Exhibit 99(p)(23)

Code of Conduct

Contents

Code of Conduct

Dear colleague,

This Code of Conduct is a guide to how we conduct ourselves in our interactions with others. It helps us understand what is appropriate in our daily work. We want to be transparent about our expectations so we all can contribute to the organization we aspire to be. We hold ourselves accountable for both our colleagues and our stakeholders.

Robeco is a performance-driven and result-oriented organization. It is a key part of our identity, our corporate culture and our success. Performance at Robeco is a combination of both financial results and the appropriate conduct.

You are our most valuable asset, you represent Robeco. Without you, our products will not be sold, our research will not be shared, our technology will not innovate and our company will not excel. Our collective behavior and your personal behavior are what ultimately make or break Robeco.

This Code of Conduct applies to all colleagues within the Robeco group worldwide. ‘All colleagues’ means all current, former and contingent employees, whether full-time, part-time, permanent, temporary, internships or on secondment. Everyone is and must feel included.

Adhering to the Code of Conduct is also everyone’s responsibility at Robeco. Each of us is expected to read and know the Code of Conduct, understand what the Code means in your daily work and be committed to apply the Code in everything you do. You acknowledge that there can be serious consequences for non-compliance with the Code of Conduct for Robeco and yourself. You are encouraged to seek guidance from your manager, a compliance officer, HR business partner, internal confidential advisor, or other relevant function if you are unsure how to act in a certain situation.

This includes speaking up and reporting any suspected or actual violations of the Code of Conduct. Such reporting is essential for living up to our core values and maintaining a healthy, safe work environment for everyone within Robeco. Retaliation against those who report violations or raise ethical concerns in good faith is not tolerated.

I rely on you to apply the Code of Conduct whenever you act within or on behalf of Robeco. Because together we can ensure that for our approximately 1,100 colleagues, Robeco is a place where people feel welcome, colleagues feel empowered to do their best and we work together toward optimal results for all our stakeholders.

Thank you,

Karin van Baardwijk
CEO Robeco

Code of Conduct

Our foundation

Mission

We enable our clients to achieve their financial and sustainability goals by providing superior investment returns and solutions.

Values

Our core values reflect the essence of Robeco and serve as a reference for our daily work. They create and strengthen a clear and shared identity and drive the behavior needed to successfully achieve our strategic ambitions. Robeco has four core values:

Our long-term ambition

Our five key investment strengths - sustainable, quantitative, thematic, credit and emerging markets investing - are founded on Robeco’s intellectual capital and reinforce each other. Together they form a complementary engine for generating specialized alpha.

Robeco’s strategy represents a natural progression of that foundation. It builds on our strong heritage and proven alpha capabilities, while setting a clear long-term ambition: to become the preferred independent asset manager for specialized alpha across Europe and Asia-Pacific.

What we do

Founded in 1929, Robeco is an international asset manager that uses a combination of fundamental, sustainable and quantitative research. With our headquarters in Rotterdam, we have multiple international offices around the world, from Australia to Asia, the US and Europe.

Achieving our clients’ goals is central to our mission. By listening closely to their feedback, adapting our processes and developing new solutions, we aim to meet their unique needs, ambitions and challenges, helping them move forward with confidence.

We contribute to economic stability by, for example, helping pension funds provide financial security to their participants and investing in companies that generate employment. Through our commitment to sustainability we also aim to play a part in addressing the challenges of our time, such as climate change, protecting biodiversity and promoting social equality.

Research and innovation

Research is the foundation of every investment decision at Robeco. Our identity as The Investment Engineers reflects our belief that rigorous analysis, data and testing are essential to delivering consistent investment outcomes. Every strategy and product is thoroughly researched and continuously evaluated before and after it is offered to clients. Innovation at Robeco is driven by curiosity, critical thinking and a willingness to learn — including learning from past mistakes.

Code of Conduct

By continuously investing in research and innovation, we aim to stay ahead of developments in financial markets, regulation and client needs, and to translate knowledge into practical, high-quality investment solutions.

A culture of connection
Everyone at Robeco is equally essential to our operations, but that does not mean we are all the same. Quite the contrary, actually: we actively seek out employees with unique perspectives, qualities and talents to make us stronger as a whole. We know that embracing our differences and creating a culture where every colleague feels equally valued is vital for Robeco to thrive. Our differences can be our gold. But in order to strike it, we must be connected.

To achieve such a culture of connection, we need all of us to be open, stay curious and respect other people, views and perspectives. No one is asking you to change your beliefs, only to listen to others and accept that they can have other views and beliefs than you. That way, every single one of us can feel equally valued here, regardless of what we look like, where we come from or whom we love. 

Personal leadership at Robeco

Personal leadership and individual accountability are key to upholding our core values, delivering on our strategic goals and maintaining a healthy integrity culture. To provide guidance on said expectations, we have developed the following leadership priorities:

Secure base

Delivering results

Growth

These leadership priorities guide how we act in our daily practice and how we – colleagues and managers alike – develop in growing further.

Code of Conduct

Code of Conduct

The core principles of conduct set out below are structured around the different stakeholders that may experience the impact of your conduct in practice:

These principles help us to maintain a culture of honesty, integrity and accountability, based on trust and confidence. You are expected to follow these principles in every aspect of your work and all your dealings with clients, colleagues and other stakeholders as a representative of Robeco. We also expect you to perform your duties with due skill, care and diligence.

Many core principles and their surrounding processes are worked out in further detail in Robeco’s policies and procedures or external laws and regulations. An overview of links can be found at the end of this document. You are expected to be familiar with the internal policies and procedures that apply to your role or activities within Robeco and adhere to this internal guidance in your daily practice.

Please do not hesitate to actively seek guidance from your manager, a compliance officer, HR business partner, internal confidential advisor or other relevant function if the core principles provide insufficient or unclear guidance in a particular scenario.

Code of Conduct

Code of Conduct

Code of Conduct

You are expected to practice the core principles of conduct in every aspect of your work and all your dealings with clients and other stakeholders as a representative of Robeco. Although the principles seem very clear, in reality, however, things are not always black and white. You may sometimes find yourself in a gray area, where we ask you to rely on your own professional judgement on how to apply the principles. Applying the principles in practice is all about making careful and conscious choices and being able to provide good reasons and arguments for the choices you made.

Another reality is that different people may have different views on what they find acceptable or unacceptable behavior. The rule of thumb is to view the behavior from the perspective of the person on the receiving end. In this case, it does not matter whether the behavior occurs intentionally or unintentionally or is ‘just meant as a joke’. Because intent, seniority or humor do not justify behavior that makes others feel unsafe, excluded or disrespected.

To illustrate and provide guidance on how the principles can be applied, we provide some practical day-to-day examples regarding conduct among colleagues. These examples are non-exhaustive and whether conduct is appropriate or not always depends on the actual scenario.

Code of Conduct

To avoid misunderstandings and create a safe environment where colleagues feel confident in what they can say or do, it is recommended to actively discuss this among your colleagues. We also recommend engaging in dialogues on what a safe work environment means, how colleagues can optimally work together and how colleagues can give and receive feedback in a safe and constructive way. Encouraging and investing in these dialogues will help to foster a safe and strong performance culture.

To further support colleagues, HR provides training on inclusive behavior.¹ During this training colleagues can in an informal manner explore which conduct can be negatively perceived, how to unlearn such conduct and how to address inappropriate behavior in a constructive and engaging manner.

If you need to deal with a conduct-related dilemma, this checklist may help you to identify the best possible approach in the given situation:

¹ Colleagues can subscribe for the DEI Essential training by creating a learning ticket via MyWorkday. Sessions will be scheduled once a sufficient number of registrations has been received.

Code of Conduct

When experiencing unacceptable behavior, you may choose to speak directly to the person responsible, if that is a viable path. The purpose of the conversation is to give feedback and express your grievance. The desired outcome of the conversation is to avoid unacceptable behavior in the future.

Several people and functions are available for you to approach if you need help. You can be informed about what Robeco does to promote leadership, a strong culture and positive behavior or to discuss whether specific behavior could qualify as an integrity incident and what would be the preferred reporting channel.

Your (matrix) manager is the first person to reach out to, being responsible for creating a secure base for you and your team. Your manager is expected to create the circumstances for you to develop yourself, contribute to Robeco and its clients as well as to support and advice you in more difficult situations.

You can also turn to your HR business partner to discuss what Robeco offers in terms of personal support. The HR business partner can answer any questions regarding the Code of Conduct, and advice and assist you if you encounter behavior that seems to violate this Code.

Furthermore you can approach an internal confidential advisor to discuss any questions you may have regarding the Code of Conduct or behavior that you experience, in a confidential manner. The internal confidential advisors are trained to listen and advice you on how to deal with sensitive or challenging situations, and what routes you can follow.

Robeco also has an external confidential counselor who will listen to, guide and advise you in a confidential atmosphere.

Additionally, your compliance officer is always willing to listen to you and discuss any questions you may have regarding the Code of Conduct, how to apply the core principles in practice, as well as explain your options if you experience behavior violating the Code.

It is up to you to decide who you would like to ask for advice in a certain situation. You can take into account the circumstances such as confidentiality, anonymity, professional expertise, knowledge and understanding of the specific (Robeco) context of the situation. All the above mentioned persons and functions have been trained to handle challenging situations and they know how to safeguard confidentiality and the psychological safety of the person who seeks advice or support.

Code of Conduct

Adherence to the Code of Conduct is essential for all of us. Everyone in Robeco must adhere to the standards set forth in this Code of Conduct. No one is exempt from these requirements, regardless of the position you hold, the location of your job or the number of hours you work.

You are therefore expected to annually confirm in a statement that you are familiar with the Code of Conduct and that you abide to it in practice.

Whenever you witness any suspected or actual violations of the Code of Conduct, you are expected to speak up and report such infringements without delay. Conduct in violation of the Code may jeopardize Robeco’s goals and performance and keep us from being the organization we want to be for our colleagues, clients and business partners and all other stakeholders.

Within Robeco, violations of the core principles set out in section 3 are defined as ‘integrity incidents’. There are multiple channels available to you, both within and outside Robeco, to report integrity incidents. You are free to select whichever channel you feel most comfortable taking. You can report integrity incidents through the following different channels:

More information on the different reporting processes can be found in the Incident Management Policy, Integrity Incident & Whistleblowing Procedure and on the incident framework page on RobecoWorld.

² Contact details of our global external Confidential Counsellors can be found in MyWorkday, search for ‘Confidential Counsellors’.

Code of Conduct

Robeco has zero tolerance for retaliation against anyone who reports a concern or misconduct in good faith and with the reasonable belief that the information is true. No one has the authority to justify an act of retaliation and any employee who engages in retaliation will be subject to disciplinary action, which may include up to dismissal. You are not to be afraid or reluctant to speak up when appropriate.

You are expected to act with the highest sense of integrity and exercise unbiased judgment. Behaving in contravention of the core principles of the Code of Conduct (or other internal or external applicable to conduct rules) may, depending on the severity of the violation, lead to disciplinary measures which may include, but are not limited to:

You are also expected to comply with applicable laws. If you violate a criminal law applicable to Robeco’s business, the matter may be reported to the appropriate authorities.

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