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This Independent Trustee Code of Ethics (the “Code”) establishes rules that govern certain activities of the Trustees who are not “interested persons” under the Investment Company Act of 1940 (the “Independent Trustees”) of the registered investment companies listed above (the “Funds”). The Funds and American Century Investment Management, Inc., the Funds’ investment manager (the “Advisor”), have adopted a separate Code of Ethics that governs Advisor employees, officers, and directors and Fund officers and interested trustees (the “Advisor Code”). The Advisor Code and this Code are together intended to satisfy the requirements of Rule 17j-1 under the Investment Company Act of 1940 (the “Rule”).

The purpose of this Code is to help ensure that the Independent Trustees place the interests of the Funds and their shareholders ahead of their personal interests and comply with their fiduciary obligations under applicable law, which prohibits investing based on material nonpublic information (“MNPI”) from any source, including from service as an Independent Trustee. Independent Trustees are expected to abide by the highest ethical and legal standards in conducting their personal securities transactions. This Code, however, does not address every ethical issue that might arise. It is important for the Independent Trustees to be sensitive to investments or other activities that may raise ethical issues or could result in a violation of the Code.

The Advisor Code contains provisions requiring preclearance and reporting of personal securities transactions by certain covered persons, including those Advisor employees designated under the Rule as “Access Persons” of any Fund managed by the Advisor. Except as noted in Paragraph II.B. below, Independent Trustees are generally not required to preclear or report personal securities transactions.

Independent Trustees may be subject to certain reporting requirements applicable to Access Persons and required to report personal securities transactions in a Security (as defined in the Appendix hereto) under the Rule if they knew or should have known about the Funds’ dealings in the same Security (a “Reportable Security”). An Independent Trustee with such knowledge will be required to submit a report with respect to a Reportable Security if BOTH of the following conditions are satisfied:

(1) the Independent Trustee becomes aware that the Reportable Security was purchased or sold by one or more Funds or is currently being considered for purchase or sale by one or more Funds; and

(2) the Independent Trustee executes a transaction in the Reportable Security during the 15-day period immediately before or after any date on which the Independent Trustee knew or should have known that (a) a Fund purchased or sold or (b) a Fund or its investment adviser/subadviser considered purchasing or selling the Reportable Security (the “Reporting Period”).

An Independent Trustee that is subject to these reporting requirements must promptly provide a report to the Funds’ Chief Compliance Officer of any transaction in the Reportable Security during the Reporting Period.

For purposes of this Section II.B., “knew or should have known” is intended to include only specific direct knowledge, not general awareness based on a Fund’s investment objective, investment strategy, benchmark, or underlying index, and “Reportable Security” is intended to include any put, call, straddle, option, privilege, derivative, or similar instrument specifically related to a Reportable Security.

The obligations in this Code also apply to personal securities transactions by family members living in an Independent Trustee’s home, as well as accounts for which the Independent Trustee or a family member living in their home has investment direction or beneficial ownership. No reporting is required under the Code in respect of any account for which an independent third party is contractually authorized to have full investment discretion without prior consent from or consultation with the Independent Trustee or a family member living in their home. Similarly, no report is required with respect to transactions pursuant to an automatic investment plan in place prior to the acquisition of information referenced herein.

A document requesting an exemption and containing the salient facts should be provided to the counsel to the Independent Trustees and the Funds’ Chief Compliance Officer. Counsel to the Independent Trustees and the Chief Compliance Officer will evaluate the request and present it to the Board of Trustees at a regular or special meeting, if determined to be appropriate in their discretion.

In considering the request, the Board may grant an exemption if it unanimously determines that, if granted, the exemption will not result in an improper personal benefit and is consistent with the achievement of the objectives of this Code.

All MNPI received in the course of service as an Independent Trustee (including without limitation MNPI regarding Fund Security transactions, actual or contemplated) is confidential and is not to be used for any purpose other than service as an Independent Trustee. This does not apply to information which has already been publicly disclosed by the Funds or the Advisor.

Similarly, if an Independent Trustee serves as a director, trustee, officer, consultant, or employee of, or has a similar affiliation with, another business entity that issues publicly traded securities, the Independent Trustee shall not share any MNPI regarding that entity with the Advisor, the Advisor’s representatives, or any other Independent Trustee.

Independent Trustees have a fiduciary duty to avoid acting on any matters presenting a conflict of interest that could arise from service as a director, trustee, officer, consultant, or employee of, or from a similar affiliation with, another business entity and to avoid acting in the presence of such a conflict, until the matter is disclosed to the other Independent Trustees, who will determine whether or not the conflict could reflect adversely on the trustee's independence or would compromise the interests of the Funds’ shareholders.

If an Independent Trustee is unsure whether a matter could present a conflict of interest, the Independent Trustee should consult with counsel to the Independent Trustees or the Board Chair.

The Funds’ Chief Compliance Officer will report any potential violation of this Code to the Board of Trustees, which will investigate and, if a violation is found, make a recommendation to the Board as to the action, if any, that should be taken in response thereto.

At least annually, the Funds’ Chief Compliance Officer shall 1) report to the Board any material exceptions that arose under this Code since the last report not previously reported, including but not limited to information related to any material violations of this Code and actions taken as a result of such violations; and 2) represent to the Board that the Funds maintain, in connection with this Code, procedures reasonably designed to prevent violations of the federal securities laws.

On an annual basis, Independent Trustees will be asked to complete a questionnaire detailing business affiliations, which will be furnished to counsel to the Independent Trustees and to the Advisor. At that time, Independent Trustees will be requested to represent that they have reviewed this Code of Ethics and have complied in all material respects with its provisions. If an Independent Trustee’s business affiliations materially change during the year, such Independent Trustee shall promptly notify counsel to the Independent Trustees and the Advisor.

A “Security” includes a great number of different investment vehicles. However, for purposes of this Code of Ethics, "Security" includes any of the following:

stock, (including stock acquired in private placements and restricted stock in nonpublic companies received through an employee stock ownership program),

any put, call, straddle, option, future, or privilege on any security or other financial instrument (including a certificate of deposit) or on any group or index of securities (including any interest therein or based on the value thereof), including stock options received from and employer or through a retirement plan,

any certificate of interest or participation in, temporary or interim certificate for, receipt for, guarantee of, future on or warrant or right to subscribe to or purchase, any of the foregoing.