A message from our CEO
Standards of conduct ....................................................
Who is subject to the Code of Ethics?.............................
Personal investing ........................................................
Gifts and entertainment................................................
Outside activities ...............................................................
Client confidentiality ....................................................
How we enforce our Code of Ethics...............................
Exceptions from the Code of Ethics ..............................
Closing..........................................................................
.
WHICH INVESTMENT ACCOUNTS MUST BE REPORTED?
AND
WHAT ARE THE REPORTING RESPONSIBILITIES FOR ALL PERSONNEL?
WHAT ARE THE PRECLEARANCE RESPONSIBILITIES FOR ALL PERSONNEL?
Please note that preclearance approval does not alter your responsibility to ensure that each personal securities transaction complies with the general standards of conduct, the reporting requirements, the restrictions on short-term trading,or the special rules for investment professionalsset out in ourCode of Ethics.
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WHAT ARE THE ADDITIONAL REQUIREMENTS FOR INVESTMENT PROFESSIONALS?
INVESTMENT PROFESSIONAL BLACKOUT PERIODS 
|
14 calendar days before or after |
later of |
one calendar year |
90 calendar days |
|
SHORT SALES BY AN INVESTMENT PROFESSIONAL
ACCEPTING GIFTS 
ACCEPTING BUSINESS MEALS 
ACCEPTING ENTERTAINMENT OPPORTUNITIES 
LODGING AND AIR TRAVEL 
SOLICITING GIFTS, ENTERTAINMENT OPPORTUNITIES, OR CONTRIBUTIONS 
SOURCING ENTERTAINMENT OPPORTUNITIES 
No Preclearance or Reporting Required:
Reporting of Securities Transactions Required (no need to preclear and not subject to the 60-day holding period):
Preclearance and Reporting of Securities Transactions Required:
Prohibited Investments and Activities:
This appendix is current as of 21 September 2022 and may be amended at the discretion of the Ethics Committee.
1A list of funds advised or subadvised by Wellington Management ("Wellington-Managed Funds") is available online via the Code of Ethics System. However, you remain responsible for confirming whether any particular investment represents a Wellington-Managed Fund.
2If the instrument is unrated, it must be of equivalent duration and comparable quality.
