Contents

	Purpose	02
	How this policy embodies	02
	‘our shared beliefs’
	Ethical principles	02
	Conflicts of interest	03
	Policy	04
	Monitoring	05
	Record keeping	05
	Appendix - Global regulatory	06
	requirements
	Scope	08
	Index of updates	09

Policy maintainance and approval

The policy is maintained by the Compliance Department.

The policy is reviewed on an at least annual basis by the Compliance Policy Review Group, on behalf of the Operational Compliance Committee (OCC).

Any material changes to the policy are approved by the Group Compliance Committee (GCC) on behalf of the relevant entities.

The policy can be shared externally.

Date of last CPRG review: December 2024

Reason for review: Annual review

Policy owner: Adam McIntosh

Any queries regarding the policy should be referred to the policy owner.

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:

șEthical principles aligned with global conduct regulations.

șConflicts of Interest guidance.

șPolicy requirements, such as personal account dealing, inducements, and outside business interests.

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.

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:

șMisleading a client about the risks of an investment.

șMisleading a client about the likely performance of a product by providing inappropriate projections of future returns.

șFailing to acknowledge or resolve mistakes in dealing with clients.

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:

șFalsifying documents.

șProviding false information to clients, regulators, auditors, or third parties.

șMismarking investment values.

șMisleading others about accepted risks.

șFailing to disclose personal dealings, gifts, political contributions, or outside interests as required by the Code of Ethics.

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:

șProviding false or inaccurate information to regulators.

șFailing to supply requested documents or information within the required time.

șNot attending interviews or answering questions from regulators.

Code of ethics policy

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:

șInsider dealing.

șUnlawful disclosure of material non-public information.

șMarket manipulation through inappropriate trading activities.

șMarket manipulation through inappropriate communication activities.

șUsing non-recorded electronic communication devices and/or applications for regulatory business activities.

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:

șPrioritising Baillie Gifford profits over client interests.

șMisuse of proprietary information for personal gain.

șNot informing clients about potential conflicts of interest that could affect investment decisions.

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:

șUnauthorised sharing of client information with a third party.

șImproper use of client data for personal gain.

șNegligent data handling leading to unauthorised access to sensitive information, compromising client privacy and trust.

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:

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șPersonally owning shares in a company and not disclosing this potential conflict to a group of decision-makers discussing a potential transaction in shares of the company on behalf of clients.

șNot fully disclosing all personal shareholdings in an initial or annual Code of Ethics declaration.

șNot fully disclosing all information requested by the Compliance Department or a regulator.

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:

șIndividuals making financial gains or avoiding losses at the client’s expense.

șHaving personal interest in the outcome of services or transactions that differs from the client’s interest.

șFinancial or other incentive which favours one client over another.

șIndividual is in the same business as the client; and

șInducements from individuals in relation to client services (monetary, goods, or services).

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).

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:

șRead and understand the Code thoroughly.

șSubmit a Code of Ethics declaration, disclosing your personal account broker accounts, shareholdings, outside business interests, political contributions from the last two years, and certify your understanding.

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:

șFollow the Firm’s guiding ethical principles.

șTake responsibility for personal compliance risks related to the Code of Ethics.

șUse the Firm’s Code of Ethics System to obtain pre-clearance for personal activities (where required) and log compliance records.

șUnderstand that the Compliance Department is available for advice but prioritises client and Firm matters over personal issues of staff.

In addition:

șThe Head of Compliance (whom failing, a delegate) can clarify the Code’s meaning and provide waivers in exceptional cases, except where it would breach regulatory requirements.

șA material violation of the Code may result in disciplinary action, remuneration clawback, or reporting a Conduct Rule breach to the UK Financial

Conduct Authority and other applicable regulators. 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:

șYou know Baillie Gifford is actively considering an investment opportunity.

șBaillie Gifford is trading applicable securities for clients.

șYou or Baillie Gifford possess material non-public information.

șIt involves misuse or improper disclosure of confidential or proprietary information related to clients or trading.

In addition:

șDo not advise, recommend or procure others to enter transactions prohibited under our PA dealing requirements. This includes disclosure of information or opinion which is likely to result in such transactions.

șDo not enter a PA deal or insurance contract to hedge against deferred remuneration risks

șObtain pre-clearance using the System before PA dealing in applicable securities. After pre-clearance, instruct the PA deal with your broker by the close of business the next working day.

șAvoid buying and selling, or selling and buying, the same or equivalent securities within 60 days.

șIf you have specific knowledge of a pending

Investment Trust share buy-back, refrain from PA dealing in that Investment Trust until completion.

șProfits from PA dealing in violation of the Code may be subject to disgorgement.

Specific to the Investment department:

șInvestment team members cannot PA deal within seven days before or after clients in a strategy they are involved in have traded the same security. If unaware of pending client activity when requesting pre-clearance, you will not violate the Code.

șInform decision-making groups if you own shares in a company under discussion and consider withdrawing from discussions if there is an unmanageable conflict of interest. Compliance can provide advice and record-keeping support case-by-case.

Inducements

șDo not accept gifts, favours, entertainment, hospitality, or other inducements of material value that could influence your decision-making or make you feel obligated to someone or their company.

șSimilarly, do not offer such inducements that could influence the recipient’s decision-making or make them feel obligated to you or Baillie Gifford.

șSoliciting gifts, hospitality, entertainment, or anything of value is prohibited.

șGiving or receiving cash gifts is also prohibited, and no cash donations should be made in connection with clients or prospective clients.

șAll staff must consider political contributions from a conflict of interest and transparency perspective. There are specific US “pay-to-play” requirements that introduce pre-clearance requirements, detailed in the Inducements supporting document.

șGiving or receiving gifts is acceptable if the gift is below approximately £50 (or equivalent in another currency) in value and does not occur frequently.

Options for scenarios where the value is greater are detailed in the Inducements supporting document, along with record-keeping requirements.

șExercise discretion in the value and frequency of business lunches, dinners, and entertainment or hospitality you give or receive. Further details are included in the Inducements supporting document.

șSome clients have specific Code of Ethics requirements that may exceed our own. Consider these additional requirements when giving gifts or entertainment.

Outside business interests

șBe able to identify, disclose to Compliance and manage any outside activities or personal associations that could negatively impact your job performance, conflict with Baillie Gifford’s interests and/or harm client relationships. If you have any concerns, seek advice from Compliance.

șDisclose proposed external positions promptly to Compliance, and in some cases, obtain pre-clearance based on the relevance to Baillie Gifford’s business, your role, and your regulatory registrations. Further details are included in the Outside Business Interests supporting document.

șThe Compliance Conduct & Market Oversight team, using the Code of Ethics System, handles all outside business interest disclosures and shares relevant information with the Human Resources, Group

Governance Services, and Anti-Financial Crime

Departments. If needed, the team will secure approval from the Head of Compliance (whom failing, a delegate) and the Chief Compliance Officer of any relevant Baillie Gifford entity, confirming receipt or requesting further information. Partners or Chief Executive

Officers of Baillie Gifford subsidiary companies must also obtain approval from a Managing Partner for external appointments.

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.

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.

Employee	Employee
Partner	Partner
Fixed term	Employee
Temporary and agency staff	Contingent worker
Interns and summer students	Employee
Secondees	Employee
Individuals providing services via personal service companies	Contingent worker
Contractors (with material systems access)	Contingent worker
Independent non-executive directors of BG entities	Contingent worker
Non-executive directors of MUBG	Contingent worker
Staff pension scheme trustees	Contingent worker

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Baillie Gifford & Co	BG&CO
Baillie Gifford & Co Ltd	BG&CoLtd
Baillie Gifford Overseas Ltd	BGO
Mitsubishi UFJ Baillie Gifford Asset Management Limited	MUBG
Baillie Gifford International LLC	BGI
Baillie Gifford Funds Services LLC	BGFS
Baillie Gifford Asia (Hong Kong) Ltd	BGA(HK)
Baillie Gifford Investment Management (Europe) Ltd	BGE
Baillie Gifford Investment Management (Shanghai) Ltd	BGIMS
Baillie Gifford Overseas Investment Fund Management (Shanghai) Ltd	BGQS
Baillie Gifford Asia (Singapore) Private Limited	BGAS

Regulatory scope

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Asset Management Association of China	AMAC
Australian Securities & Investment Commission	ASIC
Central Bank of Ireland	CBI
Dutch Authority for The Financial Markets	AFM
Federal Financial Supervisory Authority	BaFIN
Financial Conduct Authority	FCA
Financial Industry Regulatory Authority	FINRA
Financial Sector Conduct Authority	FSCA
Financial Services Commission	FSC
Ontario Securities Commission	OSC
Securities & Exchange Commission	SEC
Securities & Futures Commission	SFC
Swiss Financial Market Supervisory Authority	FINMA
Monetary Authority of Singapore	MAS

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Calton Square, 1 Greenside Row, Edinburgh EH1 3AN Telephone +44 (0)131 275 2000 / bailliegifford.com

CS2612877 Code of Ethics Policy 0725 Copyright © Baillie Gifford & Co 2025. All rights reserved.