Code of Ethics

Purpose, Overview, and Scope

educate Supervised Persons as to the laws governing their conduct;

reinforce that Supervised Persons are in a position of trust and must act with complete propriety;

protect the reputation of Morningstar Investment Management; (iv) mitigate securities law violations; and

to protect Clients by deterring Supervised Persons misconduct.

Requirements and Restrictions

employing any device or scheme to defraud a Client,

making any untrue or misleading statement to a Client or omitting to state a material fact,

engaging in any act, practice or course of business which operates or would operate as a fraud or deceit upon a Client, or

engaging in any manipulative act or practice with respect to a Client.

Fiduciary Duty to Clients

Duty of Loyalty

Morningstar Investment Management’s policy is that the interests of the firm or the Supervised Person do not come before the best interests of the Clients. Morningstar Investment Management will address this by:

Making full and fair disclosure to its Clients of all material facts relating to the advisory relationship, including the capacity in which it is acting with respect to the advice it provides. Making available to Clients its Form ADV Parts 2 and 3 (as applicable), which are documents that provides information on its services, its investment process/methodology, and conflicts of interest.

Seeking to eliminate, or if elimination is not possible, exposing through full and fair disclosure all conflicts of interest which might cause Morningstar Investment Management to render advice which is not disinterested. Such disclosure will be sufficiently specific so that a Client can understand the material fact or conflict of interest and make an informed decision whether to provide consent and will depend on the nature of the Client, the scope of the advisory services, and the material fact or conflict.

Duty of Care

Morningstar Investment Management’s policy is to perform its duties in a prudent manner and consistent with the following:

Understanding the potential risks, rewards, and costs associated with a product, investment strategy, account type, or series of transactions.

Making suitable recommendations based on the Clients’ particular facts and circumstances (e.g., personal information and financial situation), financial circumstances and investment objectives; or, if a Client declines to provide such information, determining if prudent assumptions can be made for the information not disclosed and providing prudent recommendations based on those assumptions about the Client.

Having an adequate basis and support for any and all recommendations, representations, and forecasts.

Complying with applicable securities laws, including, but not limited to, the Advisers Act, Gramm-Leach-Bliley (“GLB”) Act, Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”), and the Securities Exchange Act of 1934 (“Exchange Act”).

Seeking best execution of a client’s transactions such that the Client’s total cost or proceeds in each transaction are the most favorable under the circumstances in those relationships where Morningstar Investment Management has the responsibility to select broker-dealers to execute trades for a Client.

Providing advice and monitoring at a frequency that is in the best interest of each Client, taking into account the scope of the agreed upon relationship.

In the absence of any agreed limitation or expansion of an agreement, the scope of duty to monitor will be indicated by the duration and nature of the agreed advisory arrangement.

Treating each similar situated Client and prospective Client fairly.

Professional Responsibilities

Guaranteeing investment performance.

Falsely stating or misrepresenting his or her credentials (e.g., professional designation or education).

Selling products or services in a manipulative, deceptive or fraudulent manner.

Not performing appropriate due diligence on alternative data sources to ensure data is collected in a manner that complies with applicable laws (i.e., has not been illegally scraped from a website) and is used in a manner that complies with the source’s terms of use and copyrights.

Stating or implying that the SEC, the Department of Labor (“DOL”), the Financial Industry Regulatory Authority (“FINRA”), or any other federal or state regulatory body endorses or approves the products or services offered by Morningstar Investment Management.

Rendering legal or tax advice to Clients.

Communicating confidential, non-public information about Morningstar Investment Management or its Clients to persons outside of Morningstar Investment Management, provided, however, that Employees may communicate such confidential or non-public information to Outsourced Persons on an “as needed basis” for them to perform services on behalf of Morningstar Investment Management.

Communicating confidential, non-public information about Morningstar, Inc. or its affiliates to anyone outside of Morningstar.

Communicating information to Clients that is based solely on rumor or speculation.

Using electronic forums, channels, blogs, or other communications systems (i.e., Reddit, YouTube, Twitter) to influence trading activity.

Buying or selling a publicly traded security while in possession of inside information or tipping such inside information to others.

Buying or selling a publicly traded security using confidential information about one issuer to trade the securities of another issuer on the basis that the market price of the two securities are likely to react similarly when information about one firm becomes public (“shadow trading”).

Signing a Client’s name to any document, even if the Client gives permission to do so.

Instructing the Client to pay them (the Supervised Person) directly for services rendered by Morningstar Investment Management.

Accepting cash, checks or other forms of payment made payable to the Supervised Person from a Client.

Lending money to a Client.

Borrowing money or securities from a Client.

Settling a Client complaint without following the process described in the Customer Complaints section of this manual.

Stating or implying that Morningstar Investment Management’s products or services are offered by Morningstar, Inc., or stating or implying that an Employee is employed by Morningstar, Inc.

Becoming an employee of or serving as a director of an unaffiliated company without the approval of the Compliance team and Morningstar, Inc.’s Chief Legal and People Officers (if applicable).

Acquiring or deriving personal gain or profit from any business or investment opportunity that comes to his or her attention as a result of the Supervised Persons’ duties within or in support of Morningstar Investment Management or his or her association with Client.

Public Speaking Engagements

Supervised Persons adhere to the guidelines set forth in the Professional Responsibilities section above.

Public statements should be given by senior investment professionals, sales professionals, researchers, economists, or members of Senior Management. If other persons are invited to give public statements, they should obtain prior approval from their manager and provide notification of such approval to the Compliance team, before proceeding.

Supervised Persons will ensure:

Prepared questions, scripts, or talking points to be used during the public appearance have been reviewed and approved by the Compliance team in advance when possible.

The Compliance team is provided final versions of any recorded engagements or transcripts, prior to or at its release to attendees of the event or the public in general. Final versions of any recorded engagements, or transcripts should be reviewed by the Compliance team prior to release when possible.

For videos that are produced in Morningstar’s in-house studio, a member of the Compliance team is given the opportunity to be present during the recording.

Presentations, handouts, or other materials provided to outside parties in relation to such public statements have been submitted to the Compliance team for review prior to dissemination.

Supervised Persons are prohibited from accepting individual compensation for participating in a speaking engagement where their participation is sought out because of his or her association with Morningstar.

Supervised Persons adhere to the guidelines set forth in the Professional Responsibilities section above.

Public statements should be given by senior investment professionals, sales professionals, researchers, economists, or members of Senior Management. If other persons are invited to give public statements, they should obtain prior approval from their manager and provide notification of such approval to the Compliance team, before proceeding.

Supervised Persons will ensure:

Prepared questions, scripts, or talking points to be used during the public appearance have been reviewed and approved by the Compliance team in advance when possible.

The Compliance team is provided final versions of any recorded engagements or transcripts, prior to or at its release to attendees of the event or the public in general. Final versions of any recorded engagements, or transcripts should be reviewed by the Compliance team prior to release when possible.

For videos that are produced in Morningstar’s in-house studio, a member of the Compliance team is given the opportunity to be present during the recording.

Presentations, handouts, or other materials provided to outside parties in relation to such public statements have been submitted to the Compliance team for review prior to dissemination.

Supervised Persons are prohibited from accepting individual compensation for participating in a speaking engagement where their participation is sought out because of his or her association with Morningstar.

Clients’ Non-Public Information

Taking precautions when providing confidential information through email, fax, or over the phone, which includes using the “PII Secure Tag” in Outlook for emails containing sensitive information.

Not discussing confidential information in public places, such as elevators, hallways, or at social gatherings.

Avoiding use of speaker phones in areas where unauthorized persons may overhear conversations.

Avoiding exposing documents containing confidential information to areas where they may be read by unauthorized persons (e.g., copy machine).

Storing documents containing confidential information in a secure location when they are not in use.

Discarding documents that contain confidential information (provided they do not need to be retained under the rules for retention of books and records), ensure that they are discarded and destroyed in a secure manner.

Locking all electronic devices (computers, phones, tablets, etc.) which may contain confidential information when such devices are not in use and use password protection to unlock such devices.

Using strong passwords that cannot be easily guessed.

Refraining from giving passwords to others or saving passwords in a place that can be accessed by others.

Refraining from using unsecured wireless networks when accessing or using confidential information.

Limit the number of Supervised Persons with access to confidential information.

Place servers with confidential information in a secure location and in a controlled environment.

Limit the number of Supervised Persons that have access to the secure location where servers are maintained.

Lock access to a system with confidential information if the user fails to enter the correct password within a certain number of tries.

Require the use of encryption and/or password protection (as available) on electronic devices used to access confidential information.

Adhere to the Information Security Policies and Standards implemented by the Morningstar, Inc. Information Security Department.

Adhere to Morningstar Investment Management’s Cybersecurity Policy.

Gifts and Entertainment

Entertainment that includes, but is not limited to, meals or snacks and tickets to sporting and theater events which are extraordinary, excessive, or at which representatives of both Morningstar Investment Management and Client are not in attendance;

Travel/lodging;

Charitable contributions made on behalf of a Client or prospective Client;

Gift baskets or perishable items; and

Logo-stamped promotional items valued at more than $30 in total.

Personal gifts, such as a wedding gift, retirement gift, or congratulatory gift for the birth of a child provided that the gift was paid for out of the Supervised Person’s personal funds and the Supervised Person has a pre-existing personal or family relationship to the gift recipient that was deemed acceptable by the Compliance team.

If Morningstar Investment Management bears the cost of a gift, either directly or by reimbursing the Supervised Person, the gift will be counted towards the $250 gift limit.

Personal gifts should typically be infrequent in nature, reasonable and customary, and not so excessive as to raise questions of impropriety.

Donations facilitated through crowdsourcing websites or apps to raise funds for a Client or potential Client’s direct or indirect benefit (i.e., a GoFundMe donation for a recently diagnosed condition that will result in large medical bills) as long as the donation does not exceed $250 per person per year.

A gift sent to Morningstar Investment Management in general or to a specific department where it is shared (e.g., a fruit basket received during the holidays which is left in the tea-point).

Any meal or other business entertainment that is not frequent or so excessive as to raise any question of impropriety and for which representatives of both Morningstar Investment Management and Client are in attendance.

For example, a Supervised Person may accept an occasional dinner invitation if the person who extended the invitation attends the dinner and the purpose of the meeting is to discuss legitimate business or establish a business relationship.

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Any food or beverage item(s) provided for a virtual business event (e.g., client appreciation event held over Zoom) provided to attendees where a representative of Morningstar Investment Management is present, visible onscreen, and available for interaction with attendees throughout the event.

For the avoidance of doubt, a gift certificate for a food or beverage item is considered a gift unless it is only valid for the duration of the virtual event.

Such items must be intended to be consumed during the event by attendees, cannot be preconditioned on meeting a sales goal, and cannot be used for an item that is actually a gift (i.e., a food or beverage item to take home), and

The cost and frequency of providing such items must be reasonable so as not to raise any question of propriety.

Sponsorship of a marketing event in which representatives of both Morningstar Investment Management and the Client are present.

Marketing sponsorships between Morningstar Investment Management and an institutional Client.

Charitable contributions from Morningstar Investment Management as long as the contribution is not intended to or would result in favorable treatment or influence over a business decision or could be reasonably viewed as (i) not appropriate in its business context or (ii) placing the recipient or associated client under a real or perceived obligation to any Supervised Person or Morningstar Investment Management.

Gifts

For example, Morningstar Investment Management, directly or through Supervised Persons, cannot give two separate gifts worth $200 to any Client within a calendar year.

Gifts of charitable contributions must be submitted directly to the charitable organization.

Supervised Persons may not give to or solicit donations for a charitable organization they own or run as part of a gift.

For example, a Supervised Person cannot accept two separate $200 gifts from the same vendor of Morningstar Investment Management valued within a calendar year.

Supervised Persons may not accept cash or other items of value intended to be sent to a charitable organization as part of a gift. Supervised Persons should direct the gift giver to send the donation directly to the charitable organization.

Unsolicited donations to a charitable organization from a person or entity that relates to Morningstar Investment Management’s business must be reported to the Compliance team immediately when the charitable organization is owned or run by a Supervised Person.

Cash or checks may not be sent directly to the event’s sponsor by a Supervised Person; the event sponsor should send an invoice to Morningstar Investment Management for proper processing through Morningstar’s accounting department.

For example, for a $250 gift basket sent to a Client’s marketing department that consists of five employees, each person will be reflected as receiving a $50 gift.

For avoidance of doubt, the prohibitions contained in this paragraph pertain to those fund companies or exchange-traded fund sponsors who are not Clients of Morningstar Investment Management. For fund companies and exchange-traded fund sponsors who are Clients of Morningstar Investment Management, the policies for Clients apply.

Entertainment

one’s independence or objectivity would not be called into question or

that would reasonably cause the Supervised Person or Morningstar Investment Management to act in a manner that is inconsistent with its fiduciary duty or feel beholden to the giver or its firm.

Exceptions to the Gift Policy

Morningstar Investment Management must maintain a documented process for determining which Clients are offered registration waivers (i.e., all “Tier 1” Clients, as defined by SalesForce sales procedures, are offered a waiver.)

Clients are only offered one type of registration waiver (i.e., if a free registration, 50% off waiver, or $100 off waiver is available, Morningstar Investment Management must determine one of those types for all Clients who are offered a pass.)

Compliance must approve the client determination process, list of Clients being offered the waiver, and the waiver type prior to a waiver being offered to a Client.

Clients who are offered a registration waiver whose market value is higher than $250 may not receive any other gift during the year in which the conference took place.

Supervised Person Reporting

Conflicts of Interest

Favor the interests of one Client or one group of Clients over others (e.g., larger accounts over smaller accounts, accounts of Supervised Persons or their immediate family over other accounts, and accounts that produce higher compensation for the adviser over others).

Use the knowledge of an upcoming trade or change in Morningstar Investment Management’s products, services, or Clients to profit personally, directly or indirectly, because of such knowledge, including by purchasing or selling securities.

Recommend a security without disclosing to an appropriate designated person (e.g., Senior Management) and Client that they have a material beneficial ownership, business or personal relationship, or other material interest in the issuer or its affiliates.

Negotiate or make decisions regarding Morningstar Investment Management’s use of a vendor or supplier without disclosing to an appropriate designed person (e.g., Senior Management) that they have a material beneficial ownership, business or personal relationship, or other material interest in such vendor or supplier.

Morningstar Investment Management will disclose in its Form ADV Part 2 that Clients investing in investment companies will pay two layers of fees—one layer pertaining to the investment company’s fees and expenses and the other layer pertaining to Morningstar Investment Management’s advisory fees.

Such disclosures may also be summarized in the Form ADV Part 3 or the Form ADV Part 3 will refer the Client to the Form ADV Part 2 for further information about conflicts of interest.

Other means of such disclosure may include marketing materials or verbal communications with Clients or prospective Clients.

Conflicted personal relationships could include, but are not limited to, an immediate family member working for a competitor or client, a close friend with access to inside information of a client or competitor, an immediate

Personal Security Transaction and Holdings

Definitions

Access person is defined as

An officer of Morningstar Investment Management;

A person who makes or participates in making investment recommendation to Clients;

A person who has the ability to access nonpublic information regarding a Client’s security holdings, such as what recommendations were given or will be given to them and what securities they hold or will be holding;

Any other Supervised Person, at the discretion of the Compliance team; or

At the discretion of the Compliance team, consultants, independent contractors, or interns used by Morningstar Investment Management whose duties may expose them to the above information.

Beneficial ownership is where an access person has the opportunity, directly or indirectly, to profit or share in any profit derived from a transaction.

Generally, this includes reportable securities owned by immediate family members residing in your home (e.g., a reportable security held in an account that is under your spouse or partner’s name), investment club accounts, or other accounts where you have the ability to influence trading decisions.

Digital Assets are assets that are issued and/or transferred using distributed ledger or blockchain technology, including, but not limited to, Digital Currencies and Digital Coins or Tokens.

A particular Digital Asset may or may not meet the definition of a “security” under U.S. federal securities laws, depending on its facts and circumstances.

Digital Coins or Tokens A Digital Asset received as part of an Initial Coin Offering or through a secondary market that offers rights or interests in a business or project.

Digital Coins or Tokens may or may not be securities, depending on the facts and circumstances of the particular asset.

Digital Currencies are virtual representations of value that are designed to enable purchases, sales, or other financial transactions. Digital Currencies are intended to provide many of the same functions as long-established currencies but do not have the backing of a government or other body.

Initial Coin Offering (ICO) A method of raising capital for a business or project where individual investors typically exchange currency (such as U.S. dollars or Digital Currencies) for Digital Coins or Tokens.

Reportable securities include, but are not limited to, the following types of securities, regardless of the type of account in which they are held (e.g., IRA or 401(k)):

Stocks

Municipal or corporate bonds

Derivatives (e.g., options, futures)

Digital Assets registered with the SEC as securities

Closed-ends funds

Exchanged Traded Products (e.g., ETFs, ETNs)

Hedge funds

REITs

Morningstar restricted, market, or performance stock units (net units) at the time the units vest

Exercised stock options

Private placements

Open-end mutual funds for which Morningstar Investment Management acts as an investment adviser or sub-adviser (A current list of these funds may be requested from the Compliance team by sending a request to compliancemail@morningstar.com.)

Collective investment trusts in which Morningstar Investment Management is an investment adviser or sub-adviser to (A current list of these funds may be requested from the Compliance team by sending a request to compliancemail@morningstar.com.)

Direct obligations of the U.S. government (e.g., U.S. Treasury Bonds)

Cash and money market instruments such as bank certificates of deposit, commercial paper, high-quality short-term debt instruments (i.e., an instrument having a maturity of less than 366 days and rated in one of the highest two rating categories by a NRSRO), and Digital Assets that are not registered with the SEC as securities

Shares in open-end mutual funds, including money market funds (except for those in which the RIA is an investment adviser or sub-adviser)

Units in a unit investment trust (except for those in which Morningstar Investment Management is an investment adviser or sub-adviser) which includes separate accounts supporting an insurance company’s variable insurance contracts, like for example a variable annuity

Units in a collective investment trust (except for those in which Morningstar Investment Management is an investment adviser or sub-adviser)

Unvested restricted, performance, or market stock units of Morningstar, Inc. stock

Unexercised stock options of Morningstar, Inc. stock

529 Plan securities

Transactions include the purchase, sale, donation, or other related activities involving shares of a security or investment product or coins, tokens, shares, or other unit of ownership of a Digital Asset. Certain purchases or sales listed below that are not directed by the access person at the time of execution are exempt from the definition of a transaction:

Dividends or capital gains reinvestments made as part of an automatic reinvestment plan.

Regular periodic purchases or withdrawals made automatically in accordance with a previously established predetermined schedule and allocation (an “automatic investment plan.”)

An access person’s immediate family consists of his/her spouse or live-in partner, each family member residing in the access person’s household, and any other person or entity whose investment activity could reasonably be attributed to the access person.

Personal Trading Policies

All Supervised Persons are considered access persons.

Supervised Persons and their immediate family members may only maintain accounts containing reportable securities at brokers approved by the Compliance team. Exceptions to this policy must be approved by the Compliance team.

Reportable securities held in accounts over which the Supervised Person and/or their immediate family member does not have any control or influence over the purchase or sale of reportable securities (e.g., an account managed by a financial professional who has discretion over the account’s trading activities, commonly known as a “managed account”) will be granted an exception to this policy after the Supervised Person provides the Compliance team with documentation certifying the managed status of the account.

Supervised Persons may obtain the current list of approved brokers from the Compliance team by sending a request to compliancemail@morningstar.com. Supervised Persons of Morningstar Investment Management must comply with this policy within 30 days of association with Morningstar Investment Management.

Supervised Persons will take the necessary steps to include their account on a broker’s electronic feed, when such feed is available.

Supervised Persons will obtain written approval from the Chief Compliance Officer, or their designee, prior to participating in an initial public offering (“IPO”) or Initial Coin Offering or similar presale of Digital Coins or Tokens of securities registered with the SEC (“ICO”) or investing in a private placement (which includes hedge funds.)

Requests to the Chief Compliance Officer or their designee for IPO, ICO, or private placement transactions are to be made through the compliance reporting system.

For restricted, market, and performance stock units, Supervised Persons will, within 5 business days of their vesting, transfer their vested shares to a personal brokerage account connected to an electronic feed.

Supervised Persons will not participate in “day trading”, where an investor buys and sells a security within the same trading day to a degree that could reasonably be determined that the volume of trading is interfering with or detracting from the Supervised Person’s employment responsibilities.

Senior Management reserves the right to place trading restrictions on Supervised Persons found to be undertaking day trading, or any other trading practices that interferes with their job performance during regular business hours.

Portfolio managers of Select Equity Wealth portfolios and their teams (“Equity PMs”) are prohibited from executing or influencing any transaction in any company’s reportable securities when the company is listed on the Restricted Stock List for All Equity Analysts and MIM US Equity PM Team (“Restricted List”).

This includes any equity or debt securities of a company and applies to each security that derives its value from a security issued by the company, such as puts, calls, or other derivatives (without regard to the issuer of the put, call, or other derivative.)

Equtiy PMs are responsible for checking the Restricted List prior to making a transaction and are also responsible for checking the Restricted List on behalf of their immediate family members.

For the avoidance of doubt, Supervised Persons and their immediate family members are not responsible for trades made in securities contained on the Restricted List if they have no control or influence over those trades (e.g., for trades made by an investment adviser with discretionary authority over the account). The Compliance team may require a Supervised Person to certify they had no control or influence over such trades.

Supervised Persons with advanced knowledge of an upcoming or likely transaction directed by Morningstar Investment Management in an equity or ETF security are prohibited from directing or influencing any transaction in that company’s securities (including options) in any beneficially owned accounts from the time the Supervised Persons is made aware of the transaction until a reasonable period of time (e.g., 48 hours) has passed after Morningstar Investment Management has placed the trade for all its Clients.

This includes any equity or debt securities of a company and applies to each security that derives its value from a security issued by the company, such as puts, calls, or other derivatives (without regard to the issuer of the put, call, or other derivative.)

For the avoidance of doubt, Supervised Persons and their immediate family members are not responsible for trades made if they have no control or influence over those trades (e.g., for trades made by an investment adviser with discretionary authority over the account). The Compliance team may require a Supervised Person to certify they had no control or influence over such trades.

Supervised Persons who have, or are likely to have access to, advanced knowledge of trades made by Morningstar Investment Management in regard to the portion of a Morningstar Funds Trust fund it manages are prohibited from executing or influencing any transaction in a security or company’s securities when the security or company is listed on the Morningstar Funds Restricted List. Supervised Persons subject to the Morningstar Funds Restricted List will be notified of such and educated on the dates on which a security or company is added to or removed from the Morningstar Funds Restricted List.

This includes any equity or debt securities of a company and applies to each security that derives its value from a security issued by the company, such as puts, calls, or other derivatives (without regard to the issuer of the put, call, or other derivative.)

Applicable Supervised Persons are responsible for checking the Morningstar Funds Restricted List prior to making a transaction and are also responsible for checking the Morningstar Funds Restricted List on behalf of their immediate family members.

For the avoidance of doubt, Supervised Persons and their immediate family members are not responsible for trades made in securities contained on the Morningstar Funds Restricted List if they have no control or influence over those trades (e.g., for trades made by an investment adviser with discretionary authority over the account). The Compliance team may require a Supervised Person to certify they had no control or influence over such trades.

Supervised Persons will comply with the following reporting requirements:

Initial Report Within ten calendar days of becoming a Supervised Person, provide an inventory of all reportable securities that the Supervised Person has a beneficial ownership in that are not held in managed accounts. The inventory of reportable securities must be current within 45 days of becoming a Supervised Person.

Quarterly Report Within 30 calendar days after a calendar quarter end, or such earlier date as may be specified by the Compliance team, ensure all transactions in reportable securities made during the prior calendar quarter (with the exception of those held in managed accounts) are reflected in the compliance reporting system or have been disclosed to the Compliance team via a submitted broker account statement. For the avoidance of doubt:

Purchases and sales made in connection with the initiation, modification, or termination of an automatic investment plan are required to be reported as part of the Quarterly Report. Only predetermined periodic purchases and sales made as part of an established automatic investment plan are excluded from the definition of a transaction. o Dividends and capital gains that are automatically reinvested do not need to be reported on the Quarterly Report.

Annual Report Within 30 calendar days after the calendar year-end, or such earlier date as may be specified by the Compliance team, ensure the holdings reflected within the compliance reporting system represents an accurate and complete listing of all reportable securities in which the Supervised Person has a beneficial ownership as of the calendar year-end, with the exception of those held in managed accounts, or have been submitted to the Compliance team via a submitted broker account statement.

For the avoidance of doubt, Supervised Persons are required to update their holdings in all reportable securities, including those holdings that are part of an automatic dividend or capital gain reinvestment plan or an automatic investment plan.

Supervised Persons will provide the Compliance team with duplicate trade confirmations or account statements for a given period upon request.

Senior Management will cause the Compliance team to be promptly notified of securities or companies to be included or removed from any Restricted List and changes to Supervised Persons subject to Restricted Lists.

Violations

The first material violation will include a written notification to the Supervised Person. Supervised Persons are required to review the Code of Ethics upon notification.

A second material violation will include written notification to the Supervised Person of the violation and any additional requirements or conditions deemed appropriate on the Supervised Person’s personal trading. Supervised Persons are required to review the Code of Ethics upon notification.

Any subsequent material violations will be handled in accordance with the severity of the violations as determined by Senior Management and/or the Compliance team and may include preclearance of any personal trade by the Supervised Person and their immediate family going forward, disgorgement of any profits, recording of the violations in the Supervised Person’s employment records (e.g., performance evaluations), and/or outright prohibition of personal investing by the Supervised Person.

Insider Trading

Outside Activities

a Client, or

having discretion to invest and/or participate in investment decisions, or related investment matters whether compensated for the activity or not.

An outside activity is any activity that is not part of a Supervised Person’s assigned duties or a Morningstar sponsored activity.

Involvement in social, religious, educational, charitable, civic or fraternal organizations that do not involve the Supervised Person being involved in the organization’s investment matters does not require written approval from the Compliance team.

Obtaining approval under the Morningstar, Inc. Code of Ethics for an outside activity does not take the place of obtaining compliance’s approval under this Compliance Manual’s policies and procedures, and vice versa.

Confidential Information

Supervised Persons may disclose information contained within Morningstar, Inc.’s 10-Q, 10-K, or 8-K only after its publication.

Any request for information that is not generally released in the normal course of business should be referred to the Chief Compliance Officer for determination as to whether such request will be fulfilled.

Requests from or Visits by Regulatory Authorities

In the case of telephone requests, the Supervised Person receiving the request should obtain the name, agency, address, and telephone number of the representative making such request.

Subpoenas or Other Legal Process

If service is attempted upon a non-officer Supervised Person, he or she must immediately contact Senior Management, the Legal team, or the Chief Compliance Officer.

Reporting Violations

violation of any applicable securities laws;

breach in Morningstar Investment Management’s fiduciary duty arising under any federal or state laws;

violation of any federal or state law;

Code of Ethics violation; or

An act of wrongdoing such as, but not limited to, bribery, theft, falsifying documents, destroying/deleting documents or lying to regulators.

In lieu of notifying the Chief Compliance Officer directly, notifications can be sent using the Morningstar Ethics Hotline website (http://morningstar.ethicspoint.com/) or by calling 1-800-555-8316 (US or Canada) or 000 117 then enter 833 626 1539 (India).

the identity of the reporting employee,

the information provided, and

any subsequent discussions or actions in response to the reporting employee’s notification.

Applicable Regulations and Summary

Section 206 of the Advisers Act

Rule 204A-1 of the Advisers Act

Section 204A of the Advisers Act

Section 21F of the Securities Exchange Act of 1934, as amended

Commission Interpretation Regarding Standard of Conduct for Investment Advisers, effective July 12, 2019

Section 922 of the Dodd-Frank Act

Duty of Loyalty

Duty of Care

Duty to Provide Advice in the Best Interest of the Client

Duty to Seek Best Execution of Client Transactions

Duty to Provide Advice and Monitoring Over the Course of the Relationship

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