INVESTMENT ADVISER CODE OF ETHICS

INTRODUCTION

Rule 204A-1 under the Advisers Act requires each federally registered investment adviser to adopt a written code of ethics (the “Code”) designed to prevent fraud by reinforcing the principles that govern the conduct of investment advisory firms and their personnel. In addition, the Code must set forth specific requirements relating to personal securities trading activity including reporting transactions and holdings.

Generally, the Code applies to directors, officers and employees acting in an investment advisory capacity who are known as Supervised Persons and, in some cases, also as Access Persons of the adviser. Supervised Persons covered by more than one code of ethics meeting the requirements of Rule 204A-1 will be subject to the code of the primary entity with which the Supervised Person is associated. Employees identified as Supervised and Access Persons must comply with the Code. Compliance is responsible for notifying each individual who is subject to the Code. Supervised Persons must be provided and must acknowledge receipt of this Code and any amendments to the Code. They must also comply with the federal securities laws.

GENERAL ETHICAL STANDARDS

Prudential holds its employees to the highest ethical standards. Maintaining high standards requires a total commitment to sound ethical principles and Prudential’s values. It also requires nurturing a business culture that supports decisions and actions based on what is right, not simply what is expedient.

It is the responsibility of management to make the Company’s ethical standards clear. At every level, employees must set the right example in their daily conduct. Prudential expects employees to be honest and forthright and to use good judgment. We expect them to deal fairly with customers, suppliers, competitors, and one another. We expect them to avoid taking unfair advantage of others through manipulation, concealment, abuse of confidential information or misrepresentation. Moreover, employees must understand the expectations of the Company and apply these guidelines to analogous situations or seek guidance if they have questions about conduct in given circumstances.

It is each employee’s responsibility to ensure that we:

➢Nurture a company culture that is highly moral and make decisions based on what is right.

➢Build lasting customer relationships by offering only those products and services that are appropriate to customers’ needs and provide fair value.

➢Maintain an environment where employees conduct themselves with courage, integrity, honesty and fair dealing at all times.

➢Ensure no individual’s personal success or business group’s bottom line is more important than preserving the name and goodwill of Prudential.

➢Regularly monitor and work to improve our ethical work environment.

Because Ethics is not a science, there may be gray areas. We encourage individuals to ask for help in making the right decisions. Business Management, Business Ethics Officers, and our Human Resources, Law and Compliance and Enterprise Ethics professionals are all available for guidance at any time.

Prudential Financial, Inc.- Compliance Approval Required Prior to External Dissemination

revised 01/31/2025

INVESTMENT ADVISER FIDUCIARY STANDARDS

Investment advisers are fiduciaries for clients. Fiduciary status may exist under contract; common law; state law; or federal laws, such as the Investment Advisers Act of 1940, the Investment Company Act of 1940 and ERISA.

Whenever a Prudential adviser acts in a fiduciary capacity, it will endeavor to consistently put the client’s interest ahead of the firm’s interests. It will disclose actual and potential meaningful conflicts of interest. It will manage actual conflicts in accordance with applicable legal standards. If applicable legal standards do not permit management of a conflict, the adviser will avoid the conflict. Adviser personnel will not engage in fraudulent, deceptive or manipulative conduct. Advisers will act with appropriate care, skill and diligence.

Advisory personnel are required to know when an adviser is acting as a fiduciary with respect to the work they are doing. In such cases, advisory personnel are expected to comply with all fiduciary standards applicable to the firm in performing their duties. In addition, they must also put the client’s interest ahead of their own personal interest. An employee’s fiduciary duty is a personal obligation. While advisory personnel may rely upon subordinates to perform many tasks that are part of their responsibilities, they are personally responsible for fiduciary obligations even if carried out through subordinates. Employees should be aware that failure to adhere to the standards under this Code might lead to disciplinary action up to and including termination of employment.

OTHER IMPORTANT POLICIES

This Code complements other important Prudential Policies that address ethics and conflicts, such as:

•Prudential’s Code of Conduct – Making the Right Choices - applies to all Prudential employees, including those affiliated with an investment adviser.

•Code of Ethics – Personal Investing Standards. All investment advisory personnel are subject to the Code of Ethics – Personal Investing Standards and must comply with all requirements therein unless otherwise notified by Compliance.

•Global Insider Trading Policy. All employees of Prudential are subject to the Global Insider Trading Policy and must comply with applicable requirements.

•Insider Trading and Information Barrier Standards. All Supervised and Access Persons receive training on their obligations and must comply with any information barrier restrictions applicable to their business unit or job function.

•Compliance Policies and Procedures – all investment advisory personnel must comply with their applicable business unit policies and procedures.

REPORTING VIOLATIONS OF THE CODE

Failure to comply with any of the requirements (or report potential violations) of this Code and the other important policies listed above may result in violations of securities laws and regulations. Prudential takes such violations very seriously. Any potential violation of the provisions of this Code will be investigated by Law & Compliance. If a determination is made that a violation has occurred, we may impose appropriate sanctions, up to and including termination of employment or referral to regulatory, civil, or criminal authorities.

To report suspected violations, you should contact Compliance. If you feel uncomfortable reporting directly to Compliance, you may also report suspected violations to our Ethics Help

Prudential Financial, Inc.- Compliance Approval Required Prior to External Dissemination

revised 01/31/2025

Line (1-800-752-70241) or Website https://prudential.ethicspoint.com. Prudential will not tolerate any discrimination, harassment, or retaliation against anyone who makes a good faith report or assists in an investigation.

You may voluntarily communicate with or provide information to government agencies regarding potential violations of the law without providing notice to, or obtaining approval, from Prudential. Nothing in these Standards is intended to, or should be interpreted, to preclude anyone from exercising these rights.

Prudential Financial, Inc.- Compliance Approval Required Prior to External Dissemination

revised 01/31/2025

Code of Ethics

Personal Investing Standards

April 2026

Applies to:

All employees (full-time and part-time), globally, that work for, support, or are a registered representative of any of Prudential’s asset management, investment adviser, and broker dealer businesses (CIO, PAD, PGIM, PIMS, and PruCo)

All contractors, interns, temporary employees, and others who have been notified by compliance are subject to this policy.

Questions?

CONTACT: PST.Help@prudential.com

This policy complements other important Prudential policies that address ethics and conflicts, such as Prudential’s Code of Conduct

–Making the Right Choices, Conflicts of Interest Policy, Global Anti-Bribery and Anti- Corruption Policy, Information Barrier Standards, and Global Insider Trading Policy.

Prudential Financial, Inc.- Compliance Approval Required Prior to External Dissemination

Table of Contents
Overview .......................................................................................................................................	4
Key Points................................................................................................................................................................	4
Who is Covered Under These Standards?...............................................................................................................	4
Roles and Responsibilities .......................................................................................................................................	4
Employee Classifications .........................................................................................................................................	5
Escalation Requirements.........................................................................................................................................	5
Key Definitions ........................................................................................................................................................	5
Policy Requirements ......................................................................................................................	6
Personal Trading ..................................................................................................................................................	6
Key Principles ......................................................................................................................................................	6
Trading Restrictions.............................................................................................................................................	6
Material Nonpublic Information (MNPI).............................................................................................................	6
Investing in Prudential Funds..............................................................................................................................	6
Private Placements & Private Securities Transactions ........................................................................................	7
Initial Public Offerings (IPOs) ..............................................................................................................................	7
Trading in Prudential Securities ..........................................................................................................................	7
Gifts of Prudential Securities...............................................................................................................................	7
Board Memberships and Joint Ventures.............................................................................................................	7
Short Sales ..........................................................................................................................................................	7
Associated, Access, & Investment Persons Account Reporting.............................................................	8
What Must be Reported?.....................................................................................................................................	8
Initial Investment Securities Account Disclosure ................................................................................................	8
Initial Holdings Disclosures .................................................................................................................................	8
Authorized Brokers for US Reportable Accounts ................................................................................................	8
Non-US Reportable Accounts..............................................................................................................................	8
Cryptocurrency....................................................................................................................................................	9
Ongoing Disclosure, Reporting, & Attestation Responsibilities......................................................................	9
Additional Requirements for Access and Investment Persons............................................................	10
Preclearance Process for Personal Trading ....................................................................................................	10
What Trades Must Be Precleared? ...................................................................................................................	10
How does the Preclearance Process Work?......................................................................................................	10
Two-Day Approval Window ..............................................................................................................................	10
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Options & Futures.............................................................................................................................................	10
Additional Restrictions for NFA Associated Persons.........................................................................................	11
Trading Restrictions...........................................................................................................................................	11
Excessive Trading ..............................................................................................................................................	11
Restricted Securities .........................................................................................................................................	11
Blackout Periods ...............................................................................................................................................	11
Minimum Holding Periods & Short-Swing Profits.............................................................................................	12
Exceptions (Blackout Periods, Short Swing Profits and Minimum Holding Periods).........................................	12
Additional Restrictions for PGIM Real Estate – Prudential Retirement Real Estate Fund (“PRREF”)................	13
Investment Clubs ..............................................................................................................................................	13
Financial Wagering Instruments and Prediction Markets.................................................................................	13
Additional Requirements for Designated Persons .........................................................................................	13
Trading Limited During Open Window .............................................................................................................	13
Preclearance Required for Senior Vice Presidents and Above..........................................................................	14
Exceptions ..........................................................................................................................................................	14
Excluded Transactions.......................................................................................................................................	14
Discretionary Managed Accounts .....................................................................................................................	14
Exemptions While on Leave..............................................................................................................................	14
Non-Compliance.................................................................................................................................................	15
Recordkeeping....................................................................................................................................................	15
Exhibit A – Key Definitions...............................................................................................................................	16
Exhibit B – Summary of Code Requirements by Employee Classification..................................................	19
Exhibit C – Beneficial Interest .........................................................................................................................	21
Exhibit D – Preclearance Summary Chart.......................................................................................................	22

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Overview

Key Points

We are entrusted with our clients’ investment assets and as such, Prudential Financial, Inc. and its subsidiaries (collectively “Prudential,” “PFI” or the “Company”) aspire to the highest standard of business ethics. Per our Code of Conduct, “Making the Right Choices,” we have an obligation to place our clients’ interests before our own and manage conflicts of interest fairly. In addition to Making the Right Choices, our Code of Ethics - Personal Investing Standards (the “Code”) provides a framework to make sure we meet that obligation with our personal investments.

While the Code sets out several requirements, prohibitions, and conditions, it does not cover every possible scenario and cannot be a replacement for your good judgment. If the Code is unclear, consult with Compliance and evaluate your proposed course of conduct against our principles and core values:

We do the right thing by placing the interests of our clients first.

We avoid, mitigate and/or disclose relevant conflicts of interest.

We are committed to doing business in the right way, and comply with applicable laws, rules, and regulations.

We make and keep promises, which includes holding each other accountable by reporting any violations.

The Code is designed to comply with laws, rules, and regulations of the various jurisdictions where Prudential operates. You should consult with your Local Compliance Officer to confirm if there are any additional personal investing policies and procedures that are specific to your business.

Who is Covered Under These Standards?

Except as otherwise noted, the Code applies globally to all directors, officers, and employees (including contractors, interns, temporary employees, and others who have been notified they are subject to this policy) of/or supporting Prudential asset management, investment adviser and/or broker-dealer businesses, including the Prudential Chief Investment Office (“CIO”), Prudential Annuities Distributors (“PAD”), PGIM, Prudential Investment Management Services (“PIMS”), and Prudential Financial Planning Services (“PruCo”), throughout the enterprise regardless of geographic location (“Employees”).

For the purposes of these standards, “PGIM” refers to all PGIM affiliated regulated investments firms, registered investment advisers, business lines and their associated functional areas including: AST Investment Services, PGIM Custom Harvest, PGIM DC Solutions, PGIM Global Services, PGIM, Inc, PGIM Investments, and PGIM Quantitative Solutions.

Roles and Responsibilities

Employees	Compliance	Ethics Committee
Upon hire, annually and any time	Administers and monitors adherence to the	Reviews the Code on a periodic basis in line with
material changes are made you	Code, including providing training, reviewing	business changes and changes to regulation.
will attest and agree to comply	employees’ disclosures and transactions, and
with the requirements of the	identifying potential violations.	Provides oversight of the Code, including by
Code.		reviewing exceptions and addressing incidents and
	Maintains and oversees the maintenance of	violations. Sanctions may include verbal reminders,
	certain records in accordance with applicable	educational letters, disciplinary letters, monetary
	legal and regulatory requirements.	penalties, suspension without pay, personal trading
		ban, reduction in PTO days, or other disciplinary
		action up to and including termination of employment.

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Employee Classifications

Employee monitoring classifications are listed below. For ease of reference, the term Employee will be used throughout this document, and multiple classifications may apply depending on your role.

Please see Exhibit A – Key Definitions for a full list of classifications.

	Supervised	Associated	Access Persons	Investment	Designated Persons
	Persons	Persons		Persons
	Employees of a	Employees who are	Employees who are	Employees who make or	Employees who, during the
	Prudential registered	associated with any	associated with any	participate in making	normal course of their
	investment adviser, and	Prudential broker-	Prudential broker-dealer	recommendations	employment, have routine
	other individuals who	dealer.	and/or Employees who work	regarding the purchase	access to Material Nonpublic
	provide investment		for, or support, investment	or sale of securities for	Information about Prudential.
	advice on behalf of the		advisory activities and may	client accounts (e.g.,
	adviser and are subject		have access to nonpublic:	portfolio managers and	Material Nonpublic
	to the adviser’s		• Advisory client trading	research analysts).	Information may consist of
	supervision and control.				financial or non-financial
			information;		information about Prudential
					as a whole or one or more
			• Advisory client investment		Divisions or Segments.
			recommendations; or		Please refer to Prudential’s
			• Portfolio holdings.		Global Insider Trading Policy
					for specific requirements.

Escalation Requirements

Failure to comply with any of the requirements of the Code or report potential violations may result in violations of securities regulations. Prudential takes violations very seriously. Any potential violation of the provisions of the Code will be investigated by Compliance and may be reported to the Ethics Committee.

If a determination is made that a violation has occurred, we may impose appropriate sanctions, including but not limited to one or more of the following: a written warning, profit surrender, personal trading ban, and termination of employment or referral to regulatory, civil, or criminal authorities.

To report suspected violations of the Code, you should contact Compliance. If you feel uncomfortable reporting directly to Compliance, you may also report suspected violations to our Ethics Help Line (1-800-752-7024) or website https://prudential.ethicspoint.com.

We will not tolerate any discrimination, harassment, or retaliation against anyone who makes a good faith report or assists in an investigation.

You may voluntarily communicate with or provide information to government agencies regarding potential violations of the law without providing notice to, or obtaining approval, from Prudential. Nothing in this Code is intended to, or should be interpreted, to preclude anyone from exercising these rights.

Key Definitions

See Exhibit A.

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Be aware these funds may have restrictions on frequent trading and other restrictions as described in its fund prospectus, or other offering documents.

Private Placements & Private Securities Transactions

You must obtain approval before investing in a private placement securities offering. Compliance approval may be granted after a review of the facts and circumstances, including whether:

An investment in the securities is likely to result in future conflicts with client accounts (e.g., upon a future public offering); and

You are being offered the opportunity due to your employment at or association with Prudential.

Contact Compliance for assistance with these requests.

Initial Public Offerings (IPOs)

You may not participate in IPOs. Compliance will consider exceptions under limited circumstances.

Trading in Prudential Securities

Prudential Financial, Inc. (PFI) is a publicly traded company. You may not trade or cause someone else to trade in Prudential securities while in the possession of Material Nonpublic Information (MNPI) or Inside Information.

You may not engage in transactions in PFI securities if they are speculative or short-term in nature. Speculative trading includes short sales, transactions in “put” or “call” options or similar derivative transactions. For more information, see the Global Insider Trading Policy.

Gifts of Prudential Securities

Employees with Section 16-related filing obligations regarding securities of PFI or PGIM Closed-End Funds must preclear all gifts of such securities.

Board Memberships and Joint Ventures

You should be mindful that purchasing and/or selling shares of publicly traded companies when either you or your Immediate Family Member serves on that company’s Board of Directors may require additional reporting and/or prior approval by that company. Please contact the Compliance Department of that company for guidance.

Employees serving on the Board of Directors for Prudential-affiliated joint ventures may be subject to trading restrictions on shares issued by the joint venture’s partner(s). Please contact your Local Compliance team for guidance.

Short Sales

You may not short PFI related securities under any circumstances.

Additionally, Access and Investment Persons may not short sell any security that requires pre-clearance or is prohibited. See Exhibit D.

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Additional Requirements for Access and Investment Persons

Preclearance Process for Personal Trading

The requirements in the Code are designed to mitigate or eliminate any potential or apparent conflict that may occur between your personal account dealing and client security dealing. The following requirements apply to your personal dealing in Covered Securities in Investment Securities Accounts for which you have a Beneficial Interest (See Exhibit C – Beneficial Interest).

What Trades Must Be Precleared?

If you are classified as an Access or Investment Person, you must receive approval before buying, selling, gifting and transferring ownership of stocks, bonds, options, other publicly traded securities, and private placements (Covered Securities) in any reportable Investment Securities Account. Please refer to Exhibit D to see what you need to preclear and what you are not required to preclear. You should consider any potential conflicts of interest before trading regardless of whether pre-clearance is required. PruCo Access Persons may have additional exclusions please consult with your dedicated compliance team.

How does the Preclearance Process Work?

You must preclear any trades in Covered Securities in an Investment Securities Account for which you have a Beneficial Interest.

U.S Based Employees	Non-U.S. based Employees
Employees preclear using STAR. See Exhibit	Employees preclear using STAR when available.
D for specific requirements.	Please note local law or administrative issues may limit the availability of STAR.
	In these cases, employee personal trading activity is approved, monitored, and
	tracked locally.
	Please consult your local dedicated compliance team for details.

Most requests are approved or denied immediately, but some may take longer to evaluate. Please note, a reason for denial may not be provided if it could result in the release of Confidential Information.

Two-Day Approval Window

Approvals and denials are communicated via email. If your requested transaction is approved and you choose to transact, you have until the end of the next calendar day to execute your transaction. If one of your approved days is on a weekend or market holiday, your approval does not carry over to the next business day. A new preclearance request will be required after the two calendar days have passed.

If the transaction is not placed and executed within the approved timeframe, you will need to submit a new trade request in STAR. Limit orders are allowed only if they are set to expire within the preclearance approval window.

If you engage in multi-day limit orders, you must obtain preclearance approval for the days that the order is outstanding. Transactions triggered by limit orders, margin calls, or margin account maintenance fees require preclearance approval and may result in violations.

Options & Futures

As detailed in Exhibit D, the purchase, sale and exercise of options and futures are generally subject to the same restrictions as applicable to the underlying security.

Trading options on a security held by any PGIM portfolio is at the discretion of Compliance.

You may not write uncovered call options or buy uncovered put options on any security that requires pre-clearance.

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Investment & Access Persons should keep in mind that the short-term trading profit rule might affect their ability to close out an option position at a profit as noted below.

Covered Calls/Put Options. You may purchase a put option or sell a call option if the option has a “period to expiration” of at least 60 calendar days from the date of opening the contract and you hold the option for at least 60 calendar days prior to closing of the contract. If you purchase a put to open on a security you already own, you may exercise the put once you have held the underlying security for 60 calendar days.

For PGIM and CIO Employees, except for futures on certain broad-based indices listed in Exhibit D, you may not trade futures, forward contracts, including currency forwards, physical commodities and related derivatives, over- the-counter warrants or swaps. The prohibition on commodities trading applies to trades in futures and over the counter derivatives rather than holding the physical commodity (e.g., gold bullion) or gaining exposure via publicly traded ETFs holding physical commodities (e.g. ETFs/ETCs, which are subject to pre-clearance and minimum holding periods – see Covered Securities).

Preclearance is not required when the option is exercised without any action on your part.

You should be cautious when transacting in options since a client transaction in the underlying security or a restriction associated with the underlying security may prevent an option transaction from being closed or exercised.

Additional Restrictions for NFA Associated Persons

Employees who are Associated Persons with the National Futures Association are prohibited from trading futures in their personal Investment Securities Accounts and are prohibited from maintaining a personal futures trading account.

Trading Restrictions

Excessive Trading

You may not engage in an excessive volume of trading in your personal accounts. High volumes of personal trading may raise concerns that your energies and interests are not aligned with client interests or our long-term investment philosophy and could potentially impact your ability to conduct assigned responsibilities. You and your supervisor may be notified when personal trading appears excessive (75 or more transactions per quarter).

Restricted Securities

You are prohibited from purchasing or selling securities of issuers on PGIM’s Restricted List(s).

Compliance is responsible for maintaining these Restricted Lists and/or Watch Lists pursuant to their standard operating procedures. Restricted Lists and Watch Lists are confidential and may not be shared.

If you acquired restricted securities prior to becoming subject to the Code or prior to the security being placed on the Restricted List or Watch List you must obtain a written exception from your Compliance Officer prior to the sale of such security.

Blackout Periods

You will not be granted preclearance to transact in a Covered Security when there is a pending buy or sell order for a client in that same security. Additionally:

Access Persons will not be granted preclearance to trade in a Covered Security on the same day a client trade occurs in the same security if they have knowledge that security is being considered for a client transaction.

Investment Persons will not be granted preclearance to trade in a Covered Security within seven

(7) calendar days of a client trade occurring in the same security.

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In addition, the Law Department may issue a trading restriction that applies to all or a certain subset of Employees on any Prudential-issued security or any security of a third-party issuer. The Law Department will notify impacted Employees directly with instructions regarding the trading restriction.

Minimum Holding Periods & Short-Swing Profits

Access & Investment Persons are prohibited from profiting from a purchase and sale, or sale and purchase, of the same Covered Security within any sixty (60)-calendar day period.

Transactions resulting in a loss are not subject to this prohibition.

Minimum holding periods are applicable for any purchase and subsequent sale, or any sale then subsequent purchase (short-term trading), of the same Covered Security.

Minimum holding periods for Covered Securities are as follows:

	Profile	Minimum Holding Period
	Access & Investment Person	Two months (60 calendar days)
	Employees located in Japan	PGIM Public and Private Fixed Income: Six months (180 calendar days)
		PGIM Real Estate: Three months (90 calendar days)

In keeping with the spirit of this restriction, Access and Investment Persons should not engage in options or other derivative strategies that lead to the exercise or assignment of Covered Securities that would result in a prohibited transaction (i.e., writing a short call or buying a long put with an expiration date of less than sixty days). Any violation of this prohibition will result in disgorgement of profit and/or disciplinary action.

With respect to derivatives, any transaction to close out a derivative position cannot be executed until the end of the holding period. The holding period starts the day after execution of your trade. Calculations are made using the “first-in, first-out” (FIFO) method unless a different method is required in your local jurisdiction. Any exceptions to the above will be made only after compliance review and written approval.

Exceptions (Blackout Periods, Short Swing Profits and Minimum Holding Periods)

Exceptions may be granted to the Minimum Holding Periods, Blackout Periods and Short Swing Profits Rule when the transaction is in a discretionary managed account, non-volitional, or below a certain de minimis threshold.

De minimis Amounts

De minimis amounts are based on USD and are calculated to the equivalent local currency when trading in non-US markets; aggregated over 30 days

	Blackout Period	Short Swing Profits Rule
	All Securities Subject to Pre-Clearance	All Securities Subject to a Minimum Holding
		Period (Equities, ETFs, Debt, etc.)
	$50,000 or less	$100 or less
	Minimum Holding are any trades, or series of trades	Round-trip transactions over the minimum period
	effected over the minimum period	(Buy and Sell or Sell and Buy)

Transactions in Covered Securities involving no more than the amount listed in the table above will not violate the Code. Compliance has discretion up to the nearest round lot.

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Additional Restrictions for PGIM Real Estate – Prudential Retirement Real Estate Fund (“PRREF”)

Employees in PGIM Real Estate, and those that support PGIM Real Estate, are prohibited from trading any real estate-related securities (including real estate investment trusts (REITs) and real estate operating companies (REOCs).

PGIM Real Estate Employees, as well as certain other individuals who have been specifically notified, collectively called “PRREF Covered Individuals,” are subject to special restrictions and requirements including:

The PRREF trading window and blackout period procedures; and

Only permitted to execute PRREF transactions during the respective open trading window.

Controls have been established to prevent prohibited transactions during closed trading windows. If a blocking system fails, you are still responsible for adherence to the Code. PGIM Real Estate compliance staff will send PRREF trading window and blackout period notices to all PRREF Covered Persons.

Certain limited transactions are permissible during blackout periods. Please contact your Compliance Officer for additional information regarding blackout period exclusions.

Investment Clubs

All employees are prohibited from participating in Investment Clubs.

Financial Wagering Instruments and Prediction Markets

You are prohibited from engaging in any transaction that constitutes a financial wager on the outcome of market, economic, or geopolitical events, where the participant does not acquire a direct interest in the underlying asset.

This includes, but is not limited to:

•Prediction Markets: Platforms that allow participants to bet on the likelihood of specific outcomes (e.g., interest rate decisions, election results, corporate earnings) through event contracts, options, or similar instruments.

•Spread Betting and Contracts for Difference (CFDs): Instruments that enable speculation on the price movement of financial assets without ownership of the underlying asset.

•Other Financial Wagering Instruments: Any product or platform—regulated or unregulated—that facilitates betting on financial outcomes without asset ownership, including synthetic derivatives (e.g., futures, options) or similar instruments.

Such transactions are considered speculative and can pose significant compliance and reputational risks

This prohibition does not apply to wagering on non-financial events such as sports, entertainment, or cultural outcomes (e.g., Super Bowl, Oscars, World Cup), which fall outside the scope of this Code. However, be mindful that such activities are not permitted on Prudential’s premises or while engaged in Prudential business.

Additional Requirements for Designated Persons

Trading Limited During Open Window

If you are identified as a Designated Person outlined in Prudential’s Global Insider Trading Policy, you may only trade PFI stock during an open Trading Window, or such other periods of time as determined at the discretion of the Law Department. The current Prudential Trading Window Calendar can be located in the Document Library in STAR.

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Preclearance Required for Senior Vice Presidents and Above

Employees who are a level 1-4 or 56A (e.g., Senior Vice Presidents and above), must always preclear all PFI stock trades. Compliance & Law will determine whether there is potential Material Nonpublic Information (“MNPI”) risk before you receive approval.

All employees are prohibited from trading PFI securities when in possession of MNPI regardless of pre-approval. Please contact Compliance with any questions.

Automatic investment plans, default activities, stock awards and grants are exempt from preclearance.

Exceptions

Excluded Transactions

The following transactions are excluded from the above trading restrictions:

Purchases or sales that are not voluntary, including tender offers and broker-initiated transactions.

Purchases or sales that are part of an automatic investment plan or discretionary managed account which have been approved by Compliance.

The acquisition of:

Securities because of a corporate action.

Securities because of a gift or inheritance.

Securities through an employer retirement plan such as a 401(k) plan or stock purchase plan.

Transfers in-kind of Covered Securities.

Discretionary Managed Accounts

Discretionary Accounts are managed for you by a registered investment adviser or bank/trust company over which you have no direct or indirect influence or control. These accounts need to be reported, and with approval from Compliance they are exempt from:

Quarterly transaction and annual holdings certifications.

Access & Investment Person personal investing rules (such as pre-clearance requirements and minimum holding periods).

To receive approval, submit documentation to Compliance demonstrating that all trading in the account is under the sole discretion of your adviser or other designee. Discretionary accounts still require disclosure in STAR (or other approved process, for non-U.S. based employees) and transactions in private placements and limited offerings still require preclearance approval.

Additionally, annually you will attest and acknowledge that you:

Had no direct or indirect influence or control over the trading decisions in your discretionary account(s); and

Did not suggest trades to the manager or in any way direct the manager to make any particular trades in securities for the discretionary account(s).

You are required to inform Compliance immediately if you terminate any approved advisory relationship or make management changes.

Exemptions While on Leave

All personal trade monitoring requirements outlined in the Code remain in effect while you are on leave of absence, disability, or vacation.

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In certain circumstances, when you have no access to Prudential or its systems while on extended leave, you may request a temporary suspension from certain requirements. Please work with the appropriate Compliance Officer (and management) to obtain an exemption.

Your Business Unit Compliance Officer may grant an exemption only when it would not violate laws or regulations. Until you receive confirmation of an exemption, all requirements remain in effect.

Non-Compliance

You are required to promptly report non-compliance of the Code to your business unit Chief Compliance Officer or their designee.

Incidences of non-compliance reported or detected through internal monitoring will be reported to the Ethics Committee. This Committee will review all incidents and determine any sanctions or other disciplinary actions that may be deemed appropriate.

Depending on the facts and circumstances of the incident, sanctions may include verbal reminders, educational letters, disciplinary letters, monetary penalties, suspension without pay, personal trading ban, reduction in PTO days, or other disciplinary action up to and including termination of employment. In accordance with FINRA Rule 3110, certain transactions by Registered Representatives prompting an investigation may require notification to the Self Reporting Organization. Violations of personal securities trades may require reporting to other regulatory authorities and be disclosable to future employers.

Recordkeeping

Prudential’s registered investment advisers are required under the Investment Advisers Act of 1940 and the Investment Company Act of 1940 to keep records of certain transactions in which Access and Investment Persons have a direct or indirect beneficial interest.

Compliance maintains all records relating to compliance with the Code such as preclearance requests, exception reports, memoranda relating to non-compliant transactions, records of violations and any actions taken as a result thereof, acknowledgements, and the names of Access Persons.

These records are maintained in accordance with applicable law and Prudential’s Recordkeeping Standards.

15

Exhibit A – Key Definitions

Access Person: Any Employee who has access to nonpublic information regarding any client’s purchase or sale of securities or non-public information regarding the portfolio holdings of any client account or anyone identified by Compliance who should be held to the Code because of the activities conducted by their business unit.

Affiliated Open-End Mutual Fund: A proprietary investment company advised by Prudential, or a non- proprietary investment company sub-advised by Prudential, and any investment company whose investment adviser or principal underwriter is controlled by or under common control with Prudential.

Approved ETF List: Select broad-based ETFs that track an index with a minimum of 100 constituents and other ETFs that compliance has determined to be sufficient. See the document library in STAR for the current Approved List

Associated Person: Any officer, director or branch manager (or any person occupying a similar status or performing similar functions), any person directly or indirectly controlling, controlled by, or under common control with the broker-dealer, any Employee of the broker- dealer or individuals performing covered functions under the Operations Professional rule 1230 (b)(6), except someone whose functions are solely clerical or ministerial. This includes all Employees and support personnel who are registered with a FINRA member broker-dealer firm. For the purposes of the Code Associated Persons may be classified as either Associated, Access or an Investment Person.

Authorized Broker-Dealer and Authorized Futures Commission Merchants (FCMs*):

•	Charles Schwab*	•	Interactive Investor	•	Rockefeller Capital
•	E*TRADE/Morgan	•	JP Morgan/Chase		Management
	Stanley*	•	LPL	•	UBS*
•	Edward Jones	•	Merrill Lynch	•	Vanguard
•	Fidelity	•	Raymond James	•	Wells Fargo

•Hargreaves Lansdown

U.S.-based reportable Investment Securities Accounts must be held at one of the above firms. Employees with non-U.S. reportable Investment Securities Accounts are encouraged to use firms that will provide an electronic feed to STAR.

Automatic Investment Plan: Regular periodic purchases (or withdrawals) that are made automatically in (or from) Investment Securities Accounts in accordance with a predetermined schedule and allocation. An automatic investment plan includes dividend reinvestment plans (“DRIPs”) and Employee Stock Purchase Plans (“ESPPs”).

Beneficial Interest: You have Beneficial Interest of any account or securities in which you have a direct or indirect financial interest. This includes accounts or securities held in your own name or the name of your spouse or equivalent domestic partner, your minor children, and relatives living with you and to whom you provide or receive financial support or whose investments for which you have discretion, influence, or control. This could include accounts or securities of individuals with whom you share living expenses, bank accounts, rent or mortgage payments, ownership of a home, or any other material financial support. See Exhibit C for more information.

Blackout Period: A temporary period of time as determined by Compliance during which you may be restricted from making any personal securities trades in certain specific Covered Securities to prevent conflicts of interest and safeguard the company’s and clients’ interests and integrity.

CCO: Business Area Chief Compliance Officer or their designee.

Company: Prudential Financial, Inc. and its subsidiaries, otherwise known as “Prudential.”

16

Covered Securities: In general, any securities (and derivatives thereof), including but not limited to individual stocks and bonds, exchange-traded products (ETFs and ETNs), closed-end funds, private placements, and limited offerings. See Exhibit D for a detailed list of Covered and Non-Covered securities.

Designated Person: An Employee who, during the normal course of his or her job, has routine access to material nonpublic information about Prudential. Material Nonpublic Information may consist of financial or non-financial information about Prudential as a whole, or one or more Divisions or Segments. See the Global Insider Trading Policy for more information.

Discretionary Managed Account: An account managed on a discretionary basis by a person other than the Employee or an algorithmic tool (robo-adviser), over which the Employee has no direct or indirect influence or control over the selection or disposition of securities and no knowledge of transactions therein. A Discretionary Managed Account must have a formal investment management agreement that provides full discretionary authority to a third-party money manager.

Dividend Reinvestment Plan (“DRIPs:): A stock purchase plan offered by a corporation whereby shareholders purchase stock directly from the company (usually through a transfer agent) and allow investors to reinvest their cash dividends by purchasing additional shares or fractional shares.

Employees or You: All employees of Prudential, as well as certain others as identified by Compliance.

Ethics Committee: Governance committee composed of senior leaders throughout Prudential. The Committee meets quarterly, or more often as needed, to review potential violations of the Code.

.

FCA: Financial Conduct Authority – a U.K. regulator.

Initial Public Offering: An offering of securities registered under the Securities Act of 1933, the issuer of which immediately before registration was not subject to the reporting requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934.

Investment Club: A group of two or more people, each of whom contributes money to an investment pool and participates in the investment making decision process and shares in the investment returns.

Investment Persons: An Access Person who also makes or participates in making decisions regarding the trading of securities in any client account, has access to such decisions or assists in the trade process. Investment Persons generally can include PMs, research analysts, traders, trade operations, , investments, product development and certain ELT members.

Investment Securities Accounts: Any accounts in which you have a Beneficial Interest (defined above) and other accounts you could be expected to influence or control, in whole or in part, directly or indirectly, whether for securities or other financial instruments, and that can hold Covered Securities (defined above), whether or not such capability is utilized.

Immediate Family Member: Relatives who you share the same household with, and you provide, or receive, material financial support including child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, etc.

Material Nonpublic Information (“MNPI”): Information that is not available to the investing public that an investor, considering all the surrounding facts and circumstances, would find important in deciding whether or when to buy, sell, or hold a security.

Monitored Persons: The term Monitored Persons refers collectively to Supervised Persons, Access Persons, Investment Persons, Associated Persons, and Designated Persons. This term is used by Compliance for back- end monitoring purposes.

17

NFA Associated Person: An individual who solicits orders, customers, or customer funds (or who supervises persons so engaged) on behalf of a commodity trading advisor (CTA) or commodity pool operator (CPO).

Non-Volitional: Investment Securities Account activity related to: i) transactions in approved Discretionary Managed Accounts; ii) transactions in pre-approved dividend reinvestment plans; iii) transactions resulting from automatic rebalancing plans; and v) receipt of employee stock or option bonus awards.

NRSRO: An SEC-registered Nationally Recognized Statistical Rating Organization (NRSRO). Such entities assess the creditworthiness of an obligor as an entity or with respect to specific securities or money market instruments.

Private Placement: An offering that is exempt from registration under the Securities Act of 1933, as amended, under Sections 4(2) or 4(6), or Rules 504, 505 or 506 there under.

Private Securities Transaction: Any securities transaction outside the regular course or scope of an associated person’s employment with a member, including but not limited to, new offerings of securities which are not registered with the Securities and Exchange Commission, but not including transactions in investment company and variable insurance and annuity securities. You are prohibited from investing in these transactions including Crowdfunding investments that are private placements without prior approval from their Local Compliance Officer, and as applicable, Broker-Dealer Compliance Officer based on a determination that no conflict of interest is involved.

Prudential or the Company: Prudential, its affiliates, and its subsidiaries.

Prudential Affiliated Funds: Proprietary funds advised by Prudential, or a non-proprietary fund sub-advised by Prudential, and any fund whose investment adviser or principal underwriter is controlled by or under common control with Prudential.

Prudential Securities Trading Window: The period of time commencing at the opening of business on the date that is two full trading days after an earnings release and ending at the close of business on the date that is two weeks prior to the end of each quarter, or such other period of time as determined at the discretion of the Law Department).

Star Compliance (STAR): The monitoring system utilized for all personal compliance disclosures including Personal Account Dealing.

Supervised Persons: Individuals who are officers, directors, and employees of a registered investment adviser, as well as certain other individuals who provide advice on behalf of the adviser and are subject to the adviser’s supervision and control.

SEC: U.S Securities and Exchange Commission – a U.S. regulator.

Uncovered Option: An option strategy where the options contract writer (i.e., the seller) does not hold the underlying asset to cover the contract in case of assignment (as opposed to a covered option). Nor does the seller hold any option of the same class on the same underlying asset that could protect against potential losses (options spread).

U.S. Government Entity: Any U.S. state or local government; any agency, authority, or instrumentality of a state or local government; any pool of assets sponsored by a state or local government (such as a defined benefit pension plan, separate account or general fund); and any participant-directed government plan (such as 529, 403(b), or 457 plans)

18

Exhibit B – Summary of Code Requirements by Employee Classification

Summary of Code Requirements by Employee Classification

	Supervised		Associated	Access	Investment
Acknowledgement Requirements	Required		Required	Required	Required
Complete new hire and other periodic certifications,
attestations, and acknowledgments.
Account Reporting Requirements
Report all Investment Securities Accounts and future	Not		Required	Required	Required
accounts where you have a beneficial interest.	Required
Report transactions and holdings for all securities and	Not		Required	Required	Required
			(transaction
future accounts where you have a beneficial interest.	Required
			reporting only)
Maintain Investment Securities Accounts at Authorized	Not
Broker-Dealers and Authorized Futures Commission			Required	Required	Required
	Required
Merchants
Report Affiliated Open-End Mutual Fund Accounts and	Not		Required	Required	Required
Prudential Sponsored Insurance/Annuity Products	Required
Report Retirement Accounts (e.g., 401K) that can hold	Not
individual securities or Prudential Affiliated Funds			Required	Required	Required
(Retirement accounts that do not hold securities, or	Required
Prudential affiliated funds do not have to be reported)
Discretionary Managed Accounts	Not		Required	Required	Required
	Required
Investment Restrictions
				Required
				One-Day when you	Required
	Does not		Does not	have knowledge
Blackout Period				that security is	Seven-Day
	apply		apply
				being considered
				for client
				transaction
Minimum Holdings Periods and Short Swing Profit Rule	Does not		Does not	Required (60 days)	Required
	apply		apply
Jurisdictional Guidance
Jurisdictional Area	Code
United States	Applies in Full
United Kingdom	Applies in Full

19

Summary of Code Requirements by Employee Classification

	Supervised		Associated	Access	Investment
Netherlands	Applies in Full
Mexico	Applies in Full
Japan	Applies in Full. In addition, local regulations may require more restrictive
	requirements – contact your local compliance department if you have
	questions
Ireland	Applies in Full.

References

The Code complements and should be read in conjunction with other Global Enterprise Policies that address ethics and conflicts, such as Making the Right Choices, Conflicts of Interest Policy, Global Anti-Bribery and Anti- Corruption Policy, and the Global Insider Trading Policy.

The Code is designed to comply with laws, rules, and regulations applicable to Prudential’s business across the globe, including but not limited to:

Section 206 of the US Investment Advisers Act of 1940

Section 17(j) of the US Investment Company Act of 1940

SEC Rule 17j-1, Personal Investment Activities of Investment Company Personnel

SEC Rule 204-2, Books and Records To Be Maintained by Investment Advisers

SEC Rule 204A-1, Investment Adviser Codes of Ethics

FINRA Rule 3210, Accounts At Other Broker-Dealers and Financial Institutions

FINRA Rule 3280, Private Securities Transactions of an Associate Person

FCA COBS 11.7 and 11.7A, Personal Account Dealing

Hong Kong SFC Code of Conduct for Persons Licensed by or Registered with the SFC Section 12.2

IMAS Code of Ethics & Standards of Professional Conduct 2.12, Personal Conduct and Training

NYSE Listing Rules 303A.10, Code of Business Conduct and Ethics Requirements

20

Exhibit C – Beneficial Interest

Beneficial Interest: The Code applies to all accounts and securities in which you have a Beneficial Interest (as defined above in Exhibit A – Key Definitions). This means that if you can profit, directly or indirectly, or share in any profit from a transaction, you have a Beneficial Interest. If you are unsure if an account or investment falls under your beneficial interest, contact Compliance for further guidance.

Employees Located Outside of the U.S.: If you are located outside of the United States, you may not be required to disclose or report information regarding accounts for which a spouse, dependent family member and/or minor child has a beneficial interest. Please contact your Local Compliance Team for clarification.

	Beneficial Interest	Not Beneficial Interest
	You have a spouse, domestic partner, or similar	You have a roommate and do not share bank and investment
	cohabitation arrangement: If you contribute to the
		accounts or provide material financial support to one another.
	maintenance of a household and the financial support of a
		Roommates are presumed to be temporary and therefore you
	partner or vice versa, your partner’s accounts and
		do not have beneficial interest in one another’s accounts and
	securities you have beneficial interest and are required to
		securities and are not required to disclose.
	disclose.
	Your parents live with you: If you provide financial support
	to your parents, your parents’ accounts, and securities you
	have beneficial interest and are required to disclose.
	Your child has an investment account (e.g., UGMA/UTMA)	Your child has an investment account (e.g., UGMA/UTMA) If
	If you (or your spouse) are the custodian for the minor	someone other than you (or your spouse) is the custodian for
	child, the child’s accounts give you beneficial interest and	your minor child’s account, the account does not give you
	you are required to disclose.	beneficial interest and you are not required to disclose.
	You have an adult child living in your home: If you provide	You have power of attorney: If you have been granted power
		of attorney over an account, you do not have beneficial
	financial support to your child, your child’s accounts and
		interest until the time that the power of attorney has been
	securities give you beneficial interest and you are required
		activated. Prior to activation, you do not have to disclose; post
	to disclose.
		activation you do.
	You have a college-age child: If your child is in college and
	you still claim the child as a dependent for tax purposes,
	you have beneficial interest of their accounts and securities
	and are required to disclose.
	You are the executor, trustee and/or the beneficiary of a
	trust: Due to the complexity and variety of trust
	agreements, these situations require case-by-case review
	by Compliance.

21

Exhibit D – Preclearance Summary Chart

Access & Investment Persons Pre-Clearance & Holding Period Summary Chart

			Reporting	Holding Period Required
	TYPE OF SECURITY	Pre-Clearance		60 days.
		Required	Required	Employees located in Japan:
				(FI – 180 days and RE 90 days)

Covered Securities

Publicly Traded Investment Vehicles

Closed-End Funds	Yes	Yes		Yes
Proprietary/Affiliated or Sub-advised Open End	No	Yes		No - must comply with limits in
Mutual Fund				fund documents
Unit Investment Trusts	No	Yes		No
Approved ETFs [See Star Document Library]	No	Yes		No
Exchange-Traded Funds (ETFs)	Yes	Yes		Yes
(not listed in the Approved ETF List)
Exchange-Traded Notes (ETNs)	Yes	Yes		Yes
Publicly Traded Equities
Common Stocks	Yes	Yes		Yes
Listed Depository Receipts e.g. ADRs, Ads,	Yes	Yes		Yes
GDRs
DRIPs - Automatic purchases for dividend
reinvestment plan are not subject to pre-approval	No	Yes		No
requirements. Need to report the initial account set
up/purchase within 30 days
Corporate Non-Voluntary Actions (e.g.,	No	Yes		No
Stock Splits, Mergers, Spin-off etc.)
Rights	Yes	Yes		Yes
Warrants (Listed and Exercised)	Yes	Yes		Yes
Preferred Stock	Yes	Yes		Yes
Listed Real Estate Investment Trusts (REITs)	Yes	Yes		Yes
	Only for Level 1-4			Only Section 16 Reporting
Prudential Stock	or 56A level
				Persons
	employees	Yes
Designated Persons can only trade during open				(Board of Directors and Certain
	(regardless of
window				Executive Officers) are subject to a
	other
	classifications)			6-month holding period
Initial Public Offerings (equity IPOs) and			PROHIBITED
Secondary/Follow on offerings
Private Investments in Public Equity Securities			PROHIBITED
(PIPES)
			22

Access & Investment Persons Pre-Clearance & Holding Period Summary Chart

			Reporting	Holding Period Required
	TYPE OF SECURITY	Pre-Clearance		60 days.
		Required	Required	Employees located in Japan:
				(FI – 180 days and RE 90 days)

Publicly Traded Fixed Income Instruments

Asset Backed Securities	Yes	Yes		Yes
U.S. Agency Securities including Fannie	Yes	Yes		Yes
Mae/Freddie Mac
Corporate Bonds	Yes	Yes		Yes
Convertible Bonds (converted)	Yes	Yes		Yes
Municipal Bonds	Yes	Yes		Yes
New Issues (fixed income)	Yes	Yes		Yes
Structured Notes	Yes	Yes		Yes
Sovereign Debt	Yes	Yes		Yes
Derivatives
Common Stock Options	Yes	Yes		Yes
Options and futures on certain Broad-Based
Indices. (S&P 500, FTSE 100, FTSE 250, MSCI
EAFE, MSCI EM, NASDAQ 100, Nikkei 225, NSE
S&P CNX, Russell 1000, Russell 2000, Russell	No	Yes		No
3000, S&P 100, S&P Europe 350, and S&P
MidCap 400 including CBOE securities) and ETFs
(on the Approved ETF list)
NFA Associated Persons are prohibited from
trading in futures
All other options and futures that are not listed		PROHIBITED
above
Forward Contracts		PROHIBITED
Commodities Contracts		PROHIBITED
OTC Warrants or Swaps		PROHIBITED
Derivative Instruments of Prudential Securities		PROHIBITED
speculative in nature: e.g., short sales; put or
call options
Derivatives of Sovereign Debt		PROHIBITED
Currency Related Derivatives (Futures, Swaps		PROHIBITED
and other structured products tied to
currencies)

23

Access & Investment Persons Pre-Clearance & Holding Period Summary Chart

			Reporting	Holding Period Required
	TYPE OF SECURITY	Pre-Clearance		60 days.
		Required	Required	Employees located in Japan:
				(FI – 180 days and RE 90 days)

Private Investments, Health Savings Accounts, Investment Clubs, Short Sales, & Financial Wagering and Predictive Markets

Private Investments (e.g. limited partnerships;	Yes	Yes		N/A
private placements)
Hedge Funds	Yes	Yes		Yes
HSA Accounts with Self-Directed Brokerage
Accounts (Health Equity Schwab Account) need to	Yes	Yes		Yes
follow the applicable preclearance requirements
listed above
Investment Clubs		PROHIBITED
Short Selling of any security that requires pre-		PROHIBITED
clearance under the Code
Financial Wagering Instruments and Prediction		PROHIBITED
Markets

The following do not require pre-clearance and reporting and are not subject to holding period requirements

	Non-Affiliated Open End Mutual Funds	No	No	No
	Money Market Funds	No	No	No
	Investments in 529 Plans	No	No	No
	Brokerage CDs	No	No	No
	Investment Grade Short-Term Debt
	Instruments (rated in one of the two highest	No	No	No
	categories by an NRSRO and have a maturity
	of less than 366 days)
	Bankers’ Acceptances & Certificates of	No	No	No
	Deposits
	Direct Obligations of the US Government	No	No	No
	(US Treasuries)
	Commercial Paper	No	No	No
	Cash Currencies Transactions (buying EURO,	No	No	No
	GBP, etc.)
	Cryptocurrencies that are not securities	No	No	No

24

Information Barrier Standards

August 2026

Applies to:

All employees (full-time and part-time), globally, that work for, or support, Prudential’s general account, institutional asset management, investment adviser, and broker dealer businesses (CIO, PGIM and PIMS).

All contractors, interns, temporary employees, and others who have been notified by compliance are subject to this policy.

Questions?

For any questions, please contact your local compliance officer or PST.Help@prudential.com

These Standards complement other important Prudential policies that address ethics and conflicts, such as Prudential’s Code of Conduct

–Making the Right Choices, Conflicts of Interest Policy, Global Insider Trading Policy, and Code of Ethics – Personal Securities Investing Standards.

Prudential Financial, Inc.- Compliance Approval Required Prior to External Dissemination

Policy Statement

PGIM is subject to strict laws and regulations that prohibit the misuse of Material Non-Public Information (“MNPI” as defined below). You are strictly prohibited from using MNPI to execute securities transactions for the company, client or personal gain. You are also prohibited from sharing MNPI with anyone who does not require the information in the proper course of their employment. PGIM takes a zero-tolerance approach to misuse of MNPI.

PGIM has implemented Information Barrier Controls (as defined below) designed to control the flow of, and prohibit the misuse of MNPI and to manage conflicts of interest which may arise as a result of receiving MNPI.

The below Standards set out the minimum requirements that apply to all PGIM employees, consultants, contractors, interns and others who have been advised to be subject to this Policy.

Standards

These Information Barrier Standards (“Standards”) outline the controls and information barriers that are reasonably designed to safeguard material non-public information and ensure compliance with applicable insider trading laws and regulations. PGIM’s Chief Legal and Compliance Officer is authorized to approve exceptions to and modifications of these Standards. Any requests should be documented and set forth the basis and rationale and any conditions to which the approval is subject.

For purposes of these Standards, material non-public information (“MNPI”) is defined as information not available to the general public that a reasonable investor would consider material when making decisions to buy, sell, or hold a security. Information that may not be material on its own can become MNPI when combined with other information held or internal data, such as strategic decisions or anticipated actions.

Information is considered public only when it has been widely disseminated through recognized channels (e.g., public filings, press releases, newswire services). Information accessible solely to company employees or a limited group of analysts, brokers, or institutional investors is generally not considered public.

PGIM maintains physical separation and technological controls (“Information Barrier Controls”, as further defined below) designed to prevent the exchange of MNPI between distinct investment teams and designed to control the flow of inside information. These Information Barrier Controls are designed to support compliance with insider trading laws and regulations, and to manage conflicts of interest, by enabling PGIM’s investment teams to trade independently, even when other PGIM teams may possess MNPI.

To further safeguard PGIM’s confidential information and MNPI, all employees - whether working in PGIM offices, remotely, or in shared spaces—must maintain such information in a secure, and organized workspace in alignment with these Standards. This includes removing and securing sensitive, including confidential, documents in locked drawers or cabinets when unattended, locking or shutting down devices when not in use, and ensuring passwords or access credentials are not left visible. Computer sessions must be locked when stepping away, and electronic files containing confidential information

Prudential Financial, Inc.- Compliance Approval Required Prior to External Dissemination

should be secured when not in use. Sensitive documents must be disposed of in designated shred bins, and printouts containing MNPI, confidential or personally identifiable information, or client data should be promptly retrieved and removed from shared printers or copiers.

Under these Standards, you may not share MNPI without prior written approval from Compliance, nor may you seek MNPI from others. Any other confidential, proprietary or other information that you receive during your time at Prudential must not be shared with those who do not have a need to know the information, even when this policy is otherwise followed.

You are required to understand and comply with these Standards and attest to compliance with these Standards at least annually. Employees will typically receive training on these Standards at time of hire and periodically thereafter.

Information Barrier Classifications and Controls

Above the Barrier: Certain Investment Group or Permitted Shared Resource senior officers and enumerated control functions as noted in Exhibit A may need access across Investment Groups to make strategic decisions or perform their job responsibilities. Such personnel are not involved in making security-specific trading or investment decisions for PGIM or our clients.

•Employees designated as Above the Barrier are generally not subject to the physical and technological restrictions noted in these Standards but should only communicate and receive relevant information on a “need-to-know” basis.

Information Barrier Controls: PGIM has implemented Information Barrier Controls to: (a) contain the MNPI within an Investment Group and their support teams; (b) prevent the misuse of MNPI; and (c) limit transacting while in possession of MNPI. These controls permit other Investment Groups to continue transacting unimpeded by limiting their access to MNPI. PGIM’s Information Barrier Controls include but are not limited to:

•Policies and Procedures

•Training

•Physical Separation

•Technological Separation

•Restricted Lists

Isolated Information Barrier: As needed, Compliance may approve “ad hoc” or Isolated Information Barriers around one or a group of employees with respect to potential receipt or sharing of MNPI. The relevant Compliance department is responsible for documenting the approval, maintaining the applicable controls and escalating and addressing any breaches of the Isolated Information Barrier. Please refer to the section titled “Barrier Crossings – Isolated Information Barriers” for more information regarding Isolated Information Barriers.

Investment Group: At PGIM, MNPI resides primarily in our Investment Groups. Investment Group means each distinct PGIM business group listed in Exhibit A that has its own investment and/or trading

Prudential Financial, Inc.- Compliance Approval Required Prior to External Dissemination

team that has been designated or grouped separately from other investment units. Investment Groups are subject to the following Information Barrier Controls:

•Physical Separation: Investment Groups may not co-locate with each other.

•Technological Separation: Access to Investment Group investment systems and drives is limited.

Investment Group workspace co-location and systems access permissions may be granted to Permitted Shared Resources (as defined below) that provide support to an Investment Group and require such access to perform their roles.

Investment Group Sub-Division: From time to time, we may designate a sub-division of an Investment Group as a separate sub-division information barrier (the “Sub-division Barrier”) for the purpose of receiving and containing MNPI separate from the rest of the Investment Group. The Sub-division Barrier should have sufficient managerial, physical, and technological separation from the rest of the Investment Group and may have additional controls as determined by Compliance. With reasonable controls, the receipt of MNPI by the members of the Sub-division Barrier would not restrict the Investment Group unless the MNPI was intentionally or inadvertently shared.

Permitted Shared Resources: Business groups which support multiple Investment Groups and which do not have investment authority are designated as “Permitted Shared Resources.” These business groups include the Institutional Client Group, Global Wealth, Product and Marketing, Portfolio Specialists, Operations, Technology and Finance. Permitted Shared Resources are subject to the following Information Barrier Controls:

•Physical Separation: Permitted Shared Resource teams may generally share workspace with one another, but can only co-locate with an Investment Group if they provide dedicated support to the Investment Group and require such access to perform their role.

•Technological Separation: Permitted Shared Resource teams may access each other’s systems, provided those systems do not contain unsecured MNPI. Cross-team system access should be limited to teams that regularly share information to perform their functions.

Investment Group co-location and systems access permissions may be granted to Permitted Shared Resources that provide support to an Investment Group and require such access to perform their roles.

Restricted Lists: A list of issuers or related issuers (e.g., affiliates, competitors) with respect to which PGIM has MNPI. Employees are prohibited from entering into any securities or derivative transactions in relation to any securities that are included the Restricted Lists applicable to them. If you obtain MNPI, from any source, with respect to an issuer, you must immediately notify Compliance. Compliance will place the issuer and/or the related issuer on the appropriate Restricted List(s) unless otherwise addressed (e.g., creation of Isolated Information Barriers). Trading restrictions will generally apply to related issuers (e.g. parents and subsidiaries) unless it can be determined that the MNPI is not material to those related issuers. Once Compliance reasonably concludes that no employee of an Investment Group possesses MNPI with respect to an issuer, they may remove such issuer from the applicable Restricted List(s).

Prudential Financial, Inc.- Compliance Approval Required Prior to External Dissemination

Determining Whether Information is MNPI

Prior to communicating issuer specific information with a member of another Investment Group, you must receive pre-approval from Compliance to determine if the topic of discussion relates to MNPI.

Not all information that you have access to, or come in contact with will be MNPI and subject to these Standards. MNPI is typically information that is precise, non-public, related to one or more issuers, or to one or more financial instruments and the publication of which would likely have a significant effect on the price of those financial instruments, or related financial instruments.

When assessing whether information is material, you should consider whether a reasonable person would consider the information to be important in deciding whether to buy, sell or hold a security. These materiality determinants are usually fact-intensive and can be complex. It is important to consider whether a piece of information on its own may not be material, but when taken with other information it could be material. Information you receive when combined with information you already hold and decisions you have taken, or are about to take, could, collectively, be MNPI.

Some examples of information that, depending on the circumstances, may be MNPI and should not be shared with another Investment Group without Compliance involvement include, without limitation:

•A merger or acquisition;

•A sale or divestiture of substantial assets;

•A change in dividend policy;

•Earnings results (or significant trends or projections regarding or affecting company performance or earnings results);

•Embargoed government reports and statistics;

•Unannounced government actions;

•MNPI restricted lists

•Material changes to private credit ratings

•Same day trade information (e.g., open market orders or intended trades); and

•Changes in auditors or senior management.

•Issuer specific MNPI

•Material changes to valuations for fair valued transactions where the valuation is based on MNPI

•Investment Research that Includes MNPI.

Prudential Financial, Inc.- Compliance Approval Required Prior to External Dissemination

Some examples of information that, depending on the circumstances, is not MNPI and can be shared on

a need-to-know basis include:

•Client Information (e.g., Names, Contacts, Fees, Meeting Notes)

•Client Pipeline Reports

•Marketing Decks

•Valuations for unrestricted Public Equity/Fixed Income Securities

•Time Delayed Holdings (e.g. T+1 or longer)

•Security Attributes (e.g., issuer, maturity, coupon, ratings)

•Investment Research that Does Not Include MNPI

If you are not sure whether information is MNPI, or if you believe that you have come into contact with MNPI you must reach out to Compliance for clarification.

Barrier Crossings - Isolated Information Barriers

Sharing MNPI across information barriers (“Barrier Crossing”) is permitted only when necessary for a legitimate business purpose and subject to strict controls.

From time to time, Legal or Compliance in conjunction with the business may determine to implement an ‘isolated information barrier.’ In such cases, MNPI may be shared only when there is a legitimate business need that cannot be met through alternative means. Examples include but are not limited to:

a)evaluating or executing investments, mergers, acquisitions, divestitures, or joint ventures; b) providing MNPI to Credit or Investment Committee members assessing multi-group transactions; c) supporting strategic initiatives such as product development, portfolio restructuring, or market response; and d) facilitating client-directed transactions requiring coordination between multiple groups.

Except as noted below, Barrier Crossings require pre-approval from Compliance for issuer level discussions. If MNPI is being shared, requests should generally describe the business purpose and provide additional information such as recipients, scope and duration of the trading restrictions. Approved Barrier Crossings will typically be logged, if necessary, Compliance will advise on controls for isolated information barriers and will update Restricted Lists. T and trading restrictions, if any, will remain in place until Compliance determines that MNPI is no longer held.

Pre-approval is not required for certain activities, including a) internal or client meetings limited to macro themes and general performance; b) communications related to shared third-party client advisory relationships limited to the client’s portfolio; and c) communications between affiliated advisory relationships limited to the engaging Investment Group’s portfolio.

Access to MNPI must be restricted to individuals with a demonstrated need-to-know. Recipients should be briefed on their obligations regarding MNPI handling. Compliance may require additional safeguards such as chaperoned meetings or restricted system access. Any suspected or actual breach of secured MNPI or this policy must be reported to Compliance immediately.

Prudential Financial, Inc.- Compliance Approval Required Prior to External Dissemination

Confidentiality Agreements

When an Investment Group or any of its sub-divisions enters into a confidentiality agreement, governing information to be received from a third party in connection with an actual or potential investment, the employee signing the agreement is responsible for determining whether they will likely receive MNPI and notifying Compliance. If the information is deemed to be MNPI, Compliance will update the relevant Investment Group’s Restricted List(s) as necessary.

Even if the information is not deemed to be MNPI, you must take precautions to ensure that Confidential Information, regardless of materiality, is not shared with individuals who do not need to know the information to perform their job role or function. In some cases, the terms of the confidentiality agreement may not permit the sharing of such information to other businesses or Investment Groups. Please consult your Law Department, as needed, when assessing the terms of any confidentiality agreement.

Escalation

If MNPI is shared in violation of the information barriers defined herein, the incident must be escalated to Compliance immediately.

Please note that you are not required to report receipt of MNPI to Compliance when a) you receive the MNPI from a PGIM employee and b) you have been explicitly informed that the MNPI was previously reported to Compliance and that the issuer and any associated securities have already been placed on the restricted list.

Furthermore, MNPI that is created by PGIM in the course of daily business activity does not have to be escalated to Compliance. For example, a pending order or a decision to purchase or sell securities may be MNPI. Similarly, research analysis (e.g. relative value recommendations or rating changes) which may influence trading decisions may be MNPI. You are not required to report all such instances of MNPI to Compliance, however you are prohibited from disclosing that information to any other person who does not need to know the information to perform their duties and the information may only be used to carry out the purposes for which the information was created.

Failure to report violations of this policy, or failure to disclose your receipt of MNPI may breach securities laws and will be investigated and may result in disciplinary action, including termination or referral to regulatory or other law enforcement authorities. Any suspected violations should be reported to a Compliance Officer, or, if preferred, through Prudential’s Ethics Help Line (1-800-752- 7024) or website (https://prudential.ethicspoint.com). Prudential prohibits retaliation against anyone who makes a good faith report or assists in an investigation.

Nothing in these Standards restricts your right to voluntarily communicate with government agencies about potential legal violations without notifying or seeking approval from Prudential.

Prudential Financial, Inc.- Compliance Approval Required Prior to External Dissemination

Exhibit A

Investment Groups

(also known as Information Barrier Groups)

Employees/Groups Designated as “Above the Barrier”

Prudential Officers: Prudential Chief Investment Officer, Prudential Global Investment Strategy Managing Director, Prudential Head of Global Hedge Management, Prudential Chief of Global Portfolio Management, Prudential Head of Alternative Assets

PGIM Group Heads: Chief Executive Officer, Heads of Institutional Distribution, Head of Product and Marketing, Head of Strategic Capital Group and Head of Quantitative Solutions, Head of PGIM Credit, Heads of PGIM Real Estate, Head of Global Wealth, and CEO of Jennison Associates

PGIM Functional Heads and Executive Support: Chief of Staff, Chief Legal and Compliance Officer, Heads of Each of: Strategy; People Team; Information & Technology; Administration; Finance, Risk; Communications; Operations; Marketing; and Global Services, and Chief Business Officer, PGIM Credit, and Head of Business Management.

PGIM Functional Support Units: Law, Compliance, Risk Management, Enterprise Risk Management (Investment Risk and Market Risk) and Internal Audit (IA PGIM coverage)

	PGIM	PGIM Credit	PGIM	PGIM	Jennison		PGIM	Montana	Chief	PGIM
			Credit			Deerpath				Strategic
	Global	(Fixed		Quantitative	Associates		Real	Capital	Investment
			(Private			Capital				Capital
	Wealth	Income)		Solutions	LLC		Estate	Partners	Office
			Credit)							Group

	PGIM Global	PGIM Fixed	PGIM	PGIM	Jennison	Deerpath	All PGIM	Montana	Chief	PGIM
	Wealth (all units	Income (an	Private	Quantitative	Associates	Capital (all	Real Estate	Capital	Investment	Strategic
	and locations,	investment sub-	Credit (an	Solutions (all	LLC (all	locations,	(all locations,	Partners	Office,	Capital
	and investment	group of PGIM	investment	locations, and	locations,	and	including	(all	including	Group (all
	group support	Credit - all	sub-group	investment	and	investment	GRES and	locations,	Global	locations,
	functions	locations, and	of PGIM	group support	investment	group	investment	and	Hedge	and
	deemed to be	investment group	Credit - (all	functions	group	support	group	investment	Management	investment
	Investment	support functions	locations,	deemed to be	support	functions	support	group		group
	Group	deemed to be	and	investment	functions	deemed to	functions	support	Prudential	support
	employees)
		investment group	investment	group	deemed to	be	deemed to	functions	Select	functions
	PGIM Custom	employees)	group	employees)	be	investment	be	deemed to	Strategies	deemed to
			support		investment	group	investment	be		be
	Harvest LLC	PGIM Japan Co.	functions		group	employees)	group	investment		investment
		Ltd Sub-Division	deemed to		employees)		employees)	group		group
	PGIM DC		be					employees)		employees)
	Solutions	Capital Markets	Investment				Impact &
			Group
		Group					Responsible
	Strategic		employees)
		Sub-Division					Investing
	Investment	Barrier within
	Group
		Fixed
	(SIRG)
		Income
		employees (also
		known as the
		PGIM FI Private
		Credit Team)
				Prudential Financial, Inc.- Compliance Approval Required Prior to External Dissemination