Exhibit 99.B(p)(24)

Global Credit Advisers, LLC

CODE OF ETHICS

December 2025

100 Park Avenue
35^th Floor
New York, NY 10017
212-949-1860

Global Credit Advisers, LLC (“GCA”, or the “Firm”), which is registered with the Securities and Exchange Commission (the “SEC”) as an investment adviser, has adopted this code of ethics (“Code of Ethics”) pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Although Rule 204A-1 includes a legal requirement that GCA adopt such a code, this Code of Ethics also reflects GCA’s own high standards for the conduct of its business and for the proper performance of GCA’s duties with respect to GCA’s Clients which are primarily Private Funds (“GCA Clients”). GCA Clients also include one or more funds (“‘40 Act Fund” or “‘40 Act Funds”) registered under the Investment Company Act of 1940, as amended (the “Company Act”), and this Code of Ethics that is consistent with the requirements of Rule 17j-1 under the Company Act and written policies and procedures that are reasonably designed to prevent violation of the “federal securities laws” (as such term is defined in Rule 38a-1 under the Company Act) by a ‘40 Act Fund and GCA. This Code of Ethics represents, therefore, more than a technical regulatory obligation with which all of GCA’s employees (“GCA Employees”) are expected to comply. The principles enunciated herein are central to GCA’s goal of serving the best interests of its GCA Clients.

GCA has reviewed its business, and the attendant risks of unethical conduct, and has drafted this Code of Ethics on the basis of this review. The Chief Compliance Officer (“CCO”) reviews this Code of Ethics at least annually and based on this review, revises this Code of Ethics as appropriate to keep pace with changes in GCA’s business and applicable law and regulations. Any amendments are distributed to all GCA Employees as soon as practicable after their adoption.

All GCA Employees are required to review this Code of Ethics, to be familiar with it, and to refer to it and to GCA’s senior management for guidance whenever they have a question about any activity which could have even the appearance of violating this Code of Ethics or subjecting GCA to any adverse publicity or criticism or concern on the part of GCA Clients.

It is the responsibility of every GCA Employee to comply with applicable laws and regulations and this Code of Ethics. Failure to comply with applicable laws and regulations and this Code of Ethics can result in termination, as well as civil and criminal penalties. Any violation of this Code of Ethics must be promptly reported to the COO and the CCO.

For purposes of this Code of Ethics, capitalized terms not otherwise defined shall have the following meanings:

Unless otherwise provided, any person identified above may designate in writing other qualified GCA Employees to implement specific responsibilities assigned to him in these procedures.

GCA has been entrusted with responsibility for providing advice to GCA Clients, who depend on GCA to act in their interests and to maintain the highest ethical standards. GCA requires all GCA Employees to conduct themselves at all times in compliance with the following standards of business conduct:

In order to comply with these standards, GCA Employees must be alert to any potential conflict of interest between GCA’s interest and the interests of GCA Clients and for any improper activity on the part of other GCA Employees.

GCA forbids any GCA Employee from trading, either personally or on behalf of others (including GCA Clients), on the basis of material nonpublic information (“MNPI”) or communicating MNPI to others in violation of law (as explained further in this Section). This prohibited conduct is referred to as “insider trading.” GCA’s policy applies to every GCA Employee and extends to activities within and outside his duties at GCA. Any questions regarding GCA’s policy and procedures on insider trading should be referred to the CCO.

Generally, for this purpose, a purchase or sale of a Security of an issuer is “on the basis of MNPI about that security or issuer if the person making the purchase or sale was in possession of MNPI when the person made the purchase or sale.

The law prohibits:

Examples of information that GCA Employees should consider material include:

Information may be material even though it relates to a projected future event that may or may not occur. For future events, the probability of the event must be factored against its magnitude, as well as how soon it is likely or certain to occur. For example, information that an issuer is in advanced negotiations to be acquired probably would be considered material, even though the issuer has not yet entered into any binding agreement, since the magnitude of that event would be large for that issuer.

If a loan issuer has no public securities, a GCA Employee may elect to be on the private side and have access to non-public information about the issuer and may trade the issuer’s loans based on that nonpublic information.

If a GCA Employee has elected to switch from having access to private information to the public side, at least one Form 10-Q or an equivalent quarterly financial report (or specific cleanse) available to investors must be filed or released by the issuer before GCA may trade in the issuer’s Securities.

Material information does not have to relate to a company’s business. For example, a Wall Street Journal reporter was found criminally liable for disclosing to others material information that was not related to a company’s business, but that was expected to affect the market value of the company’s securities. In that case, the material information consisted of the dates that reports on various companies would appear in The Wall Street Journal and whether those reports would be favorable or not for the company. In other words, the principal factors that determine whether information is material are:

ANY VIOLATION OF THIS POLICY CAN BE EXPECTED TO RESULT IN SERIOUS SANCTIONS BY GCA, INCLUDING DISMISSAL OF THE PERSON(S) INVOLVED.

The following procedures have been established to aid GCA Employees in avoiding insider trading, and to aid GCA in preventing, detecting and imposing sanctions against insider trading. Every GCA Employee must follow these procedures or risk serious sanctions, including dismissal, substantial personal liability and criminal penalties. (See “Penalties for Insider Trading,” above.) If you have any questions about these procedures, you should consult the CCO.

Non-public meetings with issuer insiders must be reported on the GCA Company Contact Calendar (“CCC”) to which the COO, CFO, and CCO have access. The meeting date, names of participants, and subject matter all must be reported on the GCA Company Contact Form provided on the CCC in Microsoft Outlook.

If, after consideration of these factors, you believe that the information is material and nonpublic, or if you have questions as to whether the information is material and nonpublic, you should take the following steps:

The role of the CCO is critical to the implementation and maintenance of GCA’s policies and procedures against insider trading. Supervisory Procedures can be divided into two classifications - prevention of insider trading and detection of insider trading.

A GCA Employee or his Immediate Family must not cause or attempt to cause any GCA Client account to acquire, dispose of, or hold any Security of the same class as a Security in which such GCA Employee or his Immediate Family has direct or indirect Beneficial Ownership (or which is linked in value to a Security in which the GCA Employee or his Immediate Family has a direct or indirect Beneficial Interest) unless the GCA Employee or his Immediate Family has first disclosed in writing to the CCO all facts reasonably necessary to identify the nature of the GCA Employee’s or his Immediate Family’s Beneficial Interest in the Security.

GCA Employees or their Immediate Family may own, purchase, or sell securities that are purchased or sold for GCA Client accounts. If the GCA Employee or his Immediate Family purchases or sells a Security for his or her own account, or for an account in which he or she has Beneficial Ownership, on the same day as a transaction in the same Security is effected for a GCA Client account, the GCA Client account will receive a price not less favorable than the price received by the GCA Employee’s or his Immediate Family’s account, to the extent of the size of the GCA Employee’s or his Immediate Family’s transaction. If a proposed transaction in a Security by a GCA Employee or his Immediate Family requires pre-approval and, in the opinion of the CCO, the proposed transaction would adversely affect the price of a transaction for a GCA Client account that could not be rectified by switching prices, the CCO will not approve the transaction until such time that it will not adversely affect transactions for GCA Client accounts.

The price adjustment provisions will not apply to transactions which would otherwise be covered by this Section, but which are:

If GCA Employees or their Immediate Family have accounts with the same broker-dealers that effect securities transactions for GCA Client accounts, GCA may include transactions for GCA Employees or their Immediate Family in a bunched order with transactions for GCA Client accounts. In this case, the GCA Employee or his Immediate Family will receive the same price as GCA Client accounts. If, however, in GCA’s opinion, bunching transactions for GCA Employees or his Immediate Family with GCA Client account orders would adversely affect the price of the bunched order, GCA will forego transactions for GCA Employees or their Immediate Family until such time that they will not adversely affect transactions for GCA Client accounts.

Except as provided in Section 4.4, every GCA Employee or his Immediate Family must submit to the CCO a report indicating all of the Securities in which he has any direct or indirect Beneficial Ownership. This report is due within 10 business days after any GCA Employee is hired and will be updated at least annually thereafter on a date selected by the CCO. If the GCA Employee or his Immediate Family opens an account containing Reportable Securities at a broker, dealer, bank or other intermediary not listed in the most recently submitted Holdings Report, he will promptly update the list.

Except as provided in Section 4.4, every GCA Employee or his Immediate Family must submit a quarterly report via PTCC to the CCO reporting any transaction in which he has, or by reason of such transaction acquires, any direct or indirect Beneficial Ownership in any Reportable Security that occurred during such quarter in an account (“Transactions Report”). This report should also list any new accounts opened within the quarter being reported. This report shall be due within 30 days after the end of the applicable calendar quarter and may contain a statement that the report should not be construed as an admission by the person making the report that, for purposes of the Exchange Act, he has any direct or indirect Beneficial Interest in the Security.

Notwithstanding the provisions of the foregoing Sections 4.2 and 4.3, no GCA Employee or his Immediate Family is required to submit any such:

The CCO will periodically (but no less frequently than once a year) compare trades reported by GCA Employees or their Immediate Family to trades arranged by GCA for GCA Client accounts. In doing so, the CCO will look for evidence of improper trading and misuse of information by GCA Employees or their Immediate Family in trading for accounts in which they hold a Beneficial Interest.

Every GCA Employee or his Immediate Family must certify compliance with GCA’s policies and procedures on insider trading and personal securities transactions and furnish a complete list of securities in which he has a Beneficial Interest to the CCO upon request. The CCO requests such certification and a copy of such securities list from each GCA Employee or his Immediate Family at least annually.

GCA has adopted the following policies to avoid the appearance of conflicts or actual conflicts that may arise from providing or accepting gifts and entertainment.

GCA Employees and their Immediate Family are not permitted to give gifts, gratuities or other favors to any person or firm where the payment relates in any way to the business of the recipient or the recipient’s employer or to government officials, except to the extent such gifts are in compliance with applicable law, of insignificant value, and not given in consideration or expectation of any action by the recipient.

GCA Employees must not accept or permit any member of their Immediate Family to accept, any gifts, gratuities or other favors from any GCA Client, supplier or other person doing or seeking to do business with GCA, other than items of insignificant value. Any gifts that are not of insignificant value should be returned immediately and reported to the CCO.

Common sense and moderation should prevail in travel and business entertainment undertaken on behalf of GCA. GCA Employees and their Immediate Family should not provide, or accept, business entertainment to or from anyone doing business or seeking to do business with GCA unless the entertainment is infrequent, reasonable in the circumstances and intended to serve legitimate business goals.

Rule 206(4)-5 addresses so-called “pay to play” practices in which investment advisers make campaign contributions to elected officials of state or municipal governments in order to influence the award of contracts to manage public pension plan assets and other government investment accounts. The rule applies to SEC-registered investment advisers, certain exempt reporting advisers, and foreign private advisers, who provide investment advisory services, or are seeking to provide investment advisory services, to state and municipal government entities.

a. Prohibitions. The rule contains three main prohibitions:

(i)            Two-Year Time Out. An investment adviser is prohibited from receiving compensation for providing advice to a government entity, either directly or through a “covered investment pool,” within two years after a contribution by the adviser, or by any of its “covered associates” (which include the adviser’s general partner or managing member, executive officers or other individuals with a similar status or function, solicitors, and political action committees they control) to an official of that government entity who can influence the award of advisory business.

(ii)            Third-Party Solicitor Ban. Neither an investment adviser nor any of its covered associates may provide or agree to provide, directly or indirectly, payment to any third-party to solicit government clients for GCA unless such person is a “regulated person.”

(iii)            Bundling Ban. Rule 206(4)-5 prohibits an adviser and its covered associates from “bundling” others’ contributions, i.e. coordinating or soliciting any person or political action committee to make (A) any contribution to an official of a government entity to which the adviser is providing or seeking to provide investment advisory services; or (B) any payment to a political party of a state or locality where GCA is providing or seeking to provide investment advisory services to a government entity.

b. Catch All Provision. Rule 206(4)-5(d) prohibits acts done indirectly, which, if done directly, would violate the rule.

c. Covered Investment Pools. Rule 206(4)-5 includes a provision that applies each of the prohibitions of the rule to an adviser that manages assets of a government entity through a “covered investment pool” defined as (i) any investment company registered under the Company Act that is an investment option of a plan or program of a government entity; or (ii) any company that would be an investment company under section 3(a) of the Company Act but for the exclusions from that definition provided by section 3(c)(1), section 3(c)(7) or section 3(c)(11) of that Act.

d. Recordkeeping. Rule 204-2 was amended to require registered advisers that provide investment advisory services to a government entity, or to a covered investment pool in which a government entity is an investor, to make and keep certain records related to the pay to play rule.

The giving and acceptance of any payments or other consideration in the nature of bribes and kickbacks are absolutely prohibited by law and Firm policy. Additionally, GCA Employees must obtain pre-clearance from the CCO before making any campaign contributions to candidates for, or incumbents in, state and municipality official office.

As a result of recent financial industry issues and several regulatory actions against major firms involving very significant fines, financial industry regulators, e.g., SEC and FINRA are focusing attention on adviser and broker-dealer policies and practices on the use of e-mail, other electronic communications and retention practices.

The Books and Records rule (Rule 204-2(a) (7)) provides that specific, written communications must be kept including those relating to a) investment recommendations or advice given or proposed; b) receipt or delivery of funds or securities; and c) placing and execution of orders for the purchase or sale of securities.

All electronic communications are viewed as written communications, and the SEC has publicly indicated its expectation that firms retain all electronic communications for the required record retention periods. If a method of communication lacks a retention method, then it must be prohibited from use by GCA.

Further, SEC regulators also will request and expect all electronic communications of GCA Employees to be monitored and maintained for the same required periods.

E-mails consisting of spam or viruses are not required to be maintained.

GCA’s policy provides that e-mail, instant messaging, social networks and other electronic communications are treated as written communications and that such communications must always be of a professional nature. GCA’s policy covers electronic communications for GCA, to or from GCA Clients, any personal e-mail communications within GCA and social networking sites.

All Firm and GCA Client-related electronic communications must be on GCA’s systems, and use of personal e-mail addresses, personal social networks and other personal electronic communications for Firm or GCA Client communications is prohibited. GCA prohibits any use of social networking sites of any confidential Firm information including any information about GCA Clients, investment recommendations or trading activities. GCA prohibits the use of file hosting services (e.g., Google Drive, Dropbox) for GCA business related purposes with the exception of GCA-monitored SharePoint Online and OneDrive on the Microsoft Azure cloud platform.

GCA prohibits employees from creating or maintaining any individual blogs or network pages on behalf of GCA.

Firm employees may divulge GCA’s name and their position on a professional network such as LinkedIn. Any information beyond that is prohibited without prior approval from the CCO.

While Firm employees may divulge GCA’s name as their employer on social network sites such as Facebook, GCA Employees should not divulge their position or discuss GCA, their role or any other information relating to their employment. Any communication on any other social network site is prohibited.

Each employee has an initial responsibility to be familiar with and follow GCA’s e-mail and electronic communication policy with respect to their individual communications. The CCO has the overall responsibility for making sure all employees are familiar with GCA’s policy, implementing and monitoring GCA’s policy, practices, and recordkeeping.

GCA has adopted procedures to implement its policy and conduct reviews to monitor and ensure that GCA’s policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

Exhibit A — Trading Authorization Form

TRADING AUTHORIZATION FORM

This Form must be completed by each GCA Employee for themselves or their Immediate Family for each Reportable Securities transaction not entered into PTCC. This Form is valid for one business day only (except in connection with non-volitional orders which may be executed in the future, i.e., stop and limit orders, which must be approved on the order date). Capitalized terms have the meanings given to them in the Global Credit Advisers, LLC Code of Ethics.

I am not aware of any information which, if made public, would materially change the price of the Security being transacted.

Exhibit C — Policy against Discrimination and Harassment

POLICY AGAINST DISCRIMINATION AND HARASSMENT

It is the intention of Global Credit Advisers, LLC (the “Firm”) to provide all GCA Employees with employment and advancement opportunities. GCA does not discriminate in employment opportunities or practices on the basis of race, citizenship, color, religion, sex, affectional or sexual orientation, national origin, ancestry, disability, AIDS/HIV status, age, familial status, source of income, military service or any other characteristic protected by federal, state and local laws.

This policy governs all aspects of employment, including selection, job assignment, compensation, discipline, termination, and access to benefits and training.

Any GCA Employee who has questions or concerns about any type of discrimination or harassment in the workplace is encouraged to bring these issues to the attention of the CCO. GCA Employees can raise concerns and make reports without fear of reprisal. Anyone found to be engaging in any type of unlawful discrimination will be subject to disciplinary action, up to and including termination of employment.

prohibited harassment

GCA is committed to providing a work environment that is free of discrimination and unlawful harassment. Actions, words, jokes, or comments based on an individual’s sex, affectional or sexual orientation, race, ethnicity, age, religion, disability or any other legally protected characteristic will not be tolerated.

Sexual harassment under the law includes unwelcome sexual advances, requests for sexual favors, offering or conditioning employment benefits in exchange for sexual favors, and other verbal and physical conduct of a sexual nature when:

Unlawful sexual harassment includes many forms of offensive behavior and includes gender-based harassment. In addition to the conduct listed above, unlawful sexual harassment includes other unwelcome visual or verbal conduct such as leering, sexual gestures, sexual jokes, flirtations, advances or propositions, displaying suggestive articles, cartoons, pictures or posters, inappropriate comments about an individual’s body, and suggestive or obscene words or jokes.

Other examples of inappropriate and harassing behavior include, but are not limited to, use of racial epithets or slang, making jokes which rely upon stereotypical assumptions about an individual’s race, ethnicity or other protected characteristic, or the distribution of offensive e-mails or materials that are denigrating to individuals based upon their race, ethnicity or other protected characteristic.

Any GCA Employee who wants to report an incident of sexual or other unlawful harassment or discrimination should promptly report the matter to the CCO. GCA Employees can raise concerns and make reports without fear of reprisal. Under no circumstances will GCA tolerate any retaliation against a GCA Employee who makes use of this policy.

Any supervisor or manager who becomes aware of possible sexual or other unlawful harassment must promptly advise the CCO or any member of management.

Reports of sexual or other unlawful harassment will be promptly and thoroughly investigated, and, if improper harassment has occurred, it will be stopped, and steps will be taken to prevent any reoccurrence of the harassment.

Anyone engaging in sexual or other unlawful harassment or retaliation will be subject to disciplinary action, up to and including termination of employment.

Global Credit Advisers, LLC (“GCA”) is committed to maintaining a workplace free from sexual harassment. Sexual harassment is a form of workplace discrimination. GCA Employees are required to work in a manner that prevents sexual harassment in the workplace. This Policy is one component of GCA’s commitment to a discrimination-free work environment. Sexual harassment is against the law¹ and all GCA Employees have a legal right to a workplace free from sexual harassment and GCA Employees are urged to report sexual harassment by filing a complaint internally with Timothy Finn, Chief Compliance Officer (“CCO”). GCA Employees can also file a complaint with a government agency or in court under federal, state or local antidiscrimination laws.

Policy:

¹ While this policy specifically addresses sexual harassment, harassment because of and discrimination against persons of all protected classes is prohibited. In New York State, such classes include age, race, creed, color, national origin, sexual orientation, military status, sex, disability, marital status, domestic violence victim status, gender identity and criminal history.

² A non-employee is someone who is (or is employed by) a contractor, subcontractor, vendor, consultant, or anyone providing services in the workplace. Protected non-employees include persons commonly referred to as independent contractors, “gig” workers and temporary workers. Also included are persons providing equipment repair, cleaning services or any other services provided pursuant to a contract with the employer.

What Is “Sexual Harassment”?

Sexual harassment is a form of sex discrimination and is unlawful under federal, state, and (where applicable) local law. Sexual harassment includes harassment on the basis of sex, sexual orientation, self-identified or perceived sex, gender expression, gender identity and the status of being transgender.

Sexual harassment includes unwelcome conduct which is either of a sexual nature, or which is directed at an individual because of that individual’s sex when:

A sexually harassing hostile work environment includes, but is not limited to, words, signs, jokes, pranks, intimidation or physical violence which are of a sexual nature, or which are directed at an individual because of that individual’s sex. Sexual harassment also consists of any unwanted verbal or physical advances, sexually explicit derogatory statements or sexually discriminatory remarks made by someone which are offensive or objectionable to the recipient, which cause the recipient discomfort or humiliation, which interfere with the recipient’s job performance.

Sexual harassment also occurs when a person in authority tries to trade job benefits for sexual favors. This can include hiring, promotion, continued employment or any other terms, conditions or privileges of employment. This is also called “quid pro quo” harassment.

Any employee who feels harassed should report the incident(s) promptly so that any violation of this policy can be corrected promptly. Any harassing conduct, including a single incident, can be addressed under this policy.

Examples of sexual harassment

The following describes some of the types of acts that may be unlawful sexual harassment and that are strictly prohibited:

Who can be a target of sexual harassment?

Sexual harassment can occur between any individuals, regardless of their sex or gender. New York Law protects employees, paid or unpaid interns, and non-employees, including independent contractors, and those employed by companies contracting to provide services in the workplace. Harassers can be a superior, a subordinate, a coworker or anyone in the workplace including an independent contractor, contract worker, vendor, client, customer or visitor.

Where can sexual harassment occur?

Unlawful sexual harassment is not limited to the physical workplace itself. It can occur while employees are traveling for business or at employer sponsored events or parties. Calls, texts, emails, and social media usage by employees can constitute unlawful workplace harassment, even if they occur away from the workplace premises, on personal devices or during non-work hours.

Retaliation

Unlawful retaliation can be any action that could discourage a worker from coming forward to make or support a sexual harassment claim. Adverse action need not be job-related or occur in the workplace to constitute unlawful retaliation (e.g., threats of physical violence outside of work hours).

Such retaliation is unlawful under federal, state, and (where applicable) local law. The New York State Human Rights Law protects any individual who has engaged in “protected activity.” Protected activity occurs when a person has:

Even if the alleged harassment does not turn out to rise to the level of a violation of law, the individual is protected from retaliation if the person had a good faith belief that the practices were unlawful. However, the retaliation provision is not intended to protect persons making intentionally false charges of harassment.

Reporting Sexual Harassment

Preventing sexual harassment is everyone’s responsibility. GCA cannot prevent or remedy sexual harassment unless it knows about it. Any employee, paid or unpaid intern or non-employee who has been subjected to behavior that may constitute sexual harassment is encouraged to report such behavior to the CCO. Anyone who witnesses or becomes aware of potential instances of sexual harassment should report such behavior to a supervisor, manager or the CCO.

Reports of sexual harassment may be made verbally or in writing. A form for submission of a written complaint is attached to this Policy, and all employees are encouraged to use this complaint form. Employees who are reporting sexual harassment on behalf of other employees should use the complaint form and note that it is on another employee’s behalf.

Employees, paid or unpaid interns or non-employees who believe they have been a target of sexual harassment may also seek assistance in other available forums, as explained below in the section on Legal Protections.

Supervisory Responsibilities

All supervisors and managers who receive a complaint or information about suspected sexual harassment, observe what may be sexually harassing behavior or for any reason suspect that sexual harassment is occurring, are required to report such suspected sexual harassment to the CCO.

In addition to being subject to discipline if they engaged in sexually harassing conduct themselves, supervisors and managers will be subject to discipline for failing to report suspected sexual harassment or otherwise knowingly allowing sexual harassment to continue.

Supervisors and managers will also be subject to discipline for engaging in any retaliation.

Complaint and Investigation of Sexual Harassment

All complaints or information about sexual harassment will be investigated, whether that information was reported in verbal or written form. Investigations will be conducted in a timely manner and will be confidential to the extent possible.

An investigation of any complaint, information or knowledge of suspected sexual harassment will be prompt and thorough, commenced immediately and completed as soon as possible. The investigation will be kept confidential to the extent possible. All persons involved, including complainants, witnesses and alleged harassers will be accorded due process, as outlined below, to protect their rights to a fair and impartial investigation.

Any employee may be required to cooperate as needed in an investigation of suspected sexual harassment. GCA will not tolerate retaliation against employees who file complaints, support another’s complaint or participate in an investigation regarding a violation of this policy.

While the process may vary from case to case, investigations should be done in accordance with the following steps:

Legal Protections and External Remedies

Sexual harassment is not only prohibited by GCA but is also prohibited by state, federal, and, where applicable, local law.

Aside from the internal process at GCA, employees may also choose to pursue legal remedies with the below governmental entities. While a private attorney is not required to file a complaint with a governmental agency, employees may seek the legal advice of an attorney.

In addition to those outlined below, employees in certain industries may have additional legal protections.

State Human Rights Law (HRL)

The Human Rights Law (“HRL”), codified as N.Y. Executive Law, art. 15, § 290 et seq., applies to all employers in New York State with regard to sexual harassment, and protects employees, paid or unpaid interns and non-employees, regardless of immigration status. A complaint alleging violation of the Human Rights Law may be filed either with the Division of Human Rights (“DHR”) or in New York State Supreme Court.

Complaints with DHR may be filed any time within one year of the harassment. If an individual did not file at DHR, they can sue directly in state court under the HRL, within three years of the alleged sexual harassment. An individual may not file with DHR if they have already filed a HRL complaint in state court.

Complaining internally to GCA does not extend an employee’s time to file with DHR or in court. The one year or three years is counted from date of the most recent incident of harassment.

Employees do not need an attorney to file a complaint with DHR, and there is no cost to file with DHR.

DHR will investigate the employee’s complaint and determine whether there is probable cause to believe that sexual harassment has occurred. Probable cause cases are forwarded to a public hearing before an administrative law judge. If sexual harassment is found after a hearing, DHR has the power to award relief, which varies but may include requiring GCA to take action to stop the harassment, or redress the damage caused, including paying of monetary damages, attorney’s fees and civil fines.

DHR’s main office contact information is: NYS Division of Human Rights, One Fordham Plaza, Fourth Floor, Bronx, New York 10458. You may call (718) 741-8400 or visit: www.dhr.ny.gov.

Contact DHR at (888) 392-3644 or visit dhr.ny.gov/complaint for more information about filing a complaint. The website has a complaint form that can be downloaded, filled out, notarized and mailed to DHR. The website also contains contact information for DHR’s regional offices across New York State.

Civil Rights Act of 1964

The United States Equal Employment Opportunity Commission (“EEOC”) enforces federal anti-discrimination laws, including Title VII of the 1964 federal Civil Rights Act (codified as 42 U.S.C. § 2000e et seq.). An employee can file a complaint with the EEOC anytime within 300 days from the harassment. There is no cost to file a complaint with the EEOC. The EEOC will investigate the complaint and determine whether there is reasonable cause to believe that discrimination has occurred, at which point the EEOC will issue a Right to Sue letter permitting the individual to file a complaint in federal court.

The EEOC does not hold hearings or award relief, but may take other action including pursuing cases in federal court on behalf of complaining parties. Federal courts may award remedies if discrimination is found to have occurred. In general, private employers must have at least 15 employees to come within the jurisdiction of the EEOC.

An employee alleging discrimination at work can file a “Charge of Discrimination.” The EEOC has district, area, and field offices where complaints can be filed. Contact the EEOC by calling 1-800-669-4000 (TTY: 1-800-669-6820), visiting their website at www.eeoc.gov or via email at info@eeoc.gov.

If an individual filed an administrative complaint with DHR, DHR will file the complaint with the EEOC to preserve the right to proceed in federal court.

Local Protections

Many localities enforce laws protecting individuals from sexual harassment and discrimination. An employee should contact the county, city or town in which they live to find out if such a law exists. For example, employees who work in New York City may file complaints of sexual harassment with the New York City Commission on Human Rights. Contact their main office at Law Enforcement Bureau of the NYC Commission on Human Rights, 40 Rector Street, 10th Floor, New York, New York; call 311 or (212) 306-7450; or visit www.nyc.gov/html/cchr/html/home/home.shtml.

Contact the Local Police Department

If the harassment involves unwanted physical touching, coerced physical confinement or coerced sex acts, the conduct may constitute a crime. Contact the local police department.

GLOBAL CREDIT ADVISERS, LLC
SEXUAL HARASSMENT COMPLAINT FORM

New York State Labor Law requires all employers to adopt a sexual harassment prevention policy that includes a complaint form to report alleged incidents of sexual harassment. Global Credit Advisers, LLC’s (“GCA”) policy can be found in your Compliance Manual if you are a GCA employee.

If you believe that you have been subjected to sexual harassment, you are encouraged to complete this form and submit it to: (i) Timothy Finn (tfinn@globalcreditadvisers.com; 212-949-1623; GCA, 100 Park Avenue, 35th Floor, NY, NY 10017); or (ii) your supervisor. GCA will not retaliate against you for filing a complaint.

If you are more comfortable reporting in another manner (such as verbally), Timothy Finn or your supervisor should complete this form, provide you with a copy and then GCA will follow its sexual harassment prevention policy by investigating the claims as outlined at the end of this form.

For additional resources, visit: ny.gov/programs/combating-sexual-harassment-workplace

YOUR INFORMATION

Instructions for Employers

If you receive a complaint about alleged sexual harassment, follow your sexual harassment prevention policy.

An investigation involves:

While the process may vary from case to case, all allegations should be investigated promptly and resolved as quickly as possible. The investigation should be kept confidential to the extent possible.

Document the findings of the investigation and basis for your decision along with any corrective actions taken and notify the employee and the individual(s) against whom the complaint was made. This may be done via email.

Exhibit D — Safe and Sick Leave Policy

New York City Notice of Employee Rights: Safe and Sick Leave

Notice of Employee Rights: Safe and Sick Leave

If you work part time or full time at any size business or nonprofit in NYC or if you work in an NYC household as a domestic worker, you have the right to safe and sick leave to care for yourself or anyone you consider family. You have this right regardless of your immigration status. Your employer must give you this notice explaining your rights.

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