Exhibit (p)(2)

HSBC Global Asset Management (USA) Inc. (“AMUS”)

Code of Ethics Policy & Procedures

Version 10

January 2024

No part of this publication may be reproduced, stored in a retrieval system, or transmitted, on any form or by any means, electronic, mechanical, photocopying, recording, or otherwise, without the prior written permission HSBC Global Asset Management (USA) Inc.

Table of Contents

HSBC Global Asset Management (USA) Inc. (“AMUS”) is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) to engage in investment advisory business with U.S. investors, and to provide investment advisory services to SEC Registered Investment Companies (“RIC”), i.e. U.S. Mutual Funds: the HSBC Funds.

SEC Rule 204A-1 (the “Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”), as amended, requires all registered investment advisers to establish, maintain and enforce a written code of ethics that sets forth standards of business conduct and that require compliance with Federal Securities laws. This document contains the AMUS Code of Ethics Policy and Procedures (the “Code”) for AMUS and its Covered Persons (defined). The Code is based on the principle that AMUS and its officers, directors, and employees have a fiduciary duty to place the interests of clients first and to conduct all personal securities transactions in accordance with the requirements of the Code, in compliance with federal securities laws and in a manner that avoids actual or potential conflicts of interest and does not otherwise take inappropriate advantage of a client relationship or abuse a position of trust and responsibility in respect of a client. The Code is supplementary to Covered Persons’ obligations to comply with HSBC Group and AMUS policies and procedures, as applicable.

This Code applies to all Access Persons of AMUS (defined below), referred to throughout as Covered Persons.

AMUS’s supervised persons includes any employees, partners, officers, directors (or other persons occupying a similar status or performing similar functions) as well as any other persons that provide advice on the investment adviser’s behalf and are subject to the investment adviser’s supervision and control.

An access person is a supervised person who has access to non-public information regarding clients’ purchase or sale of securities, is involved in making securities recommendations to clients or who has access to such recommendations that are non-public. A supervised person who has access to non-public information regarding the portfolio holdings of any reportable fund (i.e. HSBC Funds) is also an access person.

The following personnel are considered to be Access Persons and therefore subject to the Code:

Personnel who are not supervised by the AMUS are not considered Covered Persons and are excluded from the requirements of the Code.

This procedure is one part of a multi-part workflow. The processes that precede and follow this procedure, as applicable, are identified in the following table.

The names and/or departments listed in the following table all have some responsibility related to this procedure. Whenever this procedure is changed, these names and departments need to be informed.

¹ The term “security” includes an “investment contract” as well as other instruments. The Howey Test refers to the U.S. Supreme Court case for determining whether a transaction qualifies as an “investment contract,” and therefore would be considered a security and subject to disclosure and registration requirements under U.S. securities laws. The test applies to any contract, scheme, or transaction. If transactions qualify as “investment contracts”, those transactions are considered securities and would therefore be subject to U.S. securities laws. Certain cryptocurrencies and initial coin offerings (ICOs) may be found to meet the definition of an “investment contract” under the Howey Test. (see SEC.gov | Framework for “Investment Contract” Analysis of Digital Assets)

AMUS Compliance is responsible for maintaining version series, requests for changes, other supporting documentation, and approvals of this procedure.

The owner of this procedure is responsible for the retention of this version for a period of seven years from cancellation or revision as outlined in the Group Standards Manual.

The Code of Ethics Policy will be part of a comprehensive list of all approved AMUS Compliance procedures.

This Code of Ethics Policy is under the authority of AMUS Compliance. Management expects all Covered Persons to comply with it. If a Covered Person should wish to seek an exception from Code of Ethics Policy, the Covered Person seeking an exception shall formally request a dispensation in writing. AMUS Compliance shall review and grant any dispensations on a case-by-case basis, if warranted.

A formal action and monitoring plan must be in place to support resolution within the six-month time frame.

Requests for dispensation where compliance is expected to exceed six months shall be granted for no longer than one year from the date of approval. Dispensation requests must be supported with action plans that will get the exception item into compliance within the one-year time frame. The business executive approving the dispensation must acknowledge and accept the risk it poses to his/her business and to HSBC.

Where applicable, all documents that govern this procedure or provide guidance to this documented process are to be listed in this section. This includes the Functional Instruction Manuals (FIM), Desk Instruction Manuals (DIM), Business Instruction Manuals (BIM), particular policies or standards, and internal or external regulations.

The following documents provide guidance or detail requirements related to this procedure. This procedure adheres to all the pertinent specifics outlines in these documents.

All Covered Persons are responsible for, and have agreed to, as a requirement of their employment with and identification as access person of AMUS, to be familiar with, and comply with the Code. In addition, Covered Persons are expected to be familiar with and comply with HSBC Group and AMUS policies and procedures as they apply to the business function(s) they engage in. Furthermore, Covered Persons have a fiduciary obligation to act in the best interest of the client at all times. To that end, AMUS requires Covered Persons to conduct all business dealings in an ethical fashion and to abide by not only the technical requirements of the Code, but also to the spirit in which it is intended. When in doubt, Covered Persons should seek advice from supervisors or other appropriate personnel, or the Compliance Department.

When dealing with investment advisory clients and services, Covered Persons should fully disclose all material facts concerning any conflicts of interest that exist or arise. A conflict of interest may arise when a person or firm has an incentive to serve one interest at the expense of another interest or obligation. Examples of conflicts may include acting on an investment opportunity for oneself instead of the client, or accepting a gift, entertainment, or other advantage that could influence an investment decision.

Persons covered by the Code must adhere to these general principles as well as comply with the Code’s specific provisions

Covered Persons are required to abide by all applicable U.S. federal securities laws. Policies concerning these securities laws are discussed in other manuals and guides published by AMUS. Among other restrictions, Covered Persons are not permitted, in connection with the purchase or sale, directly or indirectly, of a security held or to be acquired by a client to:

In the course of normal business activities, Covered Persons may receive confidential information concerning clients and potential clients. To maintain client confidence and trust, this information must be handled with integrity and discretion. As a general rule, confidential information pertaining to a client of AMUS should never be communicated to anyone other than the authorized individual(s) of AMUS who need to know, and where appropriate, to the participants involved in a specific transaction.

A judgment concerning who needs to know about particular client information depends on the facts and circumstances, and should be discussed by the Covered Person with his or her supervisor or the Compliance Department as appropriate. Examples of persons within AMUS who may need to know include senior management and compliance staff. In the event confidential client information is communicated, the recipient of the information should be advised of its confidential nature, that it is given solely for the purpose of fulfilling his or her responsibilities with the client, and that it is not to be disclosed in any other form to any other person.

In accordance with insider trading laws, SEC rules, and HSBC Group and AMUS policies and procedures, Covered Persons may not transact in a security while in the possession of material non-public information about the security. Additionally, Covered Persons may not disseminate or tip such information to others who may trade the security. Material non-public information includes any information that a reasonable investor would consider in making an investment decision. Non-public information is information that has not been disseminated in a manner that would make it generally available to investors. A Covered Person who has reason to believe that he or she, or a customer, is in possession of material non-public, or non-public information should contact the AMUS Compliance Department immediately, prior to taking any action.

All personal account dealing (PAD) activity must be conducted in consultation with the Non-Financial Risk FIM, Regulatory Compliance, B.4 Conflicts of Interest (including Personal Account Dealing and Outside Activities), Mandatory Procedures, and relevant Geography Specific Requirements.

Holdings include those securities in which a Covered Person has any direct or indirect Beneficial Ownership interest, as defined in this Code.

A reportable security is subject to the reporting requirements set forth under Section 7 of the Code. Reportable securities are:

The Rule considers all securities reportable with the exception of the securities listed below. These securities are exempt from transactions and holdings reporting requirements set forth in Section 7 of this Code. These securities are also exempt from trade pre-clearance and holding period requirements set forth in Section 6 of this Code. However, trading activity in these securities must be conducted at one of the approved broker-dealers.

This Code applies to any account belonging to a Covered Person, member of their Immediate Family sharing the same household, or unrelated person in which a Covered Person has Beneficial Ownership, and/or influence, discretion, or control, either directly or indirectly, over investments or investment decisions, including but not limited to: individual and joint accounts, partnerships, power of attorney, personal- or family-owned/operated business accounts, Individual Retirement Accounts (“IRA”) and other self-directed retirement accounts, trusts or estates in which the employee, as Trustee or Executor, exercises investment discretion, herein referred to as “Covered Accounts”.

Note: “Influence, discretion or control” means any account for which the employee, or the employee’s spouse or domestic partner or dependents subject to the Policy have an ability to prompt, induce or otherwise effect transactions in the account. “Influence, discretion or control” encompasses a wide variety of factual situations.

An account held solely in the name of a member of the Covered Person’s Immediate Family sharing the same household as the Covered Person, whereby the independent account holder has an independent source of income or assets and in which the Covered Person has no financial control. Such accounts are subject to the provisions of this Code.

New Independent Accounts must be opened and maintained at one of the approved brokers. See “Approved Broker Dealer Requirement” for details.

Employees who participate in HSBC’s Health Savings Account (HSA) Program may elect to open a self-directed investment account with UMB Financial Services if they maintain a balance in their HSA savings account in excess of $1,000. These investment accounts are exempt from disclosure and reporting requirements of the Code, as the plan only permits investing in unaffiliated open-end mutual funds.

If an employee elects to open an HSA plan outside of HSBC’s HSA Program, any self-directed investment account opened in connection with such a plan at a broker other than UMB Financial Services is subject to all requirements as applicable in this Code and Group policy.

Employees participating in any of HSBC’s Group share plans (e.g. ShareMatch, UK Sharesave, Deferred Share Awards, MRT Share Awards) should refer to the Mandatory Procedures and Geography Specific Requirements for disclosure and reporting requirements.

Should you have any further questions, please contact AMUS Compliance.

AMUS Covered Persons are permitted to hold international accounts, provided:

The following types of accounts are exempt or excluded from the provisions of this Code, with the exception of certain disclosure requirements outlined below:

On a case-by-case basis when no abuse is involved a Compliance Officer may exempt a specific transaction from certain provisions of the Code except the provisions set forth under Sections 5.6 and 7.

HSBC U.S. policy requires Covered Persons to maintain their self-directed (non-discretionary) covered accounts with one of the following approved designated brokers:

In addition to maintaining a managed account, US PAD Operations has included the following robo-advisors as permissible.

If you wish to invest in a robo-advisor type account that is not included in the list above, please contact the US PAD Operations Team.

An exception to the ‘Approved Broker-Dealer Requirement’ exists for Managed accounts only after the required documentation is reviewed and approved by Compliance. The Firm where the managed account is maintained will be required to furnish Compliance with duplicate confirmations and statements.

Covered Persons are required to disclose all covered accounts via the appropriate Personal Account Dealing System immediately upon opening the account. New employees are required to transfer any/all non-exempt accounts held at a broker-dealer outside of the approved broker-dealer list to an approved broker-dealer within 90 days from hire date.

For spouses or other persons who by reason of their employment are required to conduct their securities or other financial transactions in a manner inconsistent with this Policy, employees should contact Compliance for guidance. An example of this could occur when an employee’s spouse is employed by another financial institution.

Upon receiving notification of the opening of an account, the Compliance Department will do either of the following:

The Personal Account Dealing System is also used to facilitate:

Employees are required to disclose in the appropriate Personal Account Dealing System all accounts and PIs covered by the Policy immediately upon joining and throughout their employment with the Firm,

including during the Annual Certification Process. Participation in these activities/investments cannot commence until supervisory approval is received and the disclosures reviewed by Compliance.

The ECA platform is a web-based portal specifically used to facilitate disclosure and approval of employees’ outside business activities (OBAs), personal connection conflicts, and trade associations (TA).

Employees are required to disclose in ECA all OBAs, Personal Conflicts, and TAs covered by the Policy immediately upon joining and throughout their employment with the Firm, including during any annual attestation process. Participation in these activities cannot commence until supervisory approval is received and the disclosures reviewed by Compliance.

Link to ECA: https://gfeu-x02.appiancloud.com/suite/sites/eca

Covered Persons must submit pre-clearance requests for transactions in reportable securities, reportable funds, and any other type of investment the Code requires (together, “covered securities”), and follow subsequent instructions received through the relevant Personal Account Dealing System. If instructed, the Covered Person will await pre-approval from their supervisor and AMUS RC to trade in covered securities in accounts which they have Beneficial Ownership, including Independent Accounts. Following pre-clearance, Covered Persons may purchase or sell a covered security only if:

Trade approval is only valid until close of business on the business day following approval (Approval day +1). Accordingly, GTC (good till cancelled) orders are prohibited. If a trade is not executed or is partially executed by the close of the following business day, a new pre-clearance request must be submitted.

Any authorized signatory (including the AMUS Compliance Officer) may, despite the procedure for pre-clearance outlined above, refuse to authorize any transaction or require that the number of transactions being undertaken by the Covered Person be reduced if in his/her opinion, such transactions:

In the absence of an employee’s supervisor, the employee should contact AMUS Compliance to request an alternate approver. .

Transactions in Managed Accounts are excluded from pre-clearance requirements of the Code, provided:

Periodic discussions pertaining to asset allocation and the performance of the account are acceptable.

Transactions in Exempt Securities (defined) are excluded from pre-clearance requirements of the Code.

Transactions in Exempt Accounts (defined) are excluding from pre-clearance requirements of the Code.

The Code prohibits the following types of transactions and investments:

The 30 Day Rule shall be interpreted in the same manner as it would be under the U.S. Addendum to the Group Conflicts of Interest (including Personal Account Dealing) FIM. Covered Persons must hold a covered security for at least 30 days before selling it (last-in, first-out), and not purchase a covered security for at least 30 days after selling it (last-out, first-in). For example, for execution of a buy order on 1 March 2018, the earliest possible execution of the sell order is 31 March 2018.

EMPLOYEES SHOULD CONSIDER THE HOLDING PERIOD REQUIREMENT WHEN FORMULATING AN INVESTMENT STRATEGY. EXCEPTIONS TO THE HOLDING PERIOD GENERALLY WILL NOT BE GRANTED DUE TO THE POOR MARKET PERFORMANCE OF A SECURITY AFTER IT IS TRADED.

Exceptions to the 30 Day Rule will be considered on a case-by-case basis and may be granted under exceptional circumstances such as an unanticipated significant change in the personal financial circumstances of the employee. In addition, the employee has to provide reasonable proof that the transaction does not create a conflict of interest between his/her professional responsibilities and personal trading activity.

Requests for exceptions should be made in writing (via email) to the employee’s supervisor and to the AMUS Compliance Department. Under no circumstance should an employee sell or buy a Covered Security prior to the completion of the holding period without first obtaining written approval from both the employee’s supervisor and Chief Compliance Officer (or designee).

All Covered Persons are subject to the following black out period.

Unless classified as a “restricted person,” as defined by the Group Secretary, employees are permitted to invest in the securities of HSBC provided they do not have any material non-public information about HSBC. Transactions in the publicly traded securities of HSBC are subject to trade pre-clearance and holding period requirements as detailed in the Code. Employees may not execute a trade in any derivative instrument of any Group securities at any time (with the exception of employee option plans

operated by the Group). This restriction includes, but is not limited to, the purchase or sale of equity option contracts.

Covered Persons may not engage, and may not permit any other person or entity to engage, in any purchase or sale of publicly traded Securities of which a Covered Person has, or by reason of the transaction will acquire, Beneficial Ownership, except through a registered broker-dealer.

Covered Persons must not undertake any transaction which:

A Compliance Officer reserves the right, in any event, to require an employee to close out or reverse a transaction.

Covered Persons must not request or accept from a broker, any credit or special trading facilities in connection with a transaction.

Covered Persons must disclose any conflict of interest that could influence their judgement or objectivity in conducting AMUS’s business activities. Covered Persons must not trade in a Security at a time which a Covered Person knows or could know, or in a manner likely to have, an adverse effect on the particular interests of any Advisory Client of AMUS.

Please refer to the AMUS Conflicts of Interest Policy.

AMUS Global Credit and Credit Research professionals will only be prohibited from buying and selling Fixed Income securities that fall under their areas of coverage.

Personal account transactions in Equity/ETF securities that fall under their areas of coverage will be permitted, pursuant to established pre-clearance policies and procedures.

Note: The “Black Out Period” rule still applies to all covered transactions, as set forth under Section 6.4 of the Code, and under the Personal Account Dealing Policy and US Addendum.

If you are precluded from trading under the procedures set out in the Code, you must not procure any other person to enter into such a transaction or communicate any information or opinion to another person if you know or have reason to believe that the other person will, as a result, enter into such a transaction or counsel or procure someone else to do so.

Subject to the other provisions of the AMUS Compliance Manual and to the extent permitted under Federal Securities laws, a Covered Person may not trade in Securities directly with any AMUS or HSBC Group client unless the client is a broker.

There may be instances where you will not be permitted to trade in certain Securities as a result of the involvement of an affiliated HSBC Group company in a particular transaction as noted on the share dealing restricted list – staff dealing restrictions. Accordingly, AMUS and the HSBC Group reserve the right to prohibit without explanation trading by Covered Persons in order to prevent possible conflicts of interests and to comply with applicable law.

The Code permits Access Persons to deal in cryptocurrencies for either “investment” or “household spending” purposes, consistent with the policy on cryptocurrencies set forth in the Mandatory Procedures.

Cryptocurrencies held as an investment is a Covered Investment subject to the “30-day rule” and pre-clearance; cryptocurrency used for household spending (e.g. as a form of payment, currency exchange, etc.) is not subject to the 30-day rule and pre-clearance. Access Persons must submit a pre-clearance request in Personal Account Dealing System prior to dealing in cryptocurrencies for investment purposes.

All Access Persons must disclose all accounts/wallets in Personal Account Dealing System as they would any brokerage account; new Access Persons must also disclose to AMUS Compliance when submitting their Initial Holdings and Account Disclosure. If your account does not have a unique account number assigned by the wallet/ broker, use your employee ID as the account number.

The Code prohibits Access Persons from participating in Initial Coin Offerings (“ICO”), purchasing any virtual or cryptocurrency derivatives, and participating in coin mining.

Failure to comply with these policies and procedures will result in a breach.

Nothing contained in this Code shall be interpreted as relieving any Covered Person from acting in accordance with the provision of any applicable law, rule or regulation or any other statement of policy or procedure adopted by AMUS, any Advisory Client that is a registered investment company and their affiliates or, where such law, rule, regulation policy or procedure governs the conduct of such Covered Person.

Pursuant to Rule 204A-1(b) of the Advisers Act, the Code requires each Access Person to submit reports as described below with respect to reportable securities and reportable funds in which such Access Person has any direct or indirect Beneficial Ownership. For avoidance of doubt, this includes any covered securities held outside of a brokerage, trust, custody, retirement or similar account (e.g. stocks held in certificate).

The Code requires each Access Person to submit to the AMUS Chief Compliance Officer or designee a report of their current securities holdings at the time they become an Access Person.

The initial holdings report is required to be submitted no later than ten (10) calendar days after the person becomes an Access Person.

The initial holdings reports must be current as of a date not more than 45 days prior to the date the person becomes an Access Person.

The Code requires each Access Person to submit to the AMUS Chief Compliance Officer or designee a report of their current securities holdings at least once each 12-month period after becoming an Access Person.

The annual holdings reports must be current as of a date not more than 45 days prior to the date the report is submitted.

To satisfy the requirement, access persons are asked to furnish holdings reports where not already electronically available, and to provide annual certification that they have fully disclosed all holdings.

The Code requires each Access Person to submit to the AMUS Chief Compliance Officer or designee a quarterly transaction report.

The quarterly transaction report must be submitted no later than 30 calendar days after the end of each calendar quarter, which must cover at a minimum, all transactions during the applicable quarter.

The Code may excuse access persons from submitting

An outside business activity (“OBA”), also referred to as “outside activity”, is any position of influence or control held externally other than with HSBC or its subsidiaries. All activity undertaken by AMUS Access Persons related to outside activities is subject to Non-Financial Risk FIM, Regulatory Compliance, B.4 Conflicts of Interest, (including Personal Account Dealing and Outside Activities), Mandatory Procedures and Geography Specific Requirements (“the policy”). The policy is owned by Group Compliance. The policy establishes the minimum standards that must be applied Group-wide, to ensure that a consistent and standardized approach is applied to manage potential and actual conflicts of interest. AMUS Access Persons should refer to the policy for a description of what constitutes an OBA and any potential restrictions. With the exception of those exclusions expressly noted within the policy, an employee may engage in outside activities only if such activities, in the opinion of the employee’s supervisor and the AMUS CCO or designee, do not present an actual or potential conflict of interest and do not have an adverse impact with respect to the employee’s job responsibilities at HSBC.

To ensure compliance with the requirements, Access Persons must follow a formal disclosure and approval process for participation in an OBA. The disclosure (and approval) of all OBAs is facilitated through the ECA platform: https://gfeu-x02.appiancloud.com/suite/sites/eca.

New Outside Business Activities

Employees who wish to seek, accept, or carry out a new OBA are required to disclose all pertinent details of the activity into the system prior to commencing the outside activity and may not begin the activity until they receive written notification that the request was approved by their supervisor and reviewed by Compliance.

Pre-existing Outside Business Activities

Employees who began participating in an OBA prior to joining HSBC must also disclose all pertinent details of the activity into the system for review by the employee’s supervisor and Compliance. Participation in the activity can be continued only after the matter has been reviewed and approved. If a determination is made that continued participation in the activity presents a real or potential conflict of interest, the employee will be contacted by their supervisor and Compliance to determine the appropriate action or actions necessary to either reduce or eliminate the conflict.

All Covered Persons under the Code are required to comply with this policy. Please refer to this policy for complete details.

All activity undertaken by AMUS Access Persons related to private investments is subject to Non-Financial Risk FIM, Regulatory Compliance, B.4 Conflicts of Interest, (including Personal Account Dealing and Outside Activities), Mandatory Procedures and Geography Specific Requirements (“the policy”).

A private investment/private securities transaction (“PI”) includes, but is not limited to:

An employee may engage in a PI only if such investment, in the opinion of the employee’s supervisor and Compliance, does not present an actual or potential conflict of interest and does not have an adverse impact with respect to the employee’s job responsibilities.

To ensure compliance with these requirements, Access Persons must follow a formal disclosure and approval process for making these types of investments. The disclosure (and approval) of all private investments/securities transactions is facilitated through the relevant Personal Account Dealing System.

New Private Investments/Private Securities Transactions

Employees who wish to engage in a new PI are required to disclose all pertinent details of the activity into the Personal Account Dealing System prior to committing to the investment and may not make the investment until the request is approved by their supervisor and reviewed by the AMUS CCO or designee.

Pre-existing Private Investments/Private Securities Transactions

Employees who engaged in a PI prior to joining HSBC must also disclose all pertinent details of the investment into the Personal Account Dealing System for review by the employee’s supervisor and Compliance. Maintaining the investment is contingent upon the matter being approved by the employee’s supervisor and reviewed by Compliance. If a determination is made that a continuation of the investment presents a real or potential conflict of interest, the employee will be contacted by their supervisor and the AMUS CCO or designee to determine the appropriate action or actions necessary to either reduce or eliminate the conflict.

All activity undertaken by Group Employees related to Gifts, Entertainment, and Charitable Giving (collectively referred to as “G&E”) is subject to the Group’s Global Anti-Bribery & Corruption (“AB&C”) Policy (“this policy”). This policy is owned by Global Anti-Bribery & Corruption (“AB&C”) Compliance, Financial Crime Compliance (“FCC”). The policy establishes the minimum standards that must be applied Group-wide, to ensure that a consistent and standardized approach is applied to manage potential and actual bribery and corruption risk.

Group Employees are prohibited from engaging in active or passive bribery, and any form of corruption.

In general, all G&E activity:

All Covered Persons under the Code are required to comply with this policy, as set out in the Financial Crime Risk FIM - Global Financial Crime Policy and related guidance manuals and appendices. Please refer to this policy for complete details.

The U.S. Personal Account Dealing Regulatory Compliance (“PAD RC”) team is responsible for monitoring the PAD activity of all U.S. employees who are subject to the Group’s Conflicts of Interest Policy (including Personal Account Dealing Policy and relevant addenda), which includes all Covered Persons under this Code. The PAD RC team administers the Personal Account Dealing System, which facilitates the disclosure and supervision of all U.S. employees’ PAD activity, including initial and annual certifications.

The PAD RC team periodically provides access to reporting of PAD activities of AMUS Covered Persons to AMUS RC for their review.

At least quarterly, the AMUS Chief Compliance Officer or his/her delegate(s) will review the securities transactions of all Access Persons for any apparent conflicts of interest or violations of the Code. Initially, and at least annually thereafter, the AMUS Chief Compliance Officer or his/her delegate(s) will review the securities holdings as well as OBA and PI disclosures of each access person for any conflicts of interest or violations of the Code.

AMUS RC will provide each access person with a copy of the Code and any amendments on an initial and annual basis, and after any material amendment to the Code.

Access persons are required to provide AMUS RC with a written acknowledgement of their receipt of the Code and any amendments.

Compliance with this requirement may be achieved by completing the Code Acknowledgement Form (Section 13) or by any other means the Chief Compliance Officer deems appropriate. Written acknowledgement must be recorded either electronically or manually, and is required to be returned to AMUS RC:

At least annually, AMUS RC will provide each Access Person with annual training on the principals and procedures of, and material updates to the Code.

Access Persons are required to complete the training assigned to them. The training must be completed by the due date determined by AMUS RC.

Rule 17j-1 under the Investment Company Act of 1940 requires an investment adviser of a registered investment company to adopt a written code of ethics containing provisions reasonably necessary to prevent its access persons from engaging in any conduct prohibited by the Code. Rule 17j-1 requires, among other things, that such investment advisers provide periodic reports and certifications to the board concerning the operation of the code and any material violations that occur.

On a quarterly basis, the AMUS Chief Compliance Officer or designee will furnish to the Board of Directors/Trustees of each Fund, or their delegate, a written report that:

Any Covered Person who knows of, or has a reasonable belief there is, a violation of applicable laws or of the Code, must report that information to the AMUS Compliance Department immediately. Failure to report a violation of the Code pursuant to this policy may result in disciplinary action, up to and including termination. A Covered Person should not conduct preliminary investigations.

Violations of the Code must be immediately reported to the AMUS Chief Compliance Officer or appropriate designee, provided the Chief Compliance Officer also receives reports of all violations. Violations can be reported verbally or in writing.

Such reports will be treated confidentially where possible and to the extent permitted by law, and investigated promptly and appropriately. Where normal reporting channels are unavailable or inappropriate in the judgment of the person reporting the concern, such reports may also be submitted anonymously through HSBC Confidential (refer to the HSBC staff site for further details).

Toll Free number: +1 (833) 243 5456

Alternatively, if you wish to raise a concern via e-mail: HSBC Confidential/HBUS/HSBC or hsbc.confidential@us.hsbc.com

Examples include material violations of applicable securities rules and regulations, fraud, or illegal acts involving any aspect of the firm’s business, material misstatements in client records, or reports of any material activity that is harmful to clients.

In addition to actual violations, Covered Persons are strongly encouraged to report apparent or suspected violations, or speak to a Compliance Officer if unsure whether a violation has occurred so that the Compliance Department can make the determination.

Anyone who in good faith raises an issue regarding a possible violation of law, regulation, company policy, or unethical behavior will be protected from retaliation. Any retaliation against an individual who reports a violation is prohibited and constitutes a further violation of the Code. If you have violated this Code however, making a report or participating in the investigation of the violation will not necessarily protect you from the consequences of your actions.

PAD Policy breaches must be reviewed and addressed in accordance with Global “Breach Handling” procedures outlined in the Global Personal Account Dealing Mandatory Procedures and HR FIM Mandatory First Line Procedures.

Managers should refer to Global guidance on “Managing Personal Conduct Cases (PCC)”, which provides an overview for Line Managers, HR and Risk Stewards on how performance and reward outcomes for PCC cases are determined. This approach may be layered over local disciplinary and conduct processes. The PCC guidance is available on HR Direct.

Adherence to the Code is mandatory to ensure compliance with applicable laws, regulations, and HSBC Group requirements. Any violation of the Code may result in disciplinary action that a designated person or group (e.g. Chief Compliance Officer, compliance or executive committee, Human Resources) deems appropriate, including but not limited to, warnings, cancellation of trades, disgorgement, suspension of trading privileges, demotion, or termination of licensing or employment. In addition to sanctions, violations may result in referral to civil or criminal authorities where appropriate.

Initial violations may result in a written notification or warning to the employee with increased discipline for subsequent violations. At its discretion, AMUS reserves the right to take immediate action in the event of material violation(s) of the Code, even if there had been no previous sanctions. In the event of cancelled trades, any losses arising from such trades will become the responsibility of the employee. Employees should not profit from cancelled trades and, as such, may be asked to relinquish any gains.

If it is determined that a material violation of this Code has occurred, the Chief Compliance Officer shall advise the CEO and the CEO may impose sanctions as deemed appropriate.

Please direct questions regarding the applicability of this Code to the AMUS Compliance Team email:

AMUS Compliance amus.compliance@us.hsbc.com , or to one of the compliance officers listed below:

For assistance with the Personal Account Dealing System and related questions and inquiries, please contact:

I hereby certify that I received, read, understand, and comply with the requirements of the AMUS Code of Ethics Policy (the “Code”).