as of (ii) the decision by the Employee to relinquish his or responsibilities in respect of the public honorary post in question.

Chapter IV: Our Workplace

Our work environment is of utmost importance for all of us. We treat our colleagues fairly and respectfully and collaborate with them based on trust and mutual respect.

1. Diversity

Allianz Global Investors is committed to maintaining an environment where Employees are valued, respected and able to realise their full potential. Allianz Global Investors provides equal employment and advancement opportunities for all individuals regardless of race, gender, national origin, age, disability, sexual orientation or religion. We are committed to developing and sustaining a diverse workplace.

Harassment and discrimination of any form has no place in our workplace. All forms of harassment and discrimination are serious issues that undermine our morale. Consequently, we make every effort to ensure that nobody within Allianz Global Investors is sexually harassed or discriminated against on the basis of race, religion, nationality, gender, origins, political or trade union activities or convictions, or sexual orientation. Such behaviour is unacceptable and will not be tolerated.

2. Use of Company Resources

Resources used at our premises, including materials, equipment, and facilities, are the property of Allianz Global Investors.

Resources may not be modified, sold, loaned, or given away, regardless of condition or value, without proper authorization. The unauthorized removal of materials, equipment, or supplies from our facilities may be regarded as theft.

Each Employee has an obligation to productively use the time paid for by Allianz Global Investors. Work hours should be devoted to activities directly related to our business or to activities properly authorized by the respective supervisor.

Company documents, work process and software owned by a third party must not be illegally copied, distributed or rented out. Third party software may only be used subject to receipt or an appropriate license or similar agreement.

Allianz Global Investors provides electronic communication services, including phones, fax machines, e-mail and the internet, for the conduct of its business, the performance of work-related duties, professional training, and education. Personal use of resources such as phones, computers, software, copy machines, telecommunications resources, mail services stationary, internet etc. is not permitted. Additionally, employees will not

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Display, store, distribute, edit, or record sexually explicit materials using computing and communication systems.

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Use computing or communication systems to infringe copyrights or to download and/or distribute pirated software or data.

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Deliberately propagate viruses throughout computing or communication systems.

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Use computing or communication systems to perpetrate or assist in any fraudulent or dishonest activity.

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Use computing or communication systems to distribute defamatory or discriminatory statements, or otherwise inflict harm on fellow employees or third parties.

3. Donation and Sponsorship

Corporate Citizenship is part of our business culture at Allianz Global Investors. In order to live

up to this self-conception, we provide – amongst other things – financial support for cultural and charitable organizations and events.

The Donation and Political Contributions Policy attached as Module 5 to this Code of Ethics specifies the applicable procedures to be observed by all Employees regarding donations and sponsorships.

Chapter V: Communications

The objectives of all communications activities are to enhance and protect the image of Allianz Global Investors as well as the Allianz Group. Allianz Global Investors strives to portray an accurate, credible and appropriate image of its businesses to Employees, customers, business partners and the public in general and to be consistent in terms of core messages and style worldwide. Therefore, this section covers all medium of communication (e.g. e-mail, facsimiles, letters and telephone). Regardless of the method of communication, the authorization, content, and distribution procedures set forth herein must be followed.

1. Communication with the Media

Communication with the media should be only made with the prior authorization of the Communications Department. All internal and external communication is based on the “Communication Standards and Guidelines“, the “Code of Conduct” of the Allianz Group, as well as on the “Internal Communications Policy of Allianz Global Investors“. Inquiries from journalists or individuals who are researching articles for print or electronic media have to be channelled via the Communications Department. All contact with the media that could result in coverage should occur in the presence of a communications professional.

2. Communications with Regulatory Authorities or Investigatory Bodies

Generally, all communications with regulatory authorities and investigatory bodies is the responsibility of Legal and Compliance. If you receive a request for information from any regulator, investigator or external auditor please inform your line manager and contact Legal and Compliance promptly.

3. Inspections

In the event that the regulatory authorities or investigatory bodies have ordered an inspection on the premises of Allianz Global Investors, Legal and Compliance must be informed immediately, irrespective of whether the investigation is focused on Employees, clients or (a specific department of) Allianz Global Investors. Legal and Compliance serve as the sole and central point within Allianz Global Investors for the coordination of any inspection.

In particular, Legal Department and Compliance will use best endeavours to ensure that Employees:

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make themselves readily available to the regulatory authority’s inspection team;

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on receipt of a proper request by the regulatory authority, produce to its inspection team any documents, files, records in their possession or control;

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give the regulatory authority’s inspection team access, at all times, to the relevant premises;

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to the extent that they are properly requested by the regulatory authority, permit the latter’s inspection team to copy any documents, files, records in the Department’s premises or elsewhere at Allianz Global Investors’ expense; and

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answer truthfully and fully all questions put to them by the regulatory authority’s inspection team.

4. Comments regarding Allianz

Employees may not make public comments regarding or relating to Allianz or Allianz Global Investors in any way without the prior authorisation from the respective Communications Department. The Communications Department will coordinate the authorisation process with Allianz Group Communications, if necessary. The Communications Department also needs to authorize any other comments or statements that, due to their nature and even though not directly relating to Allianz or Allianz Global Investors, could have an impact on the overall perception or reputation of Allianz or Allianz Global Investors.

Public communication not made in your capacity as an Employee should be clearly identified as being

your personal opinion and not necessarily representing the view of the Allianz Global Investors.

5. Social Media

Allianz Global Investors expects its Employees to use good judgement and take care in their communications outside the workplace in social websites to avoid negatively affecting our reputation or of its Employees. Social websites include blogs, social networks and other web-based communications.

The Employee Social Networking Policy attached as Module 6 to this Code of Ethics outlines the respective procedures to be observed by all Employees.

Chapter VI: Registration and Licensing

All employees are obliged to adhere to the registration and licensing regulations of the respective supervisory authorities and stock exchanges before performing financial services or ancillary financial services at home or abroad, including trading.

Individual registration or licensing may be required for the following activities (which serve merely as an example):

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Participation in securities trading, stock exchange trading or trading on an electronic exchange or off-exchange system;

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Investment or client advisory services;

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Portfolio management;

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Publication of research.

In some countries, registration or licensing is only required if financial services or ancillary financial services are performed within the country itself; in other countries, registration or licensing is required even if financial services or ancillary financial services are performed from abroad.

Please contact Legal and Compliance if you are in any doubt as to whether and to what extent registration or authorisation is required.

Chapter VII: Speak Up

Being able to speak up within Allianz Global Investors and raise concerns about any situation that may violate our core values, policies and procedures or laws and regulations, is an important part of our culture. Allianz Global Investors is deeply committed to conducting its business with the highest ethical and legal standards, and when we raise our concerns promptly, we help Allianz Global Investors fulfill that commitment by giving it an opportunity to consider such concerns carefully and address them properly. With that in mind and to help reinforce a “Speak Up” culture within our company, the global “Speak Up” Reporting and Anti - Retaliation Policy (the Policy) has been adopted by Allianz Global Investors.

All employees are asked to immediately report good faith concerns about any conduct they reasonably believe to be illegal, fraudulent, or unethical. Allianz Global Investors welcomes your oncerns that have a relationship to our business activities, whether that conduct occurs within Allianz Global Investors, involves one of our consultants, vendors, contractors, sub-contractors, bankers, or involves any other party having a business relationship with Allianz Global Investors.

Examples of conduct to immediately report include:

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Potential violations of applicable laws, rules and regulations;

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Fraudulent, illegal, or unethical acts involving any aspect of our business;

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Material misstatements and/or false statements made in regulatory filings, internal books and records, financial reports, or client records and reports;

•

Activity that is harmful to clients;

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Material deviations from required controls and procedures that safeguard our company and its clients, including violations of our compliance policies;

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Any accounting matter or any act or failure that could constitute (1) a potential violation of any law, rule or regulation, or (2) a potential violation of any registered investment fund policies or procedures, including compliance policies;

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Bribery;

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Theft or embezzlement of company resources; and

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Retaliatory conduct.

Employees may submit complaints, concerns, and information regarding potential unethical, fraudulent or illegal conduct to their immediate supervisors, Chief Compliance Officer or the General Counsel Europe/ Global General Counsel. Of course complaints can also be reported .. via the intranet-based application that guarantees anonymity and is accessible on the Europe Compliance Portal. However, in case employees decide to disclose their identity, this information will be kept confidential.

Allianz Global Investors is committed to reviewing all reported concerns, conducting proper, fair and thorough investigations tailored to the circumstances, and taking appropriate remedial and concluding steps as warranted. All action taken by Allianz Global Investors in response to a concern will necessarily depend on the nature and severity of the concern. This may include initial inquiries and fact-gathering to decide whether an investigation is appropriate and, if so, the form and scope of the investigation. Allianz Global Investors complies with law in conducting investigations, and expects that employees will cooperate with and provide truthful information to facilitate an effective investigation.

Furthermore, Allianz Global Investors will not tolerate retaliation, harassment or reprisals of any kind towards an employee who, in good faith reports a violation or suspected violation of our Code or raises a concern about a policy or practice of Allianz Global Investors. Employees who believe that they have been subjected to reprisal or retaliation that violates the statements above should immediately notify the European or Global General Counsel, or file a complaint. Any employee who unlawfully discriminates or retaliates against another employee as a result of his or her protected actions as described may be subject to disciplinary action, up to and including termination.

However, employees who file reports or provide evidence that they know to be false or without a reasonable belief in the truth and accuracy of such information will not be protected by the Policy mentioned above and may be subject to corrective action up to and including immediate termination.

Chapter VIII: Training, Certification of Compliance & Supervision of the Code of Ethics

Compliance provides training regarding the obligations set forth in this Code to all employees at least on an annual basis either in person or via an online-based tool. New hires will be trained within the first three months after joining the company in a face-to-face training session. Participation in the training is mandatory for all Employees. Records of attendance are kept.

All Employees must submit the Certification of Compliance on an annual basis. This serves to confirm that they have acknowledged and adhered to the Compliance rules and guidelines relating to the past year.

Compliance oversees compliance with this Code. Consequently, violations of this Code will be reviewed by Compliance. Employees who violated the Code may face disciplinary, supervisory, civil or criminal sanctions.

Allianz Global Investors shall hold all information in connection with reviews under, and violations of, this Code strictly confidential, to the extent permitted by law. However, compliance with this Code and violations of it will be disclosed to the management of Allianz Global Investors.

To ensure that the Code remains current, Compliance shall review and revise it as appropriate.

☐ I do not maintain any account for the purpose of personal account dealings. Should these circumstances change, I will promptly notify Compliance.

☐ I maintain the following account(s) for the purpose of personal account dealings which are subject to pre-clearance and disclosure requirements pursuant to Chapter III.1. of the Code of Ethics (please use additional sheets if necessary):

☐ I do not have a proxy which is subject to the disclosure requirements set out in Chapter III.1. of the Code of Ethics. Should these circumstances change, I will promptly notify Compliance.

☐ I have a proxy in relation to the following account(s) (please use additional sheets if necessary):

☐ I have arranged for AllianzGI’sCompliance Department to receive duplicate transaction statements for the above mentioned account(s) directly from the bank(s) at which the account(s) is/are maintained to the following address: Allianz Global Investors GmbH, Compliance, Bockenheimer Landstr. 42-44, D-60323 Frankfurt/Main, Germany.

☐ As the bank(s) maintaining my account(s) cannot automatically provide duplicate transaction statements, I agree to provide AllianzGI’s Compliance Department with such statements. I will also provide AllianzGI’s Compliance Department with a summary, issued by the bank(s) maintaining my account(s), of the previous year’s transactions in relation to this/these account(s) (within one month following receipt from the bank(s)).

I certify that the above statements are complete and correct and I will promptly notify Compliance about any changes.

Allianz Global Investors GmbH has established a branch in Italy, which operates under the corporate name of Allianz Global Investors GmbH, Sede Secondaria e Succursale di Milano (the ‘Italian Branch’).

For the conduct of its activities, the Italian branch is subject to the supervision of the Bank of Italy.

The Italian Branch has its registered office at Via Durini 1, 20122 Milan, Itlay.

The Italian Branch is included in the list attached to the Register of SGRs according to art. 35 of Lgs. D. 58/98, held by Bank of Italy, and is authorised to carry out the following activities:

Alberto D’Avenia is the Head of the Italian Branch and his appointment is duly notified to the CONSOB.

Articles 27, 28 and 34 of CONSOB Regulation 16190/2007 (Regolamento recante norme di attuazione del decreto legislativo 24 febbraio 1998, n. 58 in materia di intermediari, 29.10.2007), Article 34-octies 29 of CONSOB Regulation 11971/1999 (Regolamento recante norme di attuazione del decreto legislative 24 febbraio 1998, n.58 in materia di emittenti, 14.05.1999) and Article 29 of the Bank of Italy/CONSOB Regulation of 29.10.2007 (Regolamento della Banca d’Italia e della CONSOB in materia di organizzazione e procedure degli intermediari che prestano servizi di investimento o di gestione collettiva del risparmio, 29.10.2007) incorporate the conduct of business rules applicable to the Italian Branch in connection with promotional materials which are issued from Italy or which may be received in Italy.

No private placement exemption exists in Italy with respect to unregulated investment funds. No active distribution of promotional materials whatsoever is thus permitted for any fund which is not registered for distribution in Italy. Unregistered funds cannot be marketed, offered or promoted to prospective investors residing in Italy, although unsolicited and autonomous investment decisions by such investors are permitted.

INFORMATION NOTICE PURSUANT TO ARTICLE 13 OF LEGISLATIVE DECREE N. 196 OF 30 JUNE 2003

You can exercise the above mentioned access rights writing to Allianz Global Investors GmbH, Italian branch, Via Durini 1, 20122 Milano.

Finally, in relation to point (i) for individuals closely connected with the undersigned (as defined in Cap.III.1.a - Extension of the definition of personal transactions), and (ii) for individuals who are the owners of the accounts with respect to which I have a proxy, I confirm that I have requested and obtained the prior consent of such individuals for the purpose of dissemination of the data on the person and account to Allianz Global Investors, except that, to the extent permitted under Italian law, the provisions of this Notice shall also apply to such individuals.

This information is therefore also directed toward the individuals closely connected with the employee and to the individuals who are the owners of the accounts with respect to which the employee has a proxy, to which therefore it is delivered, expressing below the consent or not to the processing of data.

Consequently, I/ we agree, each within its respective jurisdiction, to the data processing of the employee and of the accounts of the undersigned - as well as those of the individuals closely connected with the employee, and those of the individuals who are or holders of the accounts with respect to which the employee has a proxy in accordance with the provisions of the Legislative Decree and with the information contained in this communication.

Allianz Global Investors GmbHhas established a branch in the Netherlands, which operates under the corporate name of Allianz Global Investors GmbH, Netherlands Branch (the “Netherlands Branch”). For the conduct of its activities, the Netherlands Branch is subject to the supervision of the Autoriteit Financiële Markten (AFM).

The Netherlands Branch has its registered office at Coolsingel 139, 3012 AG Rotterdam.

The Netherlands branch is listed on the AFM’s Register of EU investment firms, and is authorised to carry out the following investment services in the Netherlands:

Robert Koopdonk is Head of the Netherlands Branch, and his appointment has been duly notified to the AFM.

Allianz Global Investors GmbHhas established a branch in Spain, which operates under the corporate name of Allianz Global Investors GmbH, Sucursal en España (the ‘Spanish Branch’). For the conduct of its activities, the Spanish branch is subject to the supervision of the Comisión Nacional del Mercado de Valores (CNMV).

The Spanish Branch has its registered office at Calle Ramírez de Arellano 35, 4ª planta, 28043 Madrid.

The Spanish Branch is listed on the CNMV’s Register of EU investment firms, and is authorized to carry out the following investment services in Spain:

Marisa Aguilar is the Head of the Spanish branch and her appointment has been duly notified to the CNMV.

In complying with the rules set out above in Chapter II. 2., the employees of the Spanish branch must be aware that, according to the Spanish law:

The provisions of the preceding paragraph will also apply to financial instruments with regard to which a request has been made for admission to trading on a regulated market or multilateral trading facility.

In relation to futures or options on commodities, Inside Information will mean information of a precise nature which has not been made public, relating directly or indirectly, to one or more such futures or options and which users of markets on which such futures or options are traded would expect to receive in accordance with accepted market practices in those markets.

Preparing or carrying out transactions conducted with a view to discharging an obligation that results from an agreement concluded before the employer possessed insider information, is not subject to the prohibition laid down in the previous paragraph.

The aforementioned prohibitions will apply to any person who possesses Insider Information when that person knows, or ought to have known, that the information possessed is insider information.

INFORMATION NOTICE PURSUANT TO ARTICLE 5 OF THE SPANISH ORGANIC LAW 15/1999 ON DATA PROTECTION

You can exercise the above mentioned access rights writing to Allianz Global Investors GmbH, Sucursal en España, Calle Ramírez de Arellano 35, 4ª planta, 28043 Madrid.

I further confirm that I am aware that refusing to provide employee and account data, or to authorize its processing, will prevent AllianzGI to monitor personal account dealings, and may therefore constitute grounds for disciplinary action.

Consequently, I hereby give my consent for the processing of my employee and account data according to the provisions of the Handbook and the above information notice.

Allianz Global Investors (Switzerland) Ltd. – a wholly owned subsidiary of Allianz Global Investors GmbH – has been granted a distribution license by FINMA (www.finma.ch) as well as a license to provide portfolio management services for pension assets by OAKBV (Oberaufsichtskommission berufliche Vorsorge).

Allianz Global Investors (Switzerland) Ltd. has to comply with the self-regulatory provisions of the Swiss Funds Association.

Allianz Global Investors (Switzerland) Ltd. has its registered office at Gottfried-Keller-Straße 5, CH-8001 Zurich.

Allianz Global Investors (Switzerland) Ltd. is listed on the FINMA’s List of authorized distributors of collective investment schemes, and is authorised to carry out the following investment services:

Allianz Global Investors (Switzerland) Ltd. is listed on the OAKBV`s List of authorized portfolio managers, and is authorized to provide portfolio management services for pension assets.

As members of the Board of Directors of Allianz Global Investors (Switzerland) Ltd. Tobias Pross, Michael Peters, Dr. Walter Ohms and Marcel Salzmann have been appointed.

INFORMATION NOTICE PURSUANT TO ARTICLES 6, 7A AND 12 OF THE SWISS FEDERAL ACT OF 19.6.1992 ON DATA PROTECTION AND ARTICLE 328B OF THE CODE OF OBLIGATIONS OF 30.3.1911

Consequently, I hereby give my consent for the processing of my employee and account data according to the provisions of the Handbook and the above information notice.

Allianz Global Investors GmbH has established a branch in the United Kingdom, which operates under the corporate name of Allianz Global Investors GmbH, UK Branch (the ‘United Kingdom Branch’). For the conduct of its activities, the United Kingdom branch is subject to the supervision of the Financial Conduct Authority (FCA).

The United Kingdom Branch has its registered office at 199 Bishopsgate, London EC2M 3TY.

The United Kingdom Branch is listed on the FCA’s Register of EU financial services firms and is authorized to carry out the following investment services in the UK:

Deborah Zurkow is Head of the United Kingdom Branch and her appointment has been duly notified to the FCA.

The FCA has 11 Principles for Businesses which set out the fundamental obligations of all firms under the regulatory system and 7 Statements of Principle which an Approved Person must observe when carrying out Accountable Function(s). All FCA Rules relate to one or more of these Principles, which should be borne in mind at all times.

Addendum F – Members of Staff associated with Allianz Global Investors’ US Business

This Addendum applies to all members of staff associated with Allianz Global Investor’s US Business. The Compliance Department will inform you if you are classified as an “Associated Person”.

Under SEC Rule 204A-1, Allianz Global Investors’ Associated Persons are required to provide a complete report of securities holdings at the time the person becomes an Associated Person and at least once a year thereafter. The information supplied must be current as of a date not more than 45 days prior to the individual becoming an Associated Person (initial report) or prior to the date the report is submitted (annual report).

Within 10 calendar days of becoming an Associated Person (either following the commencement of employment with the company or due to a change in your classification), you are required to complete an initial report of personal securities holdings and accounts and submit the report, along with any relevant documentation as requested by the Compliance Department.

On an annual basis, Associated Persons are required to provide information regarding their securities holdings and accounts. For the avoidance of doubt, if you open a new account, you must promptly notify Compliance of the new account and provide the account details.

The Compliance Department will provide you with notification of and instructions pertaining to your initial and annual reporting and other certification requirements.

All communications and written or electronic materials maintained by Allianz Global Investors must be appropriate and in good taste. Email systems are provided to assist and facilitate business communication. All use of email must be consistent with the policies prohibiting a hostile work environment. All messages that contain statements or materials that are discriminatory, offensive, defamatory, sexual, pornographic, illegal, or harassing in nature are strictly forbidden. Statements that would be inappropriate in a memorandum or letter may not be written in an email. All information transmitted, received, stored, or

otherwise contained in systems made available by Allianz Global Investors to its Associated Persons or files is the property of Allianz Global Investors and may be accessed, decrypted and examined by Allianz Global Investors at any time.

Associated Persons shall retain those emails necessary to ensure compliance with the record retention requirements under the U.S. Federal Securities Laws. Retention of such email documents is the requirement of the originator of such emails and shall be archived for at least seven years on the drive designated for his/her official department (where appropriate, the emails shall be printed in hardcopy and placed in the corresponding hardcopy files).

As appropriate, Allianz Global Investors’ Compliance Department may review on a spot-check or other basis that emails are being archived on the relevant drive.

Allianz Global Investors engages in the retention and monitoring of electronic mail messages (“email”) sent or received by Associated Persons. Such employees are informed that their emails are the property of Allianz Global Investors and such employees express their consent. In the course of monitoring emails, Allianz Global Investors periodically takes random emails from such employees and conducts specific inquiries. The emails are scanned based on key words that are a reasonable set of words whose inclusion in an email could potentially disclose an act that may be in violation with U.S. Federal Securities Law. This list of key words is kept confidential by the Compliance Department and is not shared with employees outside of the department, including senior management. Select people are those that have been identified as being in the position to violate U.S. Federal Securities Law, and may include, senior staff, trading personnel, portfolio managers, analysts, sales and customer service personnel, and select legal and compliance personnel. IT and office services personnel are excluded from this list as they do not participate in the preparation of books and records.

Generally, the sampling of emails for review shall occur on a weekly basis. Based on Allianz Global Investors concerns, from time to time additional reviews may be performed as may be deemed necessary. The monitoring is conducted by Compliance, as part of Allianz Global Investors’overall supervisory responsibilities.

Allianz Global Investors encourages employees to exercise their rights as citizens to participate in the political process. However, Contributions¹ (financial or non-financial) made to certain political campaigns may raise potential conflicts of interest because of the ability of certain officials to influence decisions to award business to Allianz Global Investors or appoint officials who have such influence. In addition, U.S. state and U.S. federal laws and regulations may restrict the ability of Allianz Global Investors and its employees, including employees’ Immediate Family Members, to make Contributions, coordinate Contributions or Solicit any person or political action committee (“PAC”) to make Contributions. For example, Rule 206(4)-5 promulgated under the Investment Advisers Act of 1940 (“Rule 206(4)-5”) would prohibit Allianz Global Investors from receiving compensation for services rendered to a Government Entity for two years after a Contribution violating Rule 206(4)-5 was made.

Because of the serious consequences of violating a political contribution law or regulation, Allianz Global Investors has adopted this policy to monitor and restrict Contributions by Allianz Global Investors’ employees (including employees’ Immediate Family Members). For the avoidance of doubt, this policy refers to political campaigns in the United States of America only.

Public offerings give rise to potential conflicts of interest that are greater than those present in other types of personal securities transactions since such offerings are generally only offered to institutional and retail investors who have a relationship with the underwriters involved in the offering. In order to preclude any possibility of an employee profiting from his/her position with Allianz Global Investors, the following rules apply to public offerings.

You are prohibited from investing in an initial public offering (IPO) of Securities, whether or not Allianz Global Investors is participating in the offering on behalf of any funds or accounts. An IPO (also referred to as a “new issue” under FINRA Rule 5130) means an offering of securities registered under the Securities Act of 1933 (“Securities Act”), the issuer of which, immediately before the registration, was not subject to the requirements of Section 13 or 15(d) of the Exchange Act to file public periodic reports with the SEC.

Note: This prohibition does not apply to an investment in an IPO by your spouse, provided the investment pertains to your spouse’s firm of employment, subject to review and approval by your Compliance Department.

You are required to receive approval from your local Compliance Department prior to investing in a secondary offering of Securities. A secondary offering involves the issuance of new stock for public sale from a company that has already made its IPO. Secondary offerings are offered pursuant to a prospectus, similar to IPOs. Your local Compliance Department will determine whether the proposed transaction presents a conflict of interest with any of the funds or client accounts. Your request will be denied if the funds and/or clients are participating in the offering.

Employees are permitted to purchase equity and equity-related securities in rights offerings if the opportunity to purchase is extended equally to all holders of the company’s stock.

For purposes of this section, a “private placement” is the sale of securities to a relatively small number of select investors as a way of raising capital. Private placement is the opposite of a public issue, in which securities are made available for sale on the open market. Although private placements are subject to the Securities Act, the securities offered do not have to be registered with the SEC if the issuance of the securities conforms to an exemption from registration as set forth in the Securities Act and SEC rules. Investments in hedge funds and private investments in public equities (“PIPEs”) are examples of private placements.

Acquisitions of Securities in a private placement are subject to special pre-clearance procedures. Please contact Compliance for approval prior to any participation in private placements.

Note: You must also provide independent confirmation of your private placement investment to your Compliance Department upon completion of your investment.

If you have acquired Beneficial Ownership of Securities in a private placement, you must disclose your investment when you play a part in any consideration of an investment by a fund or client account in the issuer of the Securities, and any decision to make such an investment must be independently reviewed by your business unit’s CIO or a portfolio manager who does not have Beneficial Ownership of any Securities of the issuer.

Allianz Global Investors GmbH a ouvert une succursale en France qui exerce ses activités sous la dénomination sociale de « Allianz Global Investors GmbH, succursale française » ou « Allianz Global Investors, France branch » (ci-après la « succursale française »). La succursale française est soumise au contrôle de l’Autorité des Marchés Financiers (AMF) dans le cadre de la gestion de ses activités.

Le siège social de la succursale française est situé 3 boulevard des Italiens 75113 Paris cedex 02.

La succursale française est inscrite au registre des sociétés d’investissement européennes de l’AMF et est autorisée à effectuer les services d’investissement suivants en France :

Amine Benghabrit et Michael Peters sont les co- dirigeants de la succursale française.

II DISPOSITIONS CONCERNANT L’USAGE DES POSTES DE TRAVAIL, DES MATERIELS ET DES DONNEES

Il est précisé que les dispositions contenues au Règlement intérieur concernant l’usage des postes téléphoniques ainsi que l’utilisation de la messagerie et d’Internet continuent à s’appliquer nonobstant le Titre IV – 2. Utilisation des ressources appartenant à l’entreprise du présent Code de déontologie.

Le système d’alerte disponible via l’application basée sur l’Intranet n’est pas à destination des salariés de la succursale française d’Allianz Global Investors. Ainsi, tout salarié de la succursale française d’Allianz Global Investors souhaitant soumettre une plainte, une précoccupation ou une information est invité à suivre la voie hiérarchique classique ou à contacter l’équipe Conformité (via le Responsable de la Conformité européen) ou le « General Counsel » Europe ou Monde, conformément à la Section applicable du Code de déontologie, et à ne pas utiliser ce système d’alerte.

Allianz Global Investors GmbH has established a branch in Belgium, which operates under the corporate name of Allianz Global Investors GmbH, Frankfurt am Main, Zweigniederlassung Belgien (the ‘Belgium Branch’).

For the conduct of its investment fund distribution activities, the Belgium Branch is subject to the supervision of the Financial Services and Markets Authority (FSMA).

The Belgium Branch has its registered office at Rue de Laeken 35, 1000 Brussels, Belgium.

The Belgium Branch is authorised to carry out the following investment services:

Stépahnie Dupuis is the Head of the Belgium branch, and her appointment has been duly notified to the FSMA.




Name (first name; surname)				Company / Location



Department				Personnel Number


1 Integrity		A firm must conduct its business with integrity.

2 Skill, care and diligence		A firm must conduct its business with due skill, care and diligence.

3 Management and Control		A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.

4 Financial Prudence		A firm must maintain adequate financial resources.

5 Market conduct		A firm must observe proper standards of market conduct.

6 Customers’ interests		A firm must pay due regard to the interests of its customers and treat them fairly.


7 Communications with clients		A firm must pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading.

8 Conflicts of interest		A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client.

9 Customers: relationships of trust		A firm must take reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgement.

10 Clients’ assets		A firm must arrange adequate protection for clients’ assets when it is responsible for them.

11 Relations with regulators		A firm must deal with its regulators in an open and co-operative way, and must disclose to the FCA appropriately anything relating to the firm of which the FCA would reasonably expect notice.