Exhibit 99.(r)(2)

Code of Ethics

This Code of Ethics has been adopted by Ares Management LLC and its related investment advisers (“Ares” or the “Firm”) not only to fulfill technical compliance with applicable regulatory Code of Ethics Rules, including Section 204A and Rule 204A-1 under the Investment Advisers Act of 1940 (the “Advisers Act”), and Rule 17j-1 under the Investment Company Act of 1940 (the “1940 Act”), but also to prevent or mitigate actual or apparent conflicts of interest between the activities of Covered Persons and their Covered Family Members and the interests of Ares and its Clients and Investors.

Capitalized terms used throughout this Code of Ethics are defined in the . Please contact Compliance with any inquiries.

Policies

The Code of Ethics is comprised of the below policies:

General Standards

Covered Persons must certify in writing that they have read, understand, and will comply with this Code of Ethics upon becoming a Covered Person and must, at least annually thereafter, acknowledge being subject to the Code of Ethics and attest to continued compliance.

Covered Persons and their Covered Family Members are prohibited from:

Before recommending or authorizing the purchase, sale, or any other action, of a Security by or for a Client, Covered Persons must disclose to the CCO or designee on behalf of themselves and any Covered Family Members:

Confidentiality

All information submitted as required by this Code of Ethics will be treated as confidential and intended solely for internal use unless Ares is required to disclose it to a regulatory or governmental agency.

Review of Certifications/Reports and Information; Sanctions

The CCO or designee will oversee the review of all reports/certifications for any potential breaches of the Code of Ethics. If an actual or potential breach is detected, the Covered Person will first be offered an opportunity to supply additional explanatory information or material. If Compliance determines that a breach has occurred, the Company may impose appropriate sanction(s), such as the issuance of a warning or memorandum, reporting to senior management of the Firm, training, a ban on personal trading, disgorgement of profits, a suspension (with or without pay), or termination of employment or affiliation with the Firm.

Glossary

Approved Broker is an Ares-approved brokerage firm for Covered Accounts. The List of Approved Brokers is maintained on the Ares intranet.

Ares-Related Security means any Security issued by Ares Management Corporation or any Fund (including closed-end funds) advised by, sub-advised by, or otherwise affiliated with Ares. A list of Ares-Related Securities is maintained on the Ares intranet.

Beneficial Interest in a Security refers to a direct or indirect pecuniary interest. A Covered Person can have a Beneficial Interest in a Security in cases where sole or shared voting or investment power exists by reason of any contract, arrangement, understanding or relationship, even if the Security is held by another person.

Business Entertainment is any event, including any sporting or social activity, attended by a Business Partner and any Covered Person, in company with each other, that takes place within a business context or that has or could be seen as having a business dimension. This includes travel or lodging related to such event.

Business Gift is a gift directly or indirectly given to or received from a Business Partner and any Covered Person that takes place within a business context or that has or could be seen as having a business dimension. For gifts involving any individual with whom there is both a personal and business relationship, please contact a member of Compliance in advance for a determination of whether the gift qualifies as a Business Gift or a personal gift.

Business Meal is any event attended by a Business Partner and any Covered Person that takes place within a business context or that has a business dimension, that includes any meal, snacks and/or beverages only.

Business Partner is any current or potential Client, Investor, vendor, counterparty, FINRA member or Ares portfolio company – essentially, anyone with whom the Covered Person is conducting or is considering conducting Ares’ business.

Client refers to Ares’ advisory clients, which are comprised of various pooled investment vehicles, including public and private investment funds, single investor funds, co-investment vehicles, joint ventures, CLOs, CDOs and other structured investment vehicles, special purpose vehicles, alternative investment vehicles, feeder vehicles (collectively, “Funds”), and other separately managed accounts and institutional clients.

Covered Person means:

Directors of Ares Management Corporation and funds managed by Ares who do not have any material relationship with Ares that would interfere with the exercise of independent judgment in carrying out director responsibilities are not subject to the requirements of this Code of Ethics and are, therefore, excluded from the definition of Covered Persons for purposes of complying with it.

Covered Account means any account(s) maintained with any broker, dealer, bank or other financial institution that holds or may hold any Covered Securities in which a Covered Person and/or Covered Family Members have a Beneficial Interest.

Covered Family Member is i) your spouse or domestic partner; ii) minor children of you and your spouse or domestic partner; iii) immediate family member living in the same household; iv) any person whose financial affairs you control; v) any person for whom you provide discretionary investment advice/decisions; vi) any person who is financially dependent upon the employee; or vii) any partnership, corporation, or other entity in which you

a) exercise control or b) serve as a general partner, trustee, custodian, or in a similar capacity. If you have any questions whether an individual is considered a Covered Family Member, please contact Compliance.

Covered Security means any Security other than a Non-Reportable Security.

Investor refers to any current, prospective or former investor in a Client and any representatives of the same.

Managed Account means an account managed by an unaffiliated and strictly autonomous investment manager or third-party and over which a Covered Person or Covered Family Member has no direct or indirect influence or control.

Marquee Events are typically high-profile events that attract broad public interest, extensive media coverage, and publicity. Access is often limited due to premium pricing driven by high demand. Examples include, but are not limited to, the Super Bowl, Formula One races, the U.S. Open Finals, the NBA Finals, and major entertainment or art award shows. If you have a question about whether an event falls within the scope of this definition, please contact Compliance.

Non-Reportable Securities are:

Private Placement means a capital raising event that involves the sale of Securities directly to a private investor, rather than as part of a public offering, and includes any offering that is exempt from registration under the Securities Act of 1933, as amended, including, without limitation, pursuant to Section 4(a)(2) (or Rules 504, 505, 506 promulgated thereunder). Includes but is not limited to hedge funds, private equity funds, investment partnerships, fund of funds, Initial Coin Offerings, legal entities raising capital, and private REITs.

Political Contributions are any of the following:

Security means any note, share, treasury share, security future, bond, debenture, evidence of indebtedness, certificate of interest or participation in any profit-sharing agreement, collateral-trust certificate, preorganization certificate or subscription, transferable share, investment contract, voting-trust certificate, certificate of deposit for a security, fractional undivided interest in oil, gas, or other mineral rights, any put, call, straddle, option, or privilege on any security (including a certificate of deposit) or on any group or index of securities (including any interest therein or based on the value thereof), or any put, call, straddle, option, or privilege entered into on a national securities exchange relating to foreign currency, or, in general, any interest or instrument commonly known as a “security”, or any certificate of interest or participation in, temporary or interim certificate for, receipt for, guarantee of, or warrant or right to subscribe to or purchase, any of the foregoing, and includes, without limitation: (i) equity securities; (ii) shares of or interests in mutual funds, certain exchange-traded funds (ETFs) and unit investment trusts; (iii) derivative instruments or other structured products; (iv) securities issued in private placements; (v) debt/fixed income securities; and (vi) limited partnership and limited liability company interests.

A Single-Name Security is any Covered Security that provides equity or debt exposure to an individual publicly traded company. Single-Name Securities includes, but is not limited to:

Public Official is any of the following or any employee, agent or an intermediary acting on their behalf:

Personal Trading Policy

Covered Persons must place the interest of Ares Clients above their own personal interests. This Personal Trading Policy establishes standards of business conduct related to personal securities transactions, holdings, and related accounts.

Capitalized terms used throughout this Code of Ethics are defined in the Glossary. Please contact Compliance with any inquiries.

Restrictions on Securities Trades

Single-Name Security Ban

Covered Persons and Covered Family Members are prohibited from establishing new positions (long and short) in Single-Name Securities. This restriction is subject to the following exceptions.

Ares-Related Securities

All transactions, including trading plans for future transactions (i.e., 10b5-1s and dividend re-investment plans (DRIPs)), in Ares-Related Securities must be pre-cleared through the designated Compliance portal and are subject to the applicable Insider Trading Policy (or similar Policy) of each entity. Requests to establish or terminate DRIPs on Ares-Related securities will only be processed with pre-approval and within open trading windows. Executive Officers are not permitted to enter into DRIPs on ARES. Voluntary transactions in Ares-Related Securities are subject to a minimum 30-day holding period (e.g., cannot buy and then sell or sell and then buy).

Charitable donations and gifts, including donations to donor advised funds, of any Ares-Related Securities must be pre-approved through the Compliance portal and will only be approved during an open trading window, if applicable.

Ares-Related Securities received traded the quarterly exchange process is approved by Legal and not subject to the pre-approval and reporting requirements outlined in the Personal Trading Policy.

Pre-Clearing Securities Transactions

Except as expressly permitted by this Code of Ethics, Covered Persons must have written pre-approval for any transactions in a Covered Security, unless covered under the Pre-Approval Exceptions section below, before completing the transaction, including, without limitation, voluntary transactions in a Private Placement (initial investments, add-on-investments and redemptions).

The CCO or designee has full discretion over the approval process, and in certain circumstances (often related to protecting Ares and preserving confidential information, such as the nature of its trading or restricted issues), the reason for denial of a pre-clearance request or revocation of approval may not be disclosed. Generally, the CCO or designee will deny a pre-clearance request or revoke an approval for a requested personal securities transaction if it has the potential to:

Pre-Clearance Procedures

Before undertaking any transactions in a Covered Security on behalf of a Covered Person or Covered Family Member, a pre-clearance request must be submitted through the Compliance portal.

Approval Window

Pre-clearance for any transaction is valid for two (2) business days following the date on which approval is granted and will expire at the close of trading after the second business day. For example, if approval is granted on a Monday, it will remain valid through the close of trading on Wednesday. However, Private Placement approvals are valid until the closing of the offering.

If pre-approval expires prior to the execution of a transaction, a new pre-clearance request must be submitted through the Compliance portal prior to the next execution. “Limit,” “stop-loss,” “good-until-cancelled,” or “standing” orders must be fully executed before the pre-approval expires or a new pre-clearance request must be submitted and approved for continued execution of such orders.

Pre-Clearance Exceptions

Pre-approval is not required for any of the following, but transactions are still reportable:

Gifting Securities

Gifts of Covered Securities must properly be pre-cleared, as applicable, and reported in the Compliance Portal.

Giving: The gifting (including donations to donor advised funds/charitable giving accounts and donations to non-profits) of a Covered Security by you or your Covered Family Member is considered a sale transaction. As such, the pre-clearance and disclosure requirements outlined in this policy apply. Once pre-approval is received, the gift must be initiated within the approval window.

Receiving: Pre-clearance is not required for the receipt of Covered Securities as long as the donor is not an Ares business partner and the Security was selected at the full discretion of the donor.

Covered Accounts

Approved Broker Requirement

All Covered Persons must maintain Covered Accounts, for themselves and their Covered Family Members, with an Approved Broker.

New Covered Persons must close any Covered Accounts held with a non-Approved Broker within 90 days of becoming a Covered Person.

Account Reporting

All new Covered Accounts opened by Covered Persons and/or their Covered Family Members must be promptly reported through the Compliance portal and reported in the relevant certifications discussed below. Covered Persons and their Covered Family Members are prohibited from making any transactions that require pre-approval in a Covered Account unless such account has been reported through the Compliance portal.

Upon request by Compliance, Covered Persons must provide any required authorization to the broker to provide transactions and holdings information to Ares.

Covered Persons must also notify Compliance of any changes to account access, trading authority, or beneficiary designations for any Covered Account.

Duplicate Account Information and Electronic Monitoring

Covered Persons must ensure that transaction confirmations and account statements for Covered Accounts are promptly reported to Compliance. Such information may be forwarded directly to Compliance by the financial institutions where the accounts are maintained. If the financial institution does not or cannot directly provide transaction activity and holdings information on a regular basis, the Covered Person is responsible for promptly providing such trade confirmations and uploading the required statements to the Compliance portal.

Failure to provide required account information may result in trading restrictions or other remedial action.

Exceptions for Managed Accounts

Securities holdings or transactions made in Managed Accounts are exempt from the reporting requirements. Managed Accounts are not subject to the Approved Broker requirement.

To qualify for these exceptions, Covered Persons must provide Compliance with a copy of the investment management or advisory agreement evidencing the discretionary nature of the Managed Account. If such agreement is not available, the investment manager must otherwise attest or provide written confirmation directly to Compliance that the Covered Person and/or their Covered Family Members cannot directly or indirectly influence or control the trading or timing of Securities transactions in the account(s).

At the discretion of Compliance, Covered Persons may be required to complete periodic certifications to represent that they do not have the ability to influence or control trading in a Managed Account and that they will not attempt to do so. Covered Persons may also be required to inform their investment manager of Securities that are restricted. Any changes to the discretionary nature of a Managed Account must be promptly reported to Compliance.

Certifications

Covered Persons must submit various certifications through the Compliance portal or as otherwise directed by Compliance. These certifications must also include Covered Family Members’ information.

Initial Certifications

Covered Persons must complete and submit an Initial Disclosure Certification within ten (10) calendar days of being deemed a Covered Person. The certification requires, among other things, disclosure of certain Covered Account and Covered Securities holdings. The Covered Accounts and Covered Securities information reported in this certification must be dated within 45 days prior to the Covered Person being deemed a Covered Person. Failure to submit these certifications by the stated deadline will result in a prohibition from engaging in any personal securities transactions that require pre-approval until the certifications are submitted. Other sanctions may be applied as well.

Quarterly Certifications

Within 30 days of the end of each calendar quarter, unless on a leave of absence or other exception granted by the CCO or designee, Covered Persons must complete and submit a Quarterly Transaction Certification and a Quarterly Covered Account Certification. The Quarterly Transaction Certification requires disclosure of all Covered Securities transactions made by Covered Persons or their Covered Family Members during the quarter. Compliance may require additional certifications.

Annual Holdings Report

Within 30 days of each calendar year end, Covered Persons must complete an Annual Certification to report all Covered Securities held by them or their Covered Family Members as of the end of such calendar year. Covered Securities held in Managed Accounts are exempt from this reporting requirement.

Disclaimer of Beneficial Interest

For any personal Securities holdings information required to be reported in relation to any Covered Family Members’ securities holdings, Covered Persons may at any time deliver to the CCO or designee a statement that the submission of any such personal securities information does not constitute an acknowledgment that the Covered Person has any direct or indirect Beneficial Interest in any Securities about which information has been provided.

Political Contributions Policy

Ares has adopted this Political Contributions Policy in accordance with the U.S. Securities and Exchange Commission’s Pay-to-Play rule and seeks to avoid the perception that the Firm or its employees (directly or indirectly through family members living in your household) seek to influence the award of business to the Firm through Political Contributions.

Investment advisers that seek to influence the award of advisory contracts by public pension plans by making political contributions to, or soliciting them for, those officials who are in a position to influence the awards, compromise their fiduciary obligations to the public pension plans they advise and defraud prospective clients.

As Ares maintains relations in both the private and public sectors and does business with state and local governments and government entities, certain Political Contributions can result in Ares being disqualified from doing business with certain government entities and consequently unable to receive compensation for managing certain funds for a minimum period of two years. Capitalized terms used throughout this Code of Ethics are defined in the Glossary. Please contact Compliance with any inquiries.

Prohibited Political Contributions

All Covered Persons, and family members living in their household, are prohibited from:

Pre-Clearance Requirements

All Political Contributions made by Covered Persons, or family members living in their household, require pre-clearance from Compliance before such contribution is made.

All requests should be submitted for review and pre-clearance through the Compliance portal. Please note that submitting a pre-clearance request does not equate to affirmative approval and, in certain circumstances, requests may be denied.

In addition to being subject to pre-clearance requirements as noted above, all Political Contributions must be reported promptly through the Compliance portal once made.

Outside Business Activity Policy

The proper management of conflicts of interest is critical to the business and reputation of Ares Management LLC and its related investment advisers (“Ares” or the “Firm”). Ares has adopted this Outside Business Activity Policy that sets out the standards to perform certain activities outside the scope of employment relationships with Ares, and the management of potential conflicts arising from these activities. This policy is designed to detect, minimize and manage actual or potential conflicts of interests: between any outside business interests and the duties of a Covered Person through his or her employment with Ares; arising from work relationships of Covered Family Members; and arising from the previous employment relationships of Covered Persons.

Capitalized terms used throughout this Code of Ethics are defined in the Glossary. Please contact Compliance with any inquiries.

Outside Business Activities

Outside business activities are certain interests or activities undertaken by Covered Persons outside their role at or with Ares that may create an actual or perceived conflict of interest.

Covered Persons who engage in approved outside business activities are responsible for promptly reporting any changes to an approved activity to Compliance and to their direct supervisor.

Prohibited Outside Business Activity

Covered Persons are prohibited from engaging in any employment, business, or investment activities outside of Ares that might create an actual or perceived conflict of interest, unless such conflict can be appropriately mitigated as determined and stated in writing by the CCO, General Counsel, or designee. For the avoidance of doubt, this does not apply to any Ares-related roles. Such prohibited outside business activities include, but are not limited to:

Pre-Clearance Requirements

Covered Persons must obtain prior written approval from both their direct supervisor and the CCO or designee for outside business activities. Such approval, if granted, may be subject to restrictions, qualification and/or reporting to the Head of the Covered Person’s business unit and is revocable at any time. Examples of activities requiring pre-clearance include:

No approval is required to serve as a director of an organization that is exclusively charitable, civic, religious, or fraternal and is recognized as tax exempt, except in cases where such positions:

All pre-approval requests must be submitted through the Compliance portal.

Your request may be denied, and Covered Persons may be required to relinquish existing positions if Compliance determines that doing so is in the best interest of Ares or its clients at any time during employment or affiliation with the Firm.

Conflicts Involving Covered Family Members

If a Covered Person becomes aware of any situation in which an actual or potential conflict of interest exists regarding a Covered Family Member (for instance, if a Covered Family Member is a potential business partner), such relationship must be promptly reported to Compliance.

If a Covered Family Member serves or is appointed to serve as a director of a publicly traded company, such directorship must also be promptly reported to Compliance.

Interest in Transactions or Portfolio Positions

Covered Persons must disclose to Compliance any personal or family interest in any transaction by Ares on behalf of a Client. For example, if a Covered Person becomes aware that a transaction being considered or undertaken by Ares may benefit, directly or indirectly, the Covered Person or a Covered Family Member, such possibility must be promptly disclosed to Compliance.

Loans

Covered Persons are prohibited from knowingly borrowing from, or becoming indebted to, any person, business, or company that has business dealings or a relationship with Ares, except with respect to customary personal loans (e.g., home mortgage loans, automobile loans, lines of credit) on the same terms as are available generally, unless the arrangement is approved by the CCO, General Counsel or designee. Covered Persons may not use Ares’ name, position in a particular market, or goodwill to receive any benefit in loan transactions without the prior express written consent of the CCO, General Counsel or designee.

Diversion of Business or Investment Opportunities

Covered Persons are prohibited from acquiring, or deriving personal gain or profit from, any business or investment opportunity that comes to their attention as a result of their association with Ares and in which the Covered Person knows Ares or a Client might reasonably be expected to participate or have an interest, without first disclosing in writing all relevant facts to Ares, offering the opportunity to Ares, and receiving specific authorization from the CCO or designee.

Gifts and Entertainment Policy

Ares Management LLC and its related investment advisers (together, “Ares” or the “Firm”) recognize that business gifts and entertainment often promote goodwill and strengthen strategic relationships. However, despite good intentions, these exchanges can create an actual or perceived conflict of interest while increasing the risk of bribery and corruption. Unethical handling of such activities may cause financial losses, reputational harm, and civil or criminal liability for Ares or the individuals involved.

To identify and mitigate potential conflicts, Ares has adopted this Gifts and Entertainment Policy that guides Covered Persons when providing or accepting anything of value while conducting Ares business.

Capitalized terms used throughout this Code of Ethics are defined in the Glossary. Please contact Compliance with any inquiries.

Business Gifts, Entertainment and Meals

Business courtesies including gifts, standard business meals, or occasional social events are permitted if they do not improperly influence the recipient or impair the ability to make ethical business decisions that prioritize Ares Clients. In some jurisdictions, the giving and receiving of such Business Gifts, Entertainment or Meal must also be designed to enhance the quality of Ares’ services to Clients.

Solicitation of Business Gifts, Business Entertainment, Business Meals or favors of any kind that might create an actual or perceived conflict of interest or impropriety is strictly prohibited. Ares also prohibits all forms of bribery and corruption. Employees should fully comply with this policy and the Financial Crime Prevention Policies.

All Business Gifts, Business Entertainment and Business Meals given, regardless of dollar value, should be procured using Ares Corporate Amex where possible, and all expenses should be submitted through Concur in accordance with Ares’ Travel & Expense Policy.

For items of value involving individuals with whom a Covered Person has both a personal and business relationship, please contact Compliance in advance for a determination of whether this policy applies.

Business Gifts

A Business Gift may be in various forms including gratuity, reward, service, benefit, favor, discount, or anything else of value directly or indirectly given to or received from a Business Partner. To avoid the appearance of making business decisions based on Business Gift exchange, Ares has adopted the following pre-clearance and reporting requirements.

Covered Persons are prohibited from the following:

Pre-Clearance of Business Gifts

The following Business Gifts require pre-clearance from Compliance before such Business Gift can be given:

The following Business Gifts require approval from Compliance upon receipt:

Events where the host is not present, or where the host is present, but the invitation extends to a guest, are considered a Business Gifts. Marquee Events may not include guests (including, but not limited to, a spouse, domestic partner, or child) unless the cost associated with such guest is personally reimbursed by the relevant Covered Person or Business Partner.

Requests should be submitted for review and pre-clearance through the Compliance portal, or to Compliance. Approval is not guaranteed; if denied, a gift may need to be forfeited, returned, or donated to charity. Covered Persons should not open, consume, or use any Business Gift until approval is granted.

Reporting of Business Gifts

All Business Gifts received, regardless of value, should be promptly reported. The following Business Gifts are exempt from the pre-clearance and reporting requirements:

Business Entertainment and Meals

Business Entertainment and Business Meals must be reasonable and appropriate to the business context and not so frequent, extravagant, or questionable as to create an appearance of impropriety.

If you are attending an event, a Business Partner must be present at the event for the event to be deemed Business Entertainment. If a Business Partner is not present at the event, the invitation is deemed a Business Gift and thus subject to the Business Gift monetary limitations, restrictions, and approval or reporting requirements covered in this policy.

Likewise, if Ares is offering event tickets to a Business Partner, a Covered Person must attend the event for the event to be deemed to be Business Entertainment and not a Business Gift. If you are invited to receive Business Entertainment and your invitation extends to personal guest(s) (including, but not limited to, a spouse, domestic partner, or child), this would be considered a Business Gift and subject to the policy requirements.

Pre-clearance of Business Entertainment and Meals

The following Business Entertainment and Business Meals require pre-clearance from Compliance, and in some cases, the direct manager, or Head of the Covered Person’s business unit before such entertainment or meal can be accepted or given.

Requests should be submitted for review and pre-clearance through the Compliance portal, or to Compliance.

If a Covered Person cannot obtain pre-clearance, particularly for the receiving of Business Entertainment or Business Meals, the Covered Person must still report promptly upon receipt of any such Business Entertainment or Business Meal.

Reporting of Business Entertainment and Meals

Business Entertainment and Business Meals received valued over US$100/UK£100 or local market equivalent per person per event should be promptly reported through the Compliance portal.

Charitable Contributions

Covered Persons may not make charitable contributions, whether personally or in the name of the Firm, to obtain or retain business or to gain an improper business advantage. Before making any contributions, you should be informed about the organization to avoid actual or perceived conflicts of interest or impropriety.

All charitable contributions must meet the following criteria:

Pre-Clearance of Charitable Contributions

Charitable contributions, sponsorships, and participation in any fundraiser or charitable event requested by a Business Partner or involving a Public Official requires Compliance pre-clearance before making any contributions or commitments.

While Covered Persons are generally prohibited from leveraging Business Partner relationships for personal purposes, soliciting charitable contributions from Business Partners requires pre-clearance from the Head of the Covered Person’s business unit and should not take place during active fundraising. If the solicitation involves a Public Official, Compliance pre-clearance is required.

As a reminder, Political Contributions made by Covered Persons and family members living in the same household require pre-clearance. Please refer to the Political Contributions Policy for additional guidance.

Discounts

From time to time, business units may arrange discounts related to a Client’s investment or control of a company (e.g., access to portfolio company products or services). Any such discounts must be approved by the Head of the business unit managing the investment or their designee.

Discounts should be limited to Covered Persons; business units may impose additional restrictions (e.g., limiting discounts to a subset of Covered Persons).

The following practices are prohibited:

Recordkeeping

Ares will retain the following records pertaining to these Proxy Voting Policies and Procedures in accordance with Rule 204-2 under the Investment Advisers Act of 1940:

If Ares uses an outside service, it may rely on such service to maintain copies of proxy statements and records, so long as the service will provide a copy of such documents promptly upon request.