General Provisions

Individuals Covered

General Principles

The interests of Fund shareholders are paramount, and the Independent Trustees must conduct themselves to give maximum effect to this tenet by assiduously placing the interests of Fund shareholders before their own.

All personal transactions in securities by the Independent Trustees must be accomplished so as to avoid even the appearance of a conflict of interest on the part of such personnel with the interests of the Funds and their shareholders.

Independent Trustees must avoid actions or activities that allow (or appear to allow) a person to profit or benefit from his or her position with respect to the Funds, or that otherwise bring into question the person’s independence or judgment.

Notwithstanding compliance with the technical requirements of this Code, all material non-public information (“MNPI”) (as interpreted under the federal securities laws) received in the course of service as an Independent Trustee (including without limitation MNPI regarding Fund transactions in Covered Securities, actual or contemplated) is confidential, and Independent Trustees are prohibited from communicating (“tipping”) such MNPI to others. Similarly, if an Independent Trustee serves as a director, trustee, officer, consultant, or employee

For the purpose of the Funds, the term “shareholder” shall be deemed also to include owners of variable annuity contracts and variable life insurance policies funded through separate accounts investing in a Fund and participants in The Equitable 401(k) Plan.

Annual Questionnaire

Personal Securities Transactions

employ any device, scheme or artifice to defraud a Fund or any Portfolio of a Fund;

make to a Fund any untrue statement of a material fact or omit to state to a Fund a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading;

engage in any act, practice or course of business that would operate as a fraud or deceit upon a Fund or any Portfolio of a Fund;

engage in any manipulative practice with respect to a Fund or any Portfolio of a Fund.

Securities Transactions in Funds

Reporting Requirements

Initial and Annual Acknowledgement

Transactions in Covered Securities

The date of the transaction, the title, the interest rate and maturity date (if applicable) and the number of shares or the principal amount of each Covered Security involved;

The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition);

The price at which the transaction was affected;

The name of the broker, dealer or bank with or through whom the transaction was affected; and

The date the report was submitted.

Compliance with the Code

Investigating Violations of the Code

Remedies

Sanctions: If the Governance Committee determines that an Independent Trustee has committed a violation of the Code, the Governance Committee may impose such sanctions and take such other actions as it deems appropriate, including, among other things, a verbal warning, a letter of caution or warning, a fine, or removal “for cause” by the Board. The Governance Committee may also require the Independent Trustee to reverse a personal securities transaction made in violation of this Code and forfeit any profit or absorb any loss associated or derived as a result of such reversal. An Independent Trustee shall not participate in the Governance Committee’s determination of any remedies to be imposed in connection with his or her violation of the Code.

Sole Authority: The Governance Committee and the Board have the sole authority to determine the remedy for any violation of the Code by an Independent Trustee, including appropriate disposition of any monies forfeited pursuant to this provision.

Annual Reports

Record Retention Requirements

Amendments

Definitions

General Defined Terms

“Access Person” means any individual that should be treated as an “access person” to the Funds, as such term is defined in Rule 17j-1 under the 1940 Act, and includes, without limitation, the Independent Trustees.

“Sub-Adviser” means any entity who pursuant to a contract with a Fund or Investment Adviser, regularly furnishes advice to a Fund with respect to the

A security is “being considered for purchase or sale” when a recommendation to purchase or sell a Covered Security for a Fund has been made and communicated and, with respect to the person making the recommendation, when such person seriously considers making such a recommendation.

“Beneficial Ownership” shall be interpreted in the same manner as it would be under Section 16 of the Securities Exchange Act of 1934, as amended, (“Exchange Act”) and Rule 16a-1(a)(2) thereunder. A person is a “beneficial owner” of a security for purposes of the Code if he or she, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, has or shares a direct or indirect pecuniary interest in the securities. A pecuniary interest means the opportunity, directly or indirectly, to profit or share in any profit derived from a transaction in the subject securities. An indirect pecuniary interest includes, but is not limited to: (1) securities held by members of a person’s immediate family sharing the same household (for example, spouse or equivalent domestic partner, minor children, a relative, such as an adult child, stepchild or parent, who shares the home and to whom a person provides financial support); (2) a general partner’s proportionate interest in the portfolio securities held by a general or limited partnership; (3) a person’s right to dividends that is separated or separable from the underlying securities; (4) a person’s interest in securities held by a trust (for example, where the person or immediate family member is a beneficiary of the trust); and (5) a person’s right to acquire securities through the exercise or conversion of any derivative security, whether or not presently exercisable. A person will be deemed to have beneficial ownership of securities in his/her individual retirement account and securities in his/her 401(k) account or similar retirement plan, and spousal retirement plan accounts, even if the person has chosen to give someone else investment discretion over the account. A person who has and exercises power of attorney over an account, or who has investment discretion over an account that could hold Covered Securities, is deemed to be a beneficial owner of the account.

“Board” or “Board of Trustees” means the Boards of Trustees of the Funds.

“Covered Security” means any security as defined in Section 2(a)(36) of the 1940 Act including any stock, bond, future, investment contract or any other instrument that may be considered a “security.” The term “Covered Security” is very broad and includes:

Options on securities, on indexes and on currencies;

All kinds of limited partnerships (e.g., LP, LLP, etc.);

Foreign unit investment trusts and foreign mutual funds;

Private investment funds, hedge funds, and investment clubs;

Closed-end mutual funds and unit investment trusts;

Shares of exchange-traded funds (“ETFs”); and

Shares of open-end mutual funds registered under the 1940 Act that are managed by an Investment Adviser. Thus, the definition of Covered Security includes shares of the Funds.

Direct obligations of the Government of the United States or any agency thereof;

Banker’s acceptances, bank certificates of deposit, commercial paper and high-quality short-term debt instruments, including repurchase agreements; and

Shares issued by money market funds registered under the 1940 Act; and

Shares of open-end mutual funds (other than ETFs) registered under the 1940 Act that are not managed by an Investment Adviser.

“Independent Trustee” means a Trustee of a Fund who is not an “interested person” of the Fund within the meaning of Section 2(a)(19) of the 1940 Act and all consultants to the Board, in anticipation of becoming Independent Trustees (“Board Consultants”).

“Fund” means the 1290 Funds or EQAT and each of their separate series (each a “Portfolio”).

“Investment Adviser” means, with respect to EQAT and its respective Portfolios, Equitable Investment Management Group, LLC; and, with respect to 1290 Funds and its Portfolios, Equitable Investment Management, LLC.

“Purchase or sale of a Covered Security” includes, among other things, the writing of an option to purchase or sell a Covered Security.

A “Covered Security held or to be acquired” by any Portfolio or a Fund means (1) any Covered Security which, within the most recent fifteen (15) days, (a) is or has been held by any Portfolio of the Fund, or (b) is being or has been considered for purchase by any Portfolio of the Fund; and (2) any option to purchase or sell and any security convertible into or exchangeable for a Covered Security described in (1) of the definition.

A Covered Security is “being purchased or sold” by any Portfolio of a Fund or other adviser client from the time when a purchase or sale program has been

I have read the Code and I understand that it applies to me and to all securities in which I have or acquire a Beneficial Ownership interest. I have read the definition of “Beneficial Ownership” and understand that I may be deemed to have a Beneficial Ownership interest in securities owned by members of my Immediate Family and that securities transactions affected by members of my Immediate Family may therefore be subject to the Code.

I will report all securities transactions required to be reported under Section II of the Code in which I have or acquire a Beneficial Ownership interest.

I will comply with applicable provisions of the Code in all respects.

Trustee’s Signature

Name (Print)

Date