Exhibit 99.(p)(2)

BGOL Code of Ethics Manual

1.          Purpose

At Baillie Gifford, we fulfil our fiduciary duty to clients as investment managers and advisers. We commit to prioritising their interests, treating them fairly, and delivering positive outcomes. We avoid any conflicts where our interests might take precedence over theirs, guided by our Code of Ethics (‘Code’).

Our compliance culture and ethics are crucial to both clients and regulators. Clients view the Code as a reflection of our Firm’s culture and often inquire about code violations to gauge this culture.

Regulators emphasise ‘culture’ and ‘conduct,’ seeing culture as the business’s DNA that shapes behaviour and ethics. We have built our reputation through individual conduct, acting with integrity and in our clients’ interests.

The Code, enforced across all regulated entities and approved by our Group Compliance Committee, ensures regulatory compliance*. It includes:

2.          How this policy embodies ‘our shared beliefs’

Our clients come first.

We act with integrity, judging our actions and intentions through the eyes of our clients. We strive for excellence across all areas of the Firm and every contribution plays a role in developed trusted long-term partnerships with our clients.

3.          Ethical principles

All Partners and staff must adhere to the Firm’s guiding ethical principles, which align with regulatory conduct rules and codes of conduct from various professional organisations of which you may be a member.

In both personal and business life, we face ethical issues that require careful consideration. When making decisions, we must consider their impact on clients, ensure the decision-making process is fair and thorough, involve all relevant stakeholders, and identify any competing or conflicting interests.

The Ethical Principles are designed to prompt these considerations and help ensure that we put our clients interests first. They are as follows:

Fairness

Act fairly when dealing with clients and counterparties of Baillie Gifford by being impartial, objective, and honest. Examples of unfair conduct include:

Honest and integrity

Act honestly and with integrity in your role, avoiding actions that could harm Baillie Gifford’s reputation or are deceitful, oppressive, or improper. Use fair methods to win or retain business. Avoid offering lavish gifts, frequent hospitality, or engaging in ‘pay to play’ practices. Baillie Gifford is committed to conducting business fairly and has zero tolerance for bribery. Examples of conduct breaching honesty and integrity include:

Adherence to law and regulation

Follow applicable laws, regulations, and professional standards in your activities, applying them to the best of your knowledge and ability. Be open and cooperative with Baillie Gifford’s regulators. Familiarise yourself with and adhere to policies within the Personal Responsibilities section of the Group Compliance Manual. Examples of conduct that might breach openness and cooperation with regulators include:

Market conduct

When executing transactions, engaging in market dealings or communicating with counterparties, uphold market integrity and adhere to good practices and conduct expected of market participants.

Comply with relevant market codes and exchange rules. Examples of poor market conduct include:

Loyalty to clients

Put our clients’ interests ahead of your own and manage any conflicts of interest fairly and effectively. Avoid conflicts when possible, and manage and disclose them according to Baillie Gifford’s conflict procedures. Use Baillie Gifford’s investment recommendations and proprietary information exclusively for clients. Examples of disloyalty to clients include:

Maintaining confidentiality

Respect client confidentiality by not using or disclosing information about current, former, or prospective clients for unethical or illegal purposes. Share confidential client data with outside parties only when absolutely necessary, and obtain authorisation if required. If unsure, consult the Information Security policy which outlines data security classifications and handling rules. Examples of conduct which would breach confidentiality include:

Transparency

If you suspect a conflict of interest or believe there might be a perception of one, disclose the details to your Head of Department, the Compliance Department, or the relevant chairperson. Examples of conduct which would be untransparent include:

4.          Conflicts of interest

Conflicts can arise between Baillie Gifford, its Partners and employees, and a client. Conflicts can also arise between multiple clients. Situations giving rise to a conflict include:

You have a responsibility to identify potential conflicts from both a personal and Firm activity perspective.

This is supported through adherence to this Code and can be ensured by your vigilant identification, management or avoidance, and disclosure of conflicts of interest.

If you identify a new potential or unavoidable conflict at either a personal or Firm level, you have a duty to disclose to the Compliance department via the Conduct & Market Oversight team, using the following e-mail address: CodeofEthicsQueries@bailliegifford.com (secure mailbox).

5.          Policy

The following policy points are supplemented by a series of underlying supporting documents which also include guidance on how to use the Firm’s Code of Ethics System.

General

Upon starting your employment and annually thereafter, you must:

Note: Additional disclosure requirements for specific roles are detailed in the PA dealing supporting document and entity-specific compliance policies.

On an ongoing basis, you must:

In addition:

Report any potential violations immediately to the Conduct & Market Oversight team at CodeofEthicsQueries@bailliegifford.com (secure mailbox).

Personal account dealing

Baillie Gifford prioritises clients’ interests, ensuring they receive the best possible trade execution. To uphold this standard, you must avoid actions that could disadvantage clients through personal account (PA) dealing. The Firm permits PA dealing under specific restrictions, allowing you and your connected persons to conduct investment transactions within these guidelines. You must also ensure that PA dealing does not detract from your primary job responsibilities.

Note: “Connected persons” and a list of applicable securities are fully defined within the PA Dealing supporting document.

PA dealing is prohibited where:

In addition:

Specific to the Investment department:

Inducements

There are specific US “pay-to-play” requirements that introduce pre-clearance requirements, detailed in the Inducements supporting document.

Outside business interests

6.          Monitoring

The Group Compliance Monitoring Team is responsible for the compliance monitoring plan which, using a risk-based approach, seeks to provide assurance on our regulated activities. Where our risk assessment indicates monitoring is required, the Group Compliance Monitoring Team monitor for compliance with this policy. Where appropriate, a report of the results of this monitoring will be provided to the Group Compliance Committee or relevant board and the results of this monitoring will be taken into consideration when assessing the ongoing knowledge and competence of affected individuals.

7.          Record keeping

The Code of Ethics System is the repository for Code of Ethics activity records.

The Incident Management System is the repository for Code of Ethics violation records. This may prompt the creation and retention of records by the Conduct Assurance Group if a material violation is identified which prompts a conduct rule breach assessment.

All Code of Ethics activity and violation records are maintained in accordance with the Records Management Policy in the Group Compliance Manual.

Disclosure

A key aspect of Baillie Gifford’s Inducements Policy is disclosure. Under our procedures, all gifts (other than de minimis) and hospitality which are given or received are recorded in the Code of Ethics System. Disclosures should be made to your normal gifts and entertainment representatives for Trading, Investors and Clients Department, and Compliance for all other departments. Likewise, all members of staff should consider if an inducement which has been offered or received should be disclosed to a client, or potential client. This will depend upon the circumstances of each case and the Compliance Conduct & Market Oversight team can provide guidance (CodeofEthicsQueries@bailliegifford.com).

Gifts

Where the member of staff wishes to retain a gift above £50 (or equivalent in another currency), then the estimated cost of the gift above this limit should be paid to the Baillie Gifford Charity of the Year with details of this donation included with the Code of Ethics System record.

In all cases the prize offered should be of reasonable value, i.e., it should not be excessive or inappropriate. Any competition prizes won by a member of staff at a business-related event, e.g., a conference or seminar, should be recorded for transparency in the Code of Ethics System.

Entertainment

Business lunches/dinners –

Hospitality given –

Hospitality received –

Political contributions

Preclearance requests should be submitted by email to Baillie Gifford Group’s US-based Compliance Counsel and Compliance Conduct & Market Oversight team (CodeofEthicsQueries@bailliegifford.com).

Specific jurisdictional / entity requirements

Please contact Compliance for specific guidance in this area.

Outside business interests and personal associations

A personal conflict of interest can arise in relation to certain outside business interests or personal associations. Members of staff must ensure that they do not engage in any activities that would detract, divert from or conflict with the proper performance of their Baillie Gifford employment or would conflict with the interests of the firm or our clients. Members of staff must also ensure that any personal association does not affect, or reasonably appear to affect, our conduct or actions in Baillie Gifford and therefore conflict with our duties to clients or the firm.

To ensure that we comply with the requirements of global regulation, we require members of staff and Partners to inform Compliance at CodeofEthicsQueries@bailliegifford.com of any external interests at any time during employment.

Types of outside business interests

Outside business interest disclosures should be emailed to the Compliance Conduct & Market Oversight team (CodeofEthicsQueries@bailliegifford.com) at the earliest opportunity. Where possible, this should be prior to the commencement of any role or appointment.

Disclosures should contain the following information:

Please note that outside business interest disclosures are not one-off in nature. Members of staff have an ongoing obligation to notify Compliance at the earliest opportunity if there is a change in circumstances, e.g., change in role/involvement; change in remuneration; the outside interest has subsequently become a client, investee company or supplier etc.

If applicable, the Compliance Conduct & Market Oversight team will obtain approval from the Head of Compliance (whom failing, a delegate) on your behalf and will either confirm that this has been received or will request further information if required.

Please note that Partners or Chief Executive Officers of Baillie Gifford subsidiary companies who require to seek approval from the managing Partners for external appointments, must seek this approval themselves.

Specific jurisdictional / entity requirements

Personal Associations

We also must take steps to ensure that any personal interest or personal association does not affect, or reasonably appear to affect, our conduct or actions in Baillie Gifford and therefore conflict with our duties to clients or the firm. Any Significant Relationship with another person working in a relevant business connected to Baillie Gifford may need to be disclosed by email to the Compliance Department (CodeofEthicsQueries@bailliegifford.com).

Relevant businesses would include:

A relationship with another person would be deemed significant if an independent third party might reasonably consider that it could affect your actions or those of a personal associate (whether or not it does so affect your conduct). If you have a relationship with an associated person that could potentially give rise to a conflict of interest, or the perception of one, then this should be disclosed to the Compliance Department. The Compliance Department will determine if the relationship needs to be recorded and whether any action needs to be taken to manage the conflict.

Please note that personal associations can extend beyond the definition of connected person under PA Dealing, i.e., personal association disclosure requirements are not limited to immediate family members living in your household. Some examples of potential personal associations that may need to be disclosed are as follows:

Each scenario will be considered on a case-by-case basis to establish what, if any, conflict risk there is and determine if the personal association needs to be recorded. Under the general requirement to disclose conflicts of interest, members of staff should be mindful of any personal associations within Baillie Gifford that could potentially give rise to a conflict of interest and disclose accordingly.

These disclosures are designed to ensure that our work is carried out on behalf of clients in an environment that is free from any suggestion of improper influence. If you are in any doubt as to whether a business interest or personal association or relationship needs to be disclosed, please contact a member of the Compliance Department for guidance.

In general, Baillie Gifford’s PA dealing requirements apply to you and your “connected persons”, for investment holdings and transactions in “in-scope assets”. There may also be additional jurisdictional / entity level requirements which apply if you perform a specific role. The key definitions are as follows:

Connected persons –

In-scope assets –

Note: This list is not all-inclusive and may be updated from time to time. If unsure, please contact the Compliance Conduct & Market Oversight team for guidance (CodeofEthicsQueries@bailliegifford.com).

For further clarification:

Procedures for PA dealing

Prior to undertaking a PA deal, you are required to:

It is important that you take all reasonable steps to ensure that these procedures are followed by whoever is dealing. The onus is on you to raise awareness with your connected persons, obtain pre-clearance for proposed PA dealing and ensure that contract notes / trade confirmations are sent to Compliance.

Procedures for obtaining broker permission

Before you or a Connected Person begins to place transactions with a particular firm of stockbroker’s or on-line dealing platform, broker permission must be obtained and an account setup within the Code of Ethics System. The reason for this is to inform the broker that you work for Baillie Gifford and to ensure that brokers supply to Compliance, no later than 30 days after the end of the quarter in which the trading activity occurred, duplicate copies of confirmations of all personal securities transactions.

Broker notification letters can be used to notify the broker and are located in the related documents & links section of the Code of Ethics Exchange page – link.

Broker notification letters are not required for the following:

Procedures for obtaining PA dealing pre-clearance

You are also required to obtain electronic internal pre-clearance from the Code of Ethics System – link. Pre-clearance of a PA deal will remain valid until close of business on the next business day from the time permission is obtained. If the proposed transaction is not completed during the period in which the pre-clearance is granted, the member of staff must seek additional pre-clearance prior to completing the transaction. In the case of postal deals (e.g., deals that require an application form or instruction form to be completed, i.e., dealing is not direct through a broker); your dealing instruction should be sent within this pre-clearance period, although the trade itself does not have to be executed during the period.

The ‘Quick Guide to Trade Requests’ video sets out the procedures for submitting Trade Requests through the Code of Ethics System and is in the Document Library tab of the System – Link.

Please note that proposed PA deals in IPOs or Private Companies will require the use of the Private Transactions section of the System. The ‘Quick Guide to Private Transactions’ video in the Document Library tab of the System provides guidance. The key difference is that Compliance will need to review each request manually and, before providing approval, will need to obtain assurance that no conflicts with client interests will arise due to prospective PA deals in IPOs or Private Companies where client activity may also be taking place at the same time.

Special circumstances – Practical procedures

Reporting requirements

Specific jurisdictional / entity requirements