1 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required by applicable law or approved by Compliance.

CODE OF ETHICS AND PERSONAL TRADING POLICY FOR NORTH

AMERICA

Applicable To	•All Covered Persons (as defined below) •All Invesco NA entities
Departments Impacted	Global Ethics Office (“GEO”)
Risk Addressed by Policy	Clients are harmed because of a Covered Person’s conflict of interest, violation of fiduciary duties or fraudulent/deceptive personal trading activities.
Relevant Law & Related Resources	•Rule 17j-1 under the Investment Company Act (“Rule 17j-1”) •Rule 204A-1 under the Investment Advisers Act (“Rule 204A-1”) •Ontario Securities Commission: National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (“NI 31-103”)
Approved By	•Invesco Mutual Funds Board: December 2023 •Invesco ETF Board: December 2023 •Invesco Canada Limited (“ICL”) Board: November 2023
Effective Date	January 2024

GLOSSARY

Background. Invesco is required to adopt and enforce a written code of ethics as well

as to establish, maintain and apply policies and procedures that establish a system of

controls to comply with securities laws and regulations, including, but not limited to, the

management of conflicts of interest matters, which may include personal trading

activities.

This Code of Ethics and Personal Trading Policy for North America (the “Code”) requires

that Covered Persons (as defined below) adhere to high standards of ethical conduct and

act with integrity in accordance with their fiduciary duties. The Code is intended to

comply with the requirements of Rule 204A-1, Rule 17j-1 and NI 31-103.

Definitions.

“Beneficial Ownership” means the opportunity, directly or indirectly, through any contract,

arrangement, understanding, relationship or otherwise, to share in the economic interest

or profit derived from the ownership of, or transaction in, a Covered Security.

“Client Account” means an Invesco Fund (with respect to Covered Persons other than

Independent Directors/Trustees), a separately managed account, a personal trust or

estate, an Employee benefit trust or any other account for which an Invesco NA Adviser

provides investment advisory or sub-advisory services. For Independent Directors/

Trustees, “Client Account” shall mean the Invesco funds they oversee.

“Compliance Reporting System” means any third party, web-based application utilized

by Covered Persons, excluding Independent Directors/Trustees, for compliance reporting

(i.e., personal securities transactions, investment accounts, outside activities, etc.)

2 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required by applicable law or approved by Compliance.

“Contingent Worker” means any Invesco consultant or contractor with access to the firm’s internal

network systems.

“Covered Account” means any account that holds or may hold a Covered Security whether directly

or through Beneficial Ownership, and as further described in Section B.1 below.

“Covered Person” means any of the following:

•Employee (interns, part-time or full-time);

•Contingent Worker;

•Director or Officer of Invesco Ltd.;

•Independent Director/Trustee;

•any individual who is conducting business on behalf of an Invesco Adviser or

affiliate, and has access to the firm’s internal network systems or offices;

•any person meeting the definition of “Access Person” as defined in Rule 17j-1 or

Rule 204A-1; or

•anyone who, at the discretion of GEO, is deemed to be a Covered Person subject

to the requirements of this Code.

“Covered Security” generally means, investment instruments or assets (public or

private), unless otherwise exempt from the definition, are as follows:

•Stocks/shares (e.g., common, preferred or restricted) or bonds (e.g., corporate

or municipal);

•Exchange Traded Products (defined below);

•Closed-end Funds and REITs;

•Instruments that are convertible or exchangeable into a Covered Security;

•Derivatives (e.g., options, futures, forwards, ADRs (American Depository

Receipts)/GDRs (Global Depositary Receipts), swaps, commodities, warrants/

rights), or other obligation whose value is derived or based on any of the

above;

•Limited Offerings/Limited Liability Company interests (defined below);

•Invesco Open-end Mutual Funds; and

•any security/instrument that can be traded by an Invesco Adviser or an affiliate

on behalf of a client.

The following securities are exempt from the definition of “Covered Security:”

•Direct obligations of the U.S. government, the Canadian government, or direct

obligations of a Sovereign Government and their respective agencies;

•Bankers’ acceptances, bank certificates of deposit, commercial paper or high-

quality short-term debt instruments (including repurchase agreements);

•Shares of an open-end mutual fund for which Invesco does not serve as an

investment adviser, subadviser or principal underwriter;

•Money market equivalent funds;

•Investment trusts that invest exclusively in open-end mutual funds for which

Invesco does not serve as an investment adviser, subadviser or principal

underwriter;

•Any unit investment trust (including those advised or sub-advised by an Invesco

3 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required by applicable law or approved by Compliance.

NA Adviser);

•Principal-protected or linked-note investment products; and

•Physical commodities (including foreign currencies).

“Delegated Discretionary Account” means an account for which a Covered Person has

written evidence that decision-making authority has been completely relinquished to a

professional money manager who is not a family member or not otherwise subject to

this Code and over which the Covered Person has no direct or indirect influence or

control.

“Employee” means an individual who serves as a director or officer of an Invesco NA

entity or who is employed on a full-time or part-time basis by an Invesco NA entity or

subsidiary thereof. For purposes of this Code, the term Employee also includes the

Employee’s Immediate Family Members.

“ETP Access Person” means a Covered Person who has access to Material Non-public

Information attached to Invesco ETPs including but not limited to any client’s purchase

or sale of Invesco ETPs and/or the holdings of an Invesco ETP or anyone else determined

as such and as notified by Compliance.

“Exchange-Traded Product” or “ETP” means a security traded on an exchange that: (i)

tracks an underlying security, index or financial instrument; or (ii) uses a benchmark

index but whose manager(s) may change sector allocations, market-time trades, or

deviate from the index. The term “ETP” includes, among other things, exchange-traded

funds (“ETFs”), exchange-traded notes (“ETNs”) and exchange-traded commodities

(“ETCs”).

“Global Ethics Office” or “GEO” means the team within Compliance that is responsible for

monitoring conflicts in connection with a Covered Person’s personal trading, political

contributions, outside business activities and gifts and entertainment.

“Immediate Family Member” means a Covered Person’s:

•Spouse

•Domestic partner or equivalent (i.e., PACS (Civil Solidarity Pact), common law

marriage, etc.)

oGenerally considered to be a permanent committed relationship; and

oWith Beneficial Ownership of their partner’s Covered Accounts

•Child, stepchild, parent, stepparent, sibling, mother-in-law, father-in-law, daughter-in-

law, brother-in-law or sister-in-law who shares the Covered Person’s household.

A roommate who is not a domestic partner or does not otherwise have one of the attributes

above shall not be deemed to be an Immediate Family Member.

Questions regarding the applicability of this definition should be directed to the Global

Ethics Office.

“Independent Director/Trustee” means any; (i) director or trustee of an Invesco Mutual

Fund who is not an “interested person” (as defined in Section 2(a)(19) of the Investment

Company Act) of an Invesco Mutual Fund; (ii) director or trustee of an Invesco ETP who

4 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required by applicable law or approved by Compliance.

is not an “interested person” (as defined in Section 2(a)(19) of the Investment Company

Act) of an Invesco ETP; or (iii) member of the Invesco Canada Independent Review

Committee, Invesco Canada Funds Advisory Board or Board of Directors of Invesco

Corporate Class Inc. who has no other executive responsibilities or engagement in an

Invesco Canada Fund or Invesco NA’s day-to-day activities beyond the scope of their

duties as director/trustee.

“Initial Public Offering” or “IPO” means: (i) any Covered Security which is being offered

for the first time on a recognized stock exchange; or (ii) an offering of securities

registered under the Securities Act, the issuer of which immediately before such

registration was not subject to the reporting requirements of Sections 13 or 15(d) of the

Securities Exchange Act of 1934, as amended or foreign regulatory equivalents thereof.

“Investment Person” generally means a Covered Person (excluding Independent

Directors/Trustees) who:

•as part of their regular functions or duties makes or participates in making

recommendations regarding the purchase or sale of securities in a Client Account

(e.g., portfolio managers, securities analysts or traders); or

•works directly with or is in the same department/investment team as a portfolio

manager and is likely to be exposed to sensitive information relating to those

Client Accounts for which the portfolio manager has responsibility (including those

who serve an administrative function).

”Limited Offering or Private Placement” means an offering that is exempt from

registration under the Securities Act of 1933 (“33 Act”), including but not limited to those

offered according to Sections 4(a)(2), 4(a)5, 4(a)6 or pursuant to Rules 504 or 506

under the 33 Act (e.g., Special Purpose Acquisition Company (SPAC), private equity fund

or hedge fund, crowdfunding, private real estate investments such as Real Investment

Trusts (REITs) or LLCs/LPs).

“MNPI” or “Material Non-public Information” means information not known to the public

that may, if disclosed, have a significant impact on the price of a financial instrument

and that a reasonable investor would likely consider relevant or important when making

an investment decision.

“Rights Issue” or “Rights Offer” means a dividend of subscription rights to buy additional

securities in a company made to the company's existing security holders.

“Robo-Advisor Account” means a Covered Person’s account that holds, or can hold, Covered

Securities that is maintained on a digital platform offered by a broker on the

Designated/Approved Broker List to provide automated, algorithm-driven investment decisions

with little to no human intervention.

"Special Purpose Acquisition Company" or "SPAC" is a company without commercial

operations and formed specifically to raise capital through an IPO for the purpose of

acquiring or merging with an existing company.

5 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required by applicable law or approved by Compliance.

A.POLICY

Each Invesco NA Adviser has a fiduciary relationship with respect to each of their Client

Accounts. As such, Invesco NA and Covered Persons shall:

•place the interests of clients ahead of their personal interests (or, in the case of

Independent Directors/Trustees, the funds they oversee);

•conduct their personal trading in a manner consistent with this Code and other

applicable policies to avoid any actual or potential conflicts of interest or any abuse

of position of trust and responsibility;

•comply with applicable laws, rules and regulations; and

•keep all MNPI (as defined above) confidential.

Invesco NA and all Covered Persons are prohibited from:

•profiting personally by using MNPI and disclosing MNPI to any person (except as

may be permitted by law and in accordance with Invesco’s insider trading

policies);

•employing any device, scheme or artifice to defraud any Client Account;

•making an untrue statement of a material fact or omitting to state a material fact

to a client that, in light of the circumstances under which they are made, are

necessary to make the statement non-misleading;

•engaging in any act, practice or course of business that operates or would operate

as a fraud or deceit to a Client Account; or

•engaging in any manipulative practice with respect to a Client Account or

securities (including price manipulation).

Invesco NA maintains other compliance policies that may be directly applicable to a

Covered Person’s specific responsibilities and duties and that address additional

standards of conduct for Employees. These policies are available on the Invesco Ltd.

intranet site and include, but are not limited to:

•Global Code of Conduct •Global Insider Trading •Global Fraud Escalation •Global Political Contributions	•Global Outside Business Activities •Global Gifts and Entertainment •U.S. Gifts and Entertainment •Gifts and Entertainment (ICL)

Violations of any of the policies listed above may result in increased escalation. For

further detail, refer to Section C regarding violations and sanctions.

Please see Exhibit B for requirements applicable to Independent Directors/Trustees.

B.PERSONAL TRADING REQUIREMENTS

References to Covered Persons in this Section B shall exclude Independent Directors/

Trustees. Personal trading requirements and pre-clearance requirements (if any) for

Independent Directors/Trustees are set forth in Exhibit B.

6 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required by applicable law or approved by Compliance.

1.Covered Account Requirements for Covered Persons.

Covered Persons are required to report all investment accounts (i.e., Covered Accounts)

for which they, or Immediate Family Members, have Beneficial Ownership or have

discretion, control or interests, whether such discretion, control or interests are exercised

or not. It is presumed that a Covered Person can control accounts held by Immediate

Family Members living in the same household.

Covered Accounts must be held with a regulated financial institution listed on the

Designated/Approved Broker List1.

Covered Accounts include but are not limited to the following:

Brokerage Accounts	Discretionary/Robo-Advisor Accounts2	Employee Stock Plans (e.g., ESPPs, ESOPs or ISOs)
Retirement Accounts (e.g., IRAs, SIPPs, Superannuation, iDeCo, RRSP, TFSA or any other local equivalent)	Transfer Agent Accounts that hold reportable Covered Securities (e.g., Invesco open- end mutual fund account)	Mutual Fund, Collective Investment or WRAP Accounts, which hold Invesco open-end funds
Pension Plans, which hold Covered Securities (excluding Invesco open-end funds)	Stock and Shares ISAs (i.e., Investment ISA)	UTMAs and UGMAs
Invesco 401k, and the separate Schwab Personal Choice Retirement Account (“PCRA”)	529 Accounts that hold Covered Securities and the Invesco CollegeBound 529 plan

1 The Designated/Approved Broker List is accessible through the Compliance

Reporting System.

2 Discretionary and Robo-Advisor Accounts must be disclosed. New and existing Discretionary and Robo-

Advisor accounts must be approved by GEO. The Covered Person must provide supporting documentation

(e.g., managed account agreement) and other required information to GEO, including duplicate statements.

Covered Persons are required to ensure that:

•Covered Accounts held with abroker located inthe U.S. or India are

maintained:

owith a financial institution on the Designated/Approved Broker List (which

may be accessed via the Compliance Reporting System);

oin a qualified retirement plan that a Covered Person is not legally or

unilaterally able to transfer; or

ofor the U.S. only, with any full-service broker-dealer.

•Invesco Open-End Mutual Funds are held:

oin an account maintained with a financial institution (or broker on the

Designated/Approved Broker List);

oin a qualified retirement plan that a Covered Person is not legally or

unilaterally able to transfer;

7 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required by applicable law or approved by Compliance.

oin the Covered Person’s Invesco 401(k) or Invesco CollegeBound 529 plan;

or

odirectly with Invesco’s Mutual Funds’ transfer agent.

Covered Persons may not purchase or hold Invesco affiliated open-end mutual funds

beyond the above restrictions. This requirement does not apply to other Invesco

securities.

•All other Covered Accounts (e.g., external retirement plans, stock plans through

third-party administrators):

oCovered Persons shall direct their financial institution to submit

statements and confirmations to the GEO;

oIf the financial institution is unable to provide transactional statements (or

contract notes) to GEO through a link or hard copy, the Covered Person

shall be personally responsible for submitting statements directly or upon

request through the GEO Support Portal in a timely manner;

oTrade confirmations (or contract notes) must be provided no later than 15

calendar days from the date of execution; and

oTransactional statements must be provided within 15 calendar days of

receipt.

2.Statements (Transactions) and Trade Confirmations (or Contract Notes).

•Employees shall maintain a Covered Account with a financial institution that

provides electronic trade confirmations (or contract notes) and statements

directly to GEO.

•If the financial institution fails or is unable to provide an electronic link or a

hard copy, the Covered Person shall be personally responsible for providing

transactional statements and trade confirmations (or contract notes) for the

Covered Account(s) to GEO through the GEO Support Portal or where

applicable, to their local Compliance upon request.

•All Covered Accounts must be reported in the Compliance Reporting System

before trading begins or upon hire. Statements are not required for accounts

that do not meet the Covered Accounts definition, such as accounts that are

only able to invest in unaffiliated Open-end Mutual Funds.

Pre-Clearance of Personal Trades.

Covered Persons and their Immediate Family Members are required to pre-clear Covered

Securities transactions through the Compliance Reporting System as illustrated in Exhibit

A.

Covered Persons are prohibited from executing a security transaction (trade) in a Covered

Account until they are notified by GEO that the trade was approved. Covered Persons

must carefully read the automated alert from the Compliance Reporting System, which

includes the request status (i.e., approved or denied).

8 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required by applicable law or approved by Compliance.

Covered Accounts in which a Covered Person has beneficial interest but does not exercise

control (e.g., accounts for Immediate Family Members), all trade requests are required to

be submitted through the Covered Person.

GEO will notify the Covered Person if the trade request was approved or denied.

Trade Authorization (i.e., Market Orders). Trade requests which have been

submitted and approved within the Compliance Reporting System prior to market close

are only valid for the current business day, unless the approval is granted after the close

of the trading day (e.g., trading on a foreign market or OTC), then approval will not

expire until the end of the next trading day.

If the trade is not executed within the approval window, a Covered Person shall be

required to submit a new pre-clearance request and must receive approval if the Covered

Person intends to trade in that security.

Prohibited Trade Orders. Covered Persons are required to avoid executing

transactions outside of the approval window. Good ‘Til Canceled (GTC), Limit Orders and

Stop-Limit Orders among other orders beyond the same trading day are prohibited.

Pre-clearance of Limited Offerings and Private Placements. Covered Persons and

their Immediate Family Members must:

•Pre-clear investments in Limited Offerings and Private Placements and receive

approval from GEO before investing and allow a minimum of three to five

business days before the intended investment date to allow ample time for

review.

•Submit a Private Placement pre-clearance request through the Compliance

Reporting System and include a detailed description of the investment and

relevant documentation (e.g., offering deck, offering/private placement

memorandum and term sheet).

Additionally, Covered Persons seeking to invest in a Limited Offering/Private Placement

sponsored by Invesco Ltd. and its affiliates:

•Must pre-clear all transactions through the Compliance Reporting System if the

investment is made alongside third-party investors.

•May transact without pre-clearance if Invesco offers the investment exclusively to

Employees.

In all instances, Limited Offerings and Private Placements are subject to ongoing

reporting obligations. Please consult Legal and the Global Ethics Office if you have

questions about these requirements before investing.

Exemptions from Pre-Clearance. Purchases or sales of the following are exempt from

the pre-clearance requirement:

Covered Securities in an approved Delegated Discretionary/Robo-Advisor Account;

•Invesco Mutual Funds and Invesco Canada Funds (excluding closed-end

9 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required by applicable law or approved by Compliance.

Invesco Mutual Funds and closed-end Invesco Canada Funds) ;

•Invesco ETPs (this Invesco ETP pre-clearance exemption does not apply

to ETP Access Persons);

•Unaffiliated broad-based ETPs (this pre-clearance exemption does not

apply to single stock ETPs)

•Currencies, cryptocurrencies, and commodities, including trusts invested

entirely in a currency, cryptocurrency or commodity;

•Derivativesofanindexofsecurities,currencies,cryptocurrencies or

commodities;

•Invesco Mutual Fund grants awarded (Long-Term Fund Awards); and

•Securities held in Invesco CollegeBound 529 Plans, Invesco Core U.S. 401(k)

Plans (excluding elections in the personal choice retirement account) and

registered group retirement savings plans offered by an Invesco Ltd.

affiliate.

Pre-clearance of Employee Share Purchase Plans and Long-Term Incentive

Plans. The acquisition or deposit of shares, including IVZ shares through an Employee

Share Purchase Plan or Equity Awards Program is exempt from pre-clearance. However,

pre-clearance is required if Covered Persons wish to sell these shares, including IVZ

shares. Please refer to Exhibit A.

3.Trading Restrictions/Prohibitions.

Blackout Period. Covered Persons are prohibited from trading any Covered Security in

a personal account on a day during which a Client Account has a pending “buy” or “sell”

order in the same Covered Security.

In addition:

•Investment Persons with knowledge of trading in a Covered Security for a Client

Account are prohibited from personal trading within three trading days before

and three trading days after such Client Account transaction; and

•All other Covered Persons with knowledge of trading in a Covered Security for a

Client Account are prohibited from personal trading in the same Covered Security

within two trading days after such Client Account transaction.

Blackout Period Exemptions. Blackout period restrictions may be exempt if purchases

and sales of a Covered Security comply with certain conditions (e.g., large market

capitalization, daily trading limit, etc.) as may be determined from time to time by the

GEO. Refer to the FAQ for details.

Other Prohibitions. Covered Persons shall be prohibited from:

•trading a Covered Security of an issuer on the applicable Restricted List(s);

•purchasing a Covered Security in an IPO or secondary offering;

•purchasing a publicly listed SPAC when the targeted company is known;

•participating in an investment club;

1 0 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required

•excessive short-term trading of any Invesco Open-end Mutual Funds (excluding

money market funds) and/or cash-in-lieu Invesco ETPs according to the various

limitations outlined in the respective prospectus or other fund disclosure

documents;

•engaging in personal trading of Covered Securities that is excessive, or that

compromises Invesco NA’s fiduciary duty to Client Accounts, as determined by

the GEO in its discretion;

•for Investment Personnel, effecting short sales of a Covered Security in a Covered

Account if a Client Account for which the Investment Person has investment

management responsibility has a long position in such Covered Security; and

•trading options on common stock, single stock ETPs, or Invesco ETPs when the

underlying security is either not held or has been held fewer than 60 days. For

the sake of clarity, trading naked options is prohibited and only covered calls and

protective puts are permitted.

Short-Term Trading Restriction for all Covered Persons.

•Covered Persons cannot profit from the purchase and sale of a Covered Security

(or a short sale and cover of the same Covered Security) within 60 calendar days

of the trade date of the same Covered Security. Gains are calculated on a first-

in, first-out (FIFO) method.

•Transactions in Invesco Canada Funds are subject to the short-term trading

requirements outlined in the applicable prospectus.

•This restriction shall apply to all Covered Securities, including those which are

exempt from pre-clearance (e.g., Invesco Funds). Transactions in unaffiliated

ETPs (except for single stock ETPs), currencies, cryptocurrencies, commodities,

trusts invested entirely in a currency, cryptocurrency or commodity, and

derivatives (e.g., options and futures) based on an index of securities, currencies,

cryptocurrencies and commodities are exempt from the 60-day holding period.

This exemption shall not apply to derivatives of individual securities, single stock

ETPs, or Invesco ETPs.

•If a Covered Security is traded within the applicable holding period, the full

amount of any profit from the trade, which has not been adjusted to account for

applicable taxes or related fees, shall be disgorged to a charity of Invesco Ltd.’s

choice.

•Covered Persons are exempt from the 60-day holding period if the trade

transaction is executed at a loss.

4.Special Requirements for Transactions in Invesco Ltd. Stock.

Transactions in Invesco Ltd. stock are subject to the pre-clearance and reporting

requirements set forth above. Covered Persons are prohibited from engaging in

transactions in publicly traded options such as puts, calls and other derivative securities

relating to Invesco Ltd.’s securities, on an exchange or any other organized market.

Covered Persons should refer to the Global Insider Trading policy whenever they wish to

1 1 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required

transact in Invesco Ltd. securities in a Covered Account.

5.Covered Persons Reporting and Certification Requirements.

Certification Requirements. All Covered Persons are required to complete a Code of

Ethics acknowledgment on their start date with Invesco, and annually thereafter, to

acknowledge and certify that they have received, reviewed, understand, and shall

comply with the Code. In addition, Covered Persons will be required to acknowledge

receipt and understanding of any material amendments or new interpretations of the

Code.

Reporting Requirements. All Covered Persons are subject to initial (upon joining

Invesco) and ongoing reporting requirements. These reports will be reviewed by GEO

and are intended solely for internal use and are confidential unless required to be

disclosed to a regulatory or government agency.

Summary of Reporting Obligations

New Hires3	Covered Persons
Upon joining the firm (due in 10 calendar days)	Quarterly (due no later than 30 calendar days after the calendar quarter-end)	Annual (due no later than 30 calendar days from distribution)
Covered Accounts/ Initial Holdings Report (including a list of all Covered Securities and private/limited holdings. All holdings must be as of the Covered Person’s employment start date)	Quarterly Transaction Report (excluding dividends reinvested, private/limited offering transactions previously disclosed, auto investment plans, payroll deductions, transactions executed in an approved Discretionary/Robo-Advisor Account)	Annual Holdings & Private Investments Report (excluding holdings in an approved Discretionary Account, and any holdings designated as non- reportable on Exhibit A)
Initial Compliance Policies Certification		Annual Compliance Policies Certification

3Any New Hire who fails to submit the Covered Accounts/Initial Holdings

Report (IHR) within the (10) calendar days of their employment start date will be prohibited from

engaging in any personal securities transactions until such report is submitted and may be issued a

violation and subject to other sanctions.

In addition, the Quarterly Transaction Report can exclude the following transactions

executed in Covered Securities that are either:

•transacted directly with an affiliated transfer agent; or

•in the Covered Person’s registered group retirement savings plan (including

transactions made on behalf of the Covered Person in the ICL sponsored GWL

Group Retirement Savings Plan) or Invesco Core US 401(k) Plan.

1 2 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required

New Covered Accounts. All Covered Persons must report any new Covered Account

for themselves or any Immediate Family Member within 30 calendar days of opening.

Unless the account has been reported, no personal securities transactions can occur within

the account.

Exhibit A. Attached as Exhibit A is an Overview of Personal Trading Requirements that

provides a summary of certain requirements set forth under this Code which are

applicable to Covered Persons (excluding Independent Directors/Trustees). The

Overview is not meant to serve as a replacement for reading the Code.

Individuals who meet the definition of a Covered Person and are on a formal leave of

absence or garden leave without access to Invesco systems are not considered Covered

Persons during the time they are on leave.

C.VIOLATIONS AND SANCTIONS

Covered Persons shall report violations and potential violations of this Code to the GEO.

Violations and potential violations of the Code are investigated by GEO. Independent

Directors/Trustees may report violations and potential violations to the applicable CCO

(or their delegate).

If a determination is made that a Covered Person (excluding Independent Directors/

Trustees) has violated the Code, a sanction may be imposed in accordance with the

escalation procedure. Sanctions vary based on the severity of the violation(s) and

include, but are not limited to:

•a letter of education, a letter of warning or letter of reprimand;

•reversal of trades processed in violation of the Code;

•disgorgement of profits earned in the Code violation;

•prohibition of personal trading abilities;

•suspension, demotion or change in the Covered Person’s responsibilities;

•termination of employment;

•referral to civil or criminal authorities, where appropriate; or

•any other sanction, as may be determined by the GEO, CCO and/or applicable

governance committee.

The GEO maintains internal procedures regarding the violation investigation, sanction

determination and sanction enforcement process.

In mitigating or eliminating certain conflicts of interest that arise in connection with a

Covered Person’s personal trading, a Covered Person may be required to sell a Covered

Security that was previously approved. In the event the sale results in a loss, the

Covered Person will not be entitled to reimbursement for such loss. In the event of a

gain, the Covered Person may be required to disgorge any profit.

D.CODE ADMINISTRATION

In general, the GEO shall be responsible for the administration and oversight of the Code

and shall be responsible for:

1 3 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required

•identifying Covered Persons, providing Covered Persons with the Code and

notifying them of their reporting obligations under the Code, and ensuring that

Covered Persons submit the required certifications and reports required under

the Code;

•reviewing the personal trading activities of Covered Persons to identify

potential or actual violations of the Code and promptly investigating such

matters to resolve and make the appropriate remediations, if needed; and

•promptly report any violations of the Code in writing to the applicable CCO.

In very limited circumstances, certain exceptions to any provision of the Code may be

granted on a case-by-case basis by the applicable CCO or their delegate. Such exceptions

shall be documented in writing by the GEO.

Any questions regarding this Code should be directed to the GEO, which may be

contacted using the GEO Support Portal via the intranet.

E.REPORTING.

ICL Boards/Committees. At least quarterly, the CCO shall inform the Invesco Canada

Funds Independent Review Committee of violations, sanctions imposed, material

changes and any other information as may be requested from time to time relating to

the Code and for the relevant review period.

Invesco Mutual Funds Board and Invesco ETF Board.

•Quarterly: At least quarterly, each applicable CCO shall furnish a written

report to the applicable Board regarding material violations of the Code by

Covered Persons.

•Annually: No less frequently than annually, each applicable CCO shall

furnish a written report to the applicable Board that describes significant

issues arising under the Code since the last report to the Board, including

information about material violations of the Code and sanctions imposed in

response to material violations. The CCO shall certify that the applicable

Invesco NA Adviser to the Invesco Mutual Funds and Invesco ETFs has

adopted procedures reasonably designed to prevent Covered Persons from

violating the Code. At this time, the Board shall also review the current

Code.

•Material Changes to Code. The applicable Committee/Boards mentioned in

this Code shall approve any material changes made to the Code either

before implementing such change or no later than six months after the

change is implemented.

1 4 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required

EXHIBIT A

OVERVIEW OF PERSONAL TRADING REQUIREMENTS

Below are some, but not all, of the common investment instruments and key actions

required of Covered Persons (excluding Independent Directors/Trustees)under the

Code.

Security Type	Pre-Clearance	Reporting	60-Day Profit Limit Restriction
Equities
Common Stocks	Yes	Yes	Yes
IPOs	PROHIBITED	PROHIBITED	N/A
Preferred Stocks	Yes	Yes	Yes
Rights Issue or Rights Offer1	Yes	Yes	No
Trusts invested entirely in a currency or commodity	No	Yes	No
Exchange-Traded Products (i.e., ETFs, ETCs and ETNs)
Invesco ETPs (except for ETP Access Persons)	No	Yes	Yes
Invesco ETPs (ETP Access Persons)	Yes	Yes	Yes
Unaffiliated broad-based ETPs (apart from single stock ETPs)	No	Yes	No
Single-stock ETPs and unaffiliated ETPs with a limited number of underlying securities (20 or less) that include Covered Securities	Yes	Yes	Yes
Cryptocurrencies2
Cryptocurrencies	No	No	No
Trusts invested entirely in a cryptocurrency	No	Yes	No
Futures, Swaps and Options based on a cryptocurrency	No	Yes	No
Derivatives
Futures, Swaps and Options3 based on common stock and affiliated ETPs	Yes	Yes	Yes

1 Pre-clearance is required on the day of electing to participate in the Rights

issue or Offer.

2 Cryptocurrency exemptions are subject to change and requirements may be applied to certain Employees

upon notification by Compliance. Some digital assets claiming to be cryptocurrency could be deemed

securities by regulators. Please contact the Global Ethics Office if you have questions regarding the

requirements of your digital assets under the Code.

3 Options are restricted to covered calls and protective puts where the underlying security has been held

no fewer than 60 days. All other option types are prohibited.

1 5 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required

Security Type	Pre-Clearance	Reporting	60-Day Profit Limit Restriction
Naked options	PROHIBITED	PROHIBITED	N/A
Futures, Swaps and Options Based on an index, currencies, commodities, and unaffiliated ETPs	No	Yes	No
Mutual Funds
Invesco Open-end Mutual Funds	No	Yes	Yes
Invesco Closed-end Mutual Funds	Yes	Yes	Yes
Invesco Canada Open-end Mutual Funds	No	Yes	Subject to Prospectus Requirements
Invesco Canada Closed-end Mutual Funds	Yes	Yes	Yes
Unaffiliated Open-end Mutual Funds	No	No	No
Unaffiliated Closed-end Mutual Funds	Yes	Yes	Yes
Fixed Income/Bonds
US Treasury	No	No	No
Certificates of Deposit	No	No	No
Money Market Funds	No	No	No
Municipal Bonds	Yes	Yes	Yes
Corporate Bonds	Yes	Yes	Yes
Structured products linked to indices	No	Yes	No
Invesco Ltd. Corporate Securities
Open Market IVZ shares	Yes	Yes	Yes
Sale of IVZ shares acquired through ESPP, RSA and LTA	Yes	Yes	No
Derivatives on IVZ, short sells of IVZ or IVZ share transactions in Professionally Managed Accounts	PROHIBITED	PROHIBITED	N/A
IVR shares	Yes	Yes	Yes
Long-Term Fund Awards
Invesco Mutual Fund grants awarded	No	No	No
Invesco CollegeBound 529 Plan	No	Yes	No
Limited Offerings/Private Placements
Non-Invesco offerings	Yes	Yes	Yes
Invesco offerings	Yes*	Yes	Yes

*Covered Persons may not engage in a Limited Offering without first: (a) giving the GEO a detailed written

notification describing the transaction and indicating whether or not they will receive compensation; and

(b) obtaining prior written permission from the GEO.

1 6 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required

*Covered Persons must pre-clear activity in Limited Offerings/Private Placements sponsored by

Invesco Ltd. and its affiliates with GEO unless Invesco offers the investment exclusively to Employees.

1 7 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required

EXHIBIT B

INDEPENDENT DIRECTORS/TRUSTEES

Independent Directors/Trustees on the Invesco Mutual Funds, Invesco Canada Fund and the

Invesco ETP Boards shall refrain from beneficially owning Invesco Ltd. stock.

Independent Directors/Trustees who have questions, need to report a potential or actual

violation, may report such matters to the applicable Chief Compliance Officer, or their

delegate.

OVERVIEW

A.Independent Directors/Trustees of the Invesco Mutual Funds:

•are subject to and must comply with the pre-clearance requirements for certain

transactions involving Invesco Mutual Funds that are closed-end Funds under the

Independent Directors/Trustees policies and guidelines;

•shall complete a Quarterly Transaction Report only if the Independent Director/

Trustee knew or, or in the ordinary course of fulfilling their official duties as an

Independent Director/Trustee, should have known, that during the 15-days

immediately preceding or following the date of the Independent Director/Trustee’s

transaction in a Covered Security:

oan Invesco Mutual Fund purchased or sold the Covered Security; or

oan Invesco Mutual Fund, Invesco Advisers, Inc., or any sub-adviser to such

Invesco Mutual Fund considered purchasing or selling the Covered Security.

•Independent Directors/Trustees who are subject to the Quarterly Transaction

Reporting requirement per the above bullet, shall request the Quarterly Transaction

Report and complete the report with the following information for each transaction

during the quarter:

othe date of the transaction , the Covered Security name, number of shares

(for equity securities), or the interest rate and maturity date (if applicable)

and the principal amount (for debt securities) for each Covered Security;

othe nature of the transaction (e.g., buy or sell);

othe Covered Security identifier (i.e., CUSIP or symbol);

othe execution price of the Covered Security;

othe name of the broker-dealer or bank executing the transaction; and

othe date that the report was submitted to the applicable Chief Compliance

Officer.

•are subject to the short-term trading restrictions (e.g., profit restriction) with respect

to Invesco Mutual Funds that are closed-end funds.

B.Independent Directors/Trustees on the Invesco ETPs Board:

•shall complete a Quarterly Transaction Report only if the Independent Director/Trustee

knew, or in the ordinary course of fulfilling their official duties as an Independent

Director/Trustee, should have known, that during the 15-days immediately preceding

or following the date of the Independent Director/Trustee’s transaction in a Covered

Security:

oan Invesco ETP purchased or sold the Covered Security; or

oan Invesco ETP, Invesco Capital Management, LLC. or any sub-adviser to

such Invesco ETP considered purchasing or selling the Covered Security.

1 8 This policy is proprietary and may not be distributed to, or shared with, any third parties, unless required

•Independent Directors/Trustees who are subject to the Quarterly Transaction

Reporting requirement, shall request the Quarterly Transaction Report and complete

the report with the following information for each transaction during the quarter:

othe date of the transaction, the Covered Security name, number of shares

(for equity securities), or the interest rate and maturity date (if applicable)

and the principal amount (for debt securities) for each Covered Security;

othe nature of the transaction (e.g., buy or sell);

othe Covered Security identifier (i.e., CUSIP or symbol);

othe execution price of the Covered Security;

othe name of the broker-dealer or bank executing the transaction; and

othe date that the report was submitted to the applicable Chief Compliance

Officer.

•Independent Directors/Trustees on the Invesco ETPs Board, are not subject to:

opre-clearance requirements;

oproviding account statements or trade confirmations;

oCovered Account or Annual Holdings reporting requirements; or

oshort-term trading restrictions.

C.Independent Directors/Trustees on the Invesco Canada Fund Board:

•shall complete a Quarterly Transaction Report only if the Independent Director/Trustee

knew or, or in the ordinary course of fulfilling their official duties as an Independent

Director/Trustee, should have known, that during the 15-days immediately preceding

or following the date of the Independent Director/Trustee’s transaction in a Covered

Security:

oan Invesco Canada Fund purchased or sold the Covered Security; or

oan Invesco Canada Fund, Invesco Canada Ltd. or any sub-adviser to such

Invesco Canada Fund considered purchasing or selling the Covered

Security.

•Independent Directors/Trustees who are subject to the Quarterly Transaction

Reporting requirement, shall request the Quarterly Transaction Report and complete

the report with the following information for each transaction during the quarter:

othe date of the transaction, the Covered Security name, number of shares

(for equity securities), or the interest rate and maturity date (if applicable)

and the principal amount (for debt securities) for each Covered Security;

othe nature of the transaction (e.g., buy or sell);

othe Covered Security identifier (i.e., CUSIP or symbol);

othe execution price of the Covered Security;

othe name of the broker-dealer or bank executing the transaction; and

othe date that the report was submitted to the applicable Chief Compliance

Officer.

•Independent Directors/Trustees on the Invesco Canada Fund Board, are not

subject to:

opre-clearance requirements;

oproviding account statements or trade confirmations;

oCovered Account or Annual Holdings reporting requirements; or

oshort-term trading restrictions.