EX-99.p.3

Code of Ethics

Securian Asset Management, Inc.

Introduction

Rule 204A-1 under the Investment Advisers Act of 1940 (the “Advisers Act”) and Rule 17j-1 under the Investment Company Act of 1940, as amended (the “1940 Act”), require that each registered investment adviser adopt and implement a written code of ethics that, at a minimum, contains provisions regarding:

In accordance with Rule 204A-1 and Rule 17j-1, this Code of Ethics (the “Code”) sets forth the standards of business conduct expected of all Supervised Persons of Securian Asset Management, Inc. (“Securian AM”). The purpose of this Code is to prevent and detect violations of applicable federal securities laws by Securian AM and its Supervised Persons, and to promote ethical and professional conduct. The Code is based upon the principle that Securian AM owes a fiduciary duty to its clients. As such, Supervised Persons must perform their duties in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with Securian AM, and (iii) where appropriate, mitigate any actual or potential conflicts of interest. The provisions of the Code are not all-inclusive. Rather, they are intended as a guide to alert Supervised Persons to significant issues that may arise. However, this Code is not a summary of all laws or policies that apply to Securian AM’s business. Accordingly, Supervised Persons are expected to adhere to the spirit, and not just the letter, of the Code in meeting Securian AM’s fiduciary obligations to its clients. Any situation where there is uncertainty or questions as to the intent or application of the provisions of the Code should be directed to the Chief Compliance Officer (the “CCO”) of Securian AM.

Violations of the Code may result in disciplinary actions, including, but not limited to, written letters of warning, re-certification of the Code, sanctions, disgorgement of profits, and/or termination of employment.

Certification

All Supervised Persons are required to certify their receipt and understanding of, and agree to comply with, the Code within ten (10) business days of becoming a Supervised Person. On an annual basis, all Supervised Persons are required to re-certify their understanding of, and compliance with, the Code via the compliance administration system, Orion. Additional reporting and certification requirements are included in the Gifts and Entertainment and Personal Securities Transactions sections of the Code.

Personal Securities Transactions

The restrictions and limitations on personal securities trading activity set forth below only apply to Access Persons. Generally, Access Persons may engage in personal securities transactions for their own accounts or for the accounts of their immediate family members sharing the same household, or other persons with whom they have a Beneficial Ownership, provided that they fully comply with the Code. For purposes of the Code, “immediate family members” include any child, stepchild, grandchild, parent, stepparent, grandparent, spouse, domestic partner, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, and includes adoptive children, stepchildren, that share the same household as the Access Person. Personal securities transactions conducted by Access Persons must be executed in a manner consistent with Securian AM’s fiduciary obligations to its clients: trades must avoid actual or potential conflicts of interest, as well as the appearance of impropriety.

The Code applies to all personal trading accounts holding, or that are permitted to hold, any Reportable Securities over which Access Persons have any Beneficial Ownership. It may be possible for Access Persons to exclude accounts held personally or by immediate family members sharing the same household from the Code if the Access Person does not have any direct or indirect influence or control over the accounts (a “Managed Account”). Access Persons must obtain the written approval of the CCO before excluding any accounts held personally or by immediate family members sharing the same household.

Access Persons must provide periodic reports regarding transactions and holdings in all “Reportable Securities,” which include any security except the following (collectively, “Non-Reportable Securities”):

Access Persons must obtain pre-clearance for all Reportable Securities transactions via Orion. Non-Reportable Securities transactions are exempt from pre-clearance. If pre-clearance is approved, the approval is effective for a two (2) business day period. After the two (2) business day period expires, a new request for pre-clearance must be submitted.

Access Persons are required to submit both holdings reports as well as transaction reports to Securian AM Compliance for Reportable Securities over which they or immediate family members have a Beneficial Ownership, on the frequency set forth below.

1. Initial Disclosure of all Accounts and Holdings. Access Persons must submit a report listing all personal trading accounts over which the Access Person or their immediate family members have a Beneficial Ownership, that hold, or that are permitted to hold, Reportable Securities, to Securian AM Compliance via Orion within ten (10) business days of becoming an Access Person. The initial disclosure report must also include all current holdings of Reportable Securities and must be current as of a date no more than forty-five (45) days prior to the date the individual first becomes an Access Person.

2. Newly Established Accounts. Access Persons must report the opening of any new personal trading accounts over which the Access Person or their immediate family members have a Beneficial Ownership, that hold, or that are permitted to hold, Reportable Securities to Securian AM Compliance via Orion within thirty (30) days of account establishment. Any newly established account is subject to the preclearance requirements set forth above in Section C. The Access Person is responsible for ensuring that Securian AM Compliance is provided with all holdings in the account, as well as of any transactions that may have taken place in the account since the account’s inception.

3. Quarterly Reports. Within thirty (30) calendar days following the end of each calendar quarter, Access Persons must report all Reportable Securities transactions in personal trading accounts over which the Access Person or immediate family members have a Beneficial Ownership for the full quarter to Securian AM Compliance via Orion.

4. Annual Reports. On or before February 15, of each year, Access Persons must report all personal trading accounts and holdings over which the Access Person or their immediate family members have a Beneficial Ownership, that hold, or that are permitted to hold, Reportable Securities as of yearend, to Securian AM Compliance via Orion.

Access Persons may satisfy all the transactions reporting requirements required under the Code by providing Securian AM Compliance duplicate account statements for transactions placed through a broker-dealer, provided the statements includes, at a minimum, the following:

5. Exceptions from Reporting Requirements. Access Persons are not required to provide reports for the any of following:

a. Reportable Securities transactions held in Managed Accounts;

b. Reportable Securities transactions effected pursuant to an automatic investment plan (e.g., 401(k) plans that do not have a brokerage account option, and dividend reinvestment plans); and

c. Reportable Securities transactions held in accounts with a direct electronic broker feed within Orion.

Any personal trading accounts that may be eligible for these exceptions should immediately after such accounts are established be brought to the attention of the CCO, who will, on a case-by-case basis, determine whether an account qualifies for an exception and make a record of such determination. In making this determination, the CCO may ask for supporting documentation, such as a copy of the automatic investment plan, a copy of the discretionary account management agreement, and/or a written certification from an unaffiliated investment adviser and/or broker-dealer.

The Code is designed to mitigate material conflicts of interest associated with Access Persons’ personal trading activities. Accordingly, Securian AM Compliance will closely monitor Access Persons’ investment patterns to detect the following behavior that violates or potentially violates federal securities laws including but not limited to:

Any personal trading that violates or potentially violates federal securities laws will result in further inquiry by the CCO and may result in sanctions.

Securian AM and/or Access Persons may receive information that may be deemed to be material non-public information (“MNPI”). Consequently, Securian AM Compliance may choose to restrict personal trading in a security of a company or issuer by placing the company or issuer on a restricted list (“MNPI Restricted List”) and/or creating a restricted group for Access Persons that are in possession of MNPI. Access Persons that are part of a MNPI restricted group are prohibited from trading in any security of a company or issuer on the MNPI Restricted List. All questions relating to MNPI or whether a Supervised Person possesses, or may possess, MNPI should be directed to the CCO.

If you receive MNPI about a public company, you must immediately notify the CCO, so that it can be added to the MNPI Restricted List.

Gifts and Entertainment

Securian AM recognizes that certain Access Persons may receive or provide gifts, business meals or other entertainment from or to persons or entities that do business with or on behalf of Securian AM, such as brokers, dealers, custodians, service providers, sub-advisers, or clients. However, such gifts or entertainment may create actual or potential conflicts of interest with the interests of Securian AM’s clients or may otherwise violate the fiduciary duty that Securian AM owes to its clients.

Any gift that violates the Code must be refused or immediately returned, or the Access Person must consult with the CCO or his or her designee to determine the appropriate action under the circumstances. When in doubt about a gift, fully disclose the nature of the situation to the CCO prior to accepting a gift.

Conflicts of Interest and Disclosure

Securian AM recognizes that Access Persons may encounter situations or circumstances that may create actual or potential conflicts of interest with the interests of Securian AM’s clients or may otherwise violate the fiduciary duty that Securian AM owes to its clients.

Electronic Communications

All electronic communications relating to Securian AM’s business activities must be conducted through Securian AM’s approved electronic communication channels, which, as of the date of this Code, are Microsoft Teams, Bloomberg, WebEx, Zoom and Outlook. Electronic communications include, but are not limited to, emails, instant messages, text messages, voice messages, video messages, social media posts, and any other forms of electronic communication that may be used to communicate with clients, service providers, sub-advisers, regulators, or other third parties.

These channels are subject to Securian AM’s supervision, retention, and retrieval policies and procedures, and are designed to ensure that Securian AM maintains accurate and complete records of its electronic communications.

Securian AM prohibits the use of any other electronic communication channels, such as text messaging, personal email, WhatsApp, social media, or any other unapproved applications on unapproved platforms, for any business-related purposes. These channels are not subject to Securian AM’s supervision, retention, and retrieval policies and procedures, and may pose significant risks to Securian AM’s compliance with books and records requirements, as well as the protection of confidential and sensitive information.

Any Access Person of Securian AM who receives or sends any business-related electronic communication through an unapproved channel must immediately forward or copy the communication to

Securian AM’s approved channel and notify the CCO or his or her designee of the incident. The CCO or his or her designee will review the communication and determine the appropriate corrective action, which may include disciplinary measures, additional training, or reporting to Securian AM leadership.

Compliance and Reporting

Securian AM is committed to ensuring compliance with this Code and with all applicable laws and regulations governing its business activities. Securian AM has designated the CCO as the person responsible for administering and enforcing this Code, and for overseeing the compliance program of Securian AM. The CCO has the authority and the duty to interpret, implement, monitor, and review this Code and the compliance program, and to report any issues or violations to Securian AM’s management and the appropriate authorities. Access Persons must acknowledge in writing that they have received, read, understood, and agreed to comply with this Code, within 10 (ten) business days upon joining Securian AM and on an annual basis thereafter via Orion.

Client Confidentiality

All Supervised Persons have a responsibility to protect the confidentiality of information relating to Securian AM clients and their accounts. This responsibility may be imposed by law, may arise out of agreement with clients, or may be based on policies and practices adopted by Securian AM. Any nonpublic information concerning Securian AM clients that Supervised Persons acquire in connection with their employment with Securian AM is confidential. This includes information regarding actual or contemplated investment decisions, portfolio composition, investment recommendations, and client interests and holdings. The restriction of disclosing client information is not intended, nor shall it be interpreted, to prevent Supervised Persons from reporting to any regulatory authority or government body any conduct a Supervised Person believes to be in violation of the law, or from responding truthfully to questions or requests from a government body or regulator in a court of law.

Amendments

The CCO shall review the Code at least annually in light of legal, regulatory, and/or business developments to ensure the Code remain adequate and effectively implemented. Supervised Persons will be informed of any substantive changes to the Code as a result of this review and will be required to re-certify that they have received, read, understood, and agreed to comply with the revised Code.