Introduction

Reporting Code and Standard of Conduct Violations...............................

6

Certification Requirements..........................................................................

6

Sanctions.......................................................................................................

6

Code of Ethics

Who Is Subject to the Code?.......................................................................

8

Covered Accounts........................................................................................

8

New Accounts...............................................................................................

9

Authorized Brokerage Firms—U.S. Employees

and U.S. Persons Subject to the Code........................................................

9

Non-Reportable Accounts.........................................................................

10

Personal Securities Transactions................................................................

10

Private Placements.....................................................................................

11

Reportable Transactions (transactions that do not require

pre-clearance but must be reported)........................................................

11

Personal Trading Restrictions and Prohibited Activities..........................

12

Reporting Requirements............................................................................

14

Summary of Reporting Obligations...........................................................

14

Communications with Disinterested Trustees and Outside Directors....

15

Japan Supplement.....................................................................................

15

DIMENSIONAL FUND ADVISORS

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INTRODUCTION

Reporting Code and Standard of Conduct Violations

Dimensional is committed to fostering a culture of compliance. If you have

any questions or concerns, or become aware of a violation or potential

violation of the Code or the Standard of Conduct, you are required to

report the matter to one of the following:

n The Global CCO and/or Designated Officer

n General Counsel or

n a member of the Ethics Committee

The Global CCO will receive reports on all violations of the Code reported

to a Designated Officer and/or a member of the Ethics Committee.

You have the option of reporting compliance-related matters on

a confidential basis through the Compliance Reporting System (“CRS”),

or by email at Compliance@dimensional.com.

Retaliation against any employee for reporting compliance-related issues

is cause for appropriate corrective action, up to and including termination

of the employment of the retaliating employee.

General Code or Standard of Conduct questions should be directed to your

local Compliance Team members.

Certification Requirements

You are required to complete a Code of Ethics and Standard of Conduct

Acknowledgement Form upon commencement of your employment with

Dimensional, and at least annually thereafter, to acknowledge and certify

that you have received, reviewed, understand, and shall comply with the

Code and the Standard of Conduct. In addition, any material amendments

to the Code or the Standard of Conduct will be communicated to you, and

you will be required to acknowledge your receipt and understanding of any

such amendments as a condition of your continued employment.

Sanctions

Depending on the severity of the infraction, you may be subject to

sanctions for violating the Code and related personal trading controls or

the Standard of Conduct. Sanctions may include, but are not limited to:

n verbal or written warnings,

n letters of reprimand,

n suspension of personal trading activity,

DIMENSIONAL FUND ADVISORS

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INTRODUCTION

n disgorgement and forfeiture of profits,

n

suspension, and/or

n

termination of employment

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CODE OF ETHICS

Other Covered Accounts

Contract for Difference Accounts

Self-Invested Personal Pensions (SIPPs)

(CDAs) (UK-specific)

and Stock and Shares ISAs (UK-specific)

Superannuation Accounts (managed,

Nippon (Japan) Individual Savings

SMSF, or Super Wrap)

Account (NISA) (Japan-specific)

(Australia-specific)

Personal Retirement Savings Accounts

(PRSA) (Ireland-specific)

Local supplementary or mandatory provident funds or retirement schemes

(i.e., CPF accounts in Singapore; MPF accounts in Hong Kong)

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CODE OF ETHICS

n Automatic Investment Plans (including dividend reinvestment plans) in

which regular periodic purchases (or withdrawals) are made automatically

in (or from) investment accounts in accordance with a predetermined

schedule and allocation; and

n Exchange-Traded Funds (ETFs) where the aggregate daily trade value per

security is less than or equal to USD $50,000 per ETF per day.

Please note: Although transactions in ETFs in amounts less than or equal to

USD $50,000 per ETF do not require pre-clearance, post-trade review will be

performed and all other Code provisions will still apply, such as the sixty (60)

day profit restriction.

Personal Trading Restrictions and Prohibited Activities

The following transactions are prohibited:

n Limit orders that expire after the T+1 pre-clearance period (including limit

orders with no expiration date);

n Transactions on margin;

n Initial public offering (IPO) or initial coin offering (ICO) investments;

n Short selling of securities;

n Transactions in securities that are subject to firmwide restriction; and

n Transactions in a security while in possession of insider information. Such

transactions are unethical and may be illegal and will be dealt with

decisively (reference the Global Insider Trading Policy, the EU Anti-Market

Abuse Policy, the Singapore Supplemental Insider Trading Policy, and the

Japan Insider Trading Management Policies).

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CODE OF ETHICS

S H O R T - T E R M T R A D I N G R E S T R I C T I O N S

n Access Persons cannot profit from the purchase and sale (or sale and

purchase) of the same or equivalent security, across all accounts, within

sixty (60) calendar days.

n Gains are calculated based on a last-in, first-out (LIFO) method within a

sixty (60) calendar day period.

E X C E S S I V E T R A D I N G I N C O V E R E D S E C U R I T I E S

Dimensional discourages employees from engaging in excessive trading

activity. Compliance has the discretion to notify you and/or an appropriate

supervisor of excessive trading patterns if circumstances warrant.

E X C E S S I V E T R A D I N G O F D I M E N S I O N A L M A N A G E D F U N D S

Employees are prohibited from engaging in excessive trading of any

Dimensional Managed Funds in order to take advantage of short-term

market movements. Excessive trading activity, such as a frequent pattern

of exchanges, could result in harm to shareholders or clients.

E T F S F O R W H I C H D I M E N S I O N A L S E R V E S A S A D V I S O R O R S U B A D V I S O R

Employees with knowledge of the composition of the underlying ETF

constituents are prohibited from using such information or from disclosing

such information to any other person, except as authorized in the course

of their employment, until such information is made public.

C R Y P T O C U R R E N C I E S

When seeking to acquire a digital currency, either directly or in the form of

a security, please be aware of the following:

n If you purchase or sell a digital currency considered to be a “security”

within the meaning of the U.S. federal securities laws (or any other applicable

laws for non-U.S. personnel), you need to pre-clear the transaction just

as you would any other Covered Security. Likewise, if you purchase or sell

a fund or other instrument that invests in a digital currency (e.g., Bitcoin

Investment Trust (“GBTC”)), you need to pre-clear the transaction just as

you would any other covered security.

n As with any initial public offering (IPO), your participation in an Initial Coin

Offering or Initial Token Offering (ICO), is not permitted under the Code.

n Holding or transacting in actual cryptocurrency that has been determined

not to constitute a security within the meaning of the U.S. federal securities

laws (or any other applicable laws for non-U.S. personnel), including

holding or transacting in Bitcoin or Ethereum, does not require

pre‑clearance or reporting to Compliance.

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CODE OF ETHICS

E X C E P T I O N S T O C O D E R E S T R I C T I O N S

In cases of hardship, the Global CCO or Designated Officer may grant an

exception (or waiver) to the personal trading restrictions of the Code. The

decision will be based on a determination that a hardship exists and the

transaction for which the exception (or waiver) is requested would not result

in a conflict with our clients’ interests or violate any other policy embodied

in the Code. Any exception (or waiver) will be evidenced in writing and will

be reported to the Ethics Committee.

Reporting Requirements

Personal securities transactions and holdings reports will be reviewed

by Compliance. The records and reports created or maintained pursuant

to the Code are intended solely for internal use and are confidential unless

required to be disclosed to a regulatory or governmental agency.

New employees who fail to submit their Compliance New Hire

Questionnaire and Initial Holdings Report within ten (10) calendar days

of their employment start date will be prohibited from engaging in any

personal securities transaction until such report is submitted and may be

subject to other sanctions.

Summary of Reporting Obligations

New Hires

All Employees

Upon joining the firm

Quarterly and Annually

(Due 30 calendar days after

(Due in 10 calendar days)

each quarter)

New Hire Questionnaire

Quarterly and Annual

(Disciplinary Action Disclosure)

Compliance Questionnaires

Initial Holdings Report

Quarterly Transaction Reports and

(include private placements)

Annual Holdings Certification

Provide Covered Account

Covered Account(s) Certification;

statement(s) (current, within

report new accounts upon opening

45 days prior to start date)

Code of Ethics, Insider Trading

Code of Ethics, Insider Trading

and Compliance

and Compliance

Manual Acknowledgements

Manual Acknowledgements

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CODE OF ETHICS

Communications with Disinterested Trustees and Outside Directors

Dimensional attempts to keep directors/trustees informed with respect to

Dimensional’s investment activities through reports and other information

provided to them in connection with board meetings and other events.

However, it is Dimensional’s policy not to communicate specific trading

information and/or advice on specific issues to Disinterested Trustees and

Outside Directors unless the proposed transaction presents issues on which

input from the Disinterested Trustees or Outside Directors is appropriate

(i.e., no information is given regarding securities for which current activity is

being considered for clients). Any information requests by Disinterested

Trustees or Outside Directors should be reported to the General Counsel

or the Global CCO.

Disinterested Trustees are not subject to the reporting requirements except

to the extent the Disinterested Trustee knew or, in the ordinary course of

fulfilling his or her duties as a director, should have known that during the

fifteen (15) days immediately before or after the Disinterested Trustee’s

transaction in a Covered Security, a U.S. Registered Fund purchased or sold

the covered security, or an Advisor considered purchasing or selling the

covered security for a U.S. Registered Fund.

Supplemental Material

J A P A N

Pursuant to local rules and regulations, Japanese employees have

additional restrictions on personal trading (see the Japanese Code

of Ethics Addendum).

A U S T R A L I A

Dimensional employees in Australia are subject to additional rules

regarding personal transactions in Dimensional products sold in Australia

(see the Investment by Employees in The Dimensional Wholesale

Trust policy).

DIMENSIONAL FUND ADVISORS

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STANDARD OF CONDUCT

Guidelines

DIMENSIONAL FUND ADVISORS

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STANDARD OF CONDUCT

Gifts and Business Entertainment

DIMENSIONAL FUND ADVISORS

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STANDARD OF CONDUCT

If you are a member of the Fund Advisory Personnel, you must also comply

with the following restrictions:

DIMENSIONAL FUND ADVISORS

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STANDARD OF CONDUCT

n Attending meals or events in which five (5) or more Dimensional

employees are in attendance.

DIMENSIONAL FUND ADVISORS

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STANDARD OF CONDUCT

Although Dimensional encourages civic and community involvement by

its directors, officers, and employees, Dimensional desires to avoid any

situation that could curtail Dimensional’s current business or business prospects,

raise potential or actual conflicts of interest, or create an appearance of

impropriety in the context of Dimensional’s business relationships. Accordingly,

all contributions by a director, officer, employee, registered representative

or Immediate Family Member of a director, officer, or employee of the

Dimensional Entities or Distributor (each a “Contributor”) must be made on

the Contributor’s behalf, entirely voluntary, and should not be in an amount

(determined by Contributor taking into account the Code) that is likely to

influence a candidate’s judgment regarding any continued or future business

with Dimensional.

Specifically, this policy prohibits a Contributor from making political

contributions when the solicitation or request for such contributions implies

that continued or future business with Dimensional depends on making

such contributions. Similarly, no contributions should be made that create

the appearance that Dimensional stands to benefit in its business relations

because of the Contributor’s contribution. If a Contributor is unsure if a

particular political contribution would be in compliance with this policy, they

should consult Dimensional’s U.S. Legal and/or Compliance Department.

More specifically, the following actions are prohibited:

n Contributors are prohibited from making political or charitable contributions

for the purpose of obtaining or retaining potential or existing public

entity clients;

n Contributors are prohibited from making any contributions that create the

appearance that Dimensional stands to benefit in its business relations

because of such contribution; and

n Contributors from Dimensional’s non-U.S. based advisor affiliates are

prohibited from making any political contributions to political action

committees (PACs) federal, state, or local candidates for elective office

in the United States.

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GLOSSARY OF TERMS

Advisers Act means the Investment Advisers Act of 1940.

Advisor means Dimensional Fund Advisors LP, DFA Australia Limited,

Dimensional Fund Advisors Ltd., Dimensional Fund Advisors Canada ULC,

Dimensional Fund Advisors Pte. Ltd., Dimensional Japan Ltd., and

Dimensional Ireland Limited.

Authorized Brokerage Firms for U.S. employees and other U.S. persons

subject to the Code are listed on Appendix A.

Beneficial

Ownership means the employee has or shares a direct or indirect

pecuniary interest in the securities held in an account. As an employee, you

have a pecuniary interest in securities if you have the ability to directly or

indirectly profit from a securities transaction. It is presumed that you have

beneficial

ownership interests in any account held individually or jointly,

by you or by your Immediate Family Member or domestic partner (or an

unrelated adult with whom you share your home and contribute to each

other’s support) including but not limited to family trusts and family

partnerships (Securities Exchange Act of 1934, Rule 16a-1; 17 CFR 240.16a-1).

Broker Donors means broker-dealers or similar financial intermediaries

and their employees, officers, directors, and other representatives.

Covered Account includes any broker-dealer, investment adviser, bank,

or other financial institutions in which an Access Person

maintains an

account in which any securities are held or the account has the ability to

hold securities for the direct or indirect benefit of such

Access Person.

DIMENSIONAL FUND ADVISORS

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GLOSSARY OF TERMS

Dimensional Managed Funds means any series/portfolio of the U.S. Mutual

Funds, ETFs, or any other fund globally that is advised by or sub-advised by

any of the Advisors.

Discretionary Account means a personal account in which you have

completely turned over decision-making authority to a professional money

manager (who is not an Immediate Family Member or not otherwise covered

by the Code) and you have no direct or indirect influence or control over the

account. This includes accounts for which Dimensional is an investment advisor

or a sub-advisor. Such accounts are often referred to as “professionally

managed” or “managed accounts.”

Disinterested Trustee means a director/trustee of the U.S. Registered Funds

who is not considered to be an “interested person” of the U.S. Mutual Funds

within the meaning of Section 2(a)(19)(A) of the 1940 Act.

Ethics Committee means the Ethics Committee appointed by the directors/

trustees of the Dimensional Entities and consists of the certain officers of

Dimensional Fund Advisors LP, including the Co-Chief Executive Officers,

General Counsel, Global Head of Portfolio Management, Global Head and

Deputy of Human Resources, Chief Compliance Officer for the U.S. Registered

Funds, Global Chief Compliance Officer, and subject to change from

time to time.

Fund Advisory Personnel means those persons whose names appear on

the effective list of Authorized Traders kept by Dimensional.

Immediate Family Member of an employee means any of the following:

n Spouse, civil union or domestic partner;

n Any person(s) sharing the same household with the employee, including

child, stepchild, grandchild, parent, stepparent, grandparent, sibling,

mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law,

sister-in-law, adoptive relationships, and legal guardianships;

n someone who holds account(s) in which the employee is a joint owner,

has trading authority, or Beneficial Ownership; and/or

n person(s) sharing the same household with the employee for whom the

employee contributes to the maintenance of the household and the

financial support of such person.

Outside Director means a director of any Advisor who is not considered

to be an “interested person” of the Advisor within the meaning of Section

2(a)(19)(B) of the 1940 Act, provided that a director shall not be considered

interested for purposes of the Code by virtue of being a director or

DIMENSIONAL FUND ADVISORS

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GLOSSARY OF TERMS

knowingly having a direct or indirect beneficial interest in the securities

of the Advisor if such ownership interest does not exceed five percent (5%)

of the outstanding voting securities of such Advisor.

SEC Rules means rules of the U.S. Securities and Exchange Commission

(the “SEC”) including, but not limited to, Rule 206(4)-5 and Rule 204A-1

under the Advisers Act, and Rule 17j-1 under the 1940 Act.

Supervised Person means any partner, officer, director (or other person

occupying a similar status or performing similar functions), or employee

of Dimensional, or other person who provides (i) investment advice on

behalf of an Advisor and (ii) is subject to the supervision and control of

the Advisor with respect to activities that are subject to the Advisers Act

or the 1940 Act.