Exhibit 99.B(p)(34)

December 2025

Legal & General Investment Management America, Inc., d/b/a L&G – Asset Management, America (“LGIMA”) is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) under the U.S. Investment Advisers Act of 1940, as amended (“Advisers Act”). LGIMA is also a Commodity Trading Advisor and Commodity Pool Operator subject to regulation by the U.S. Commodity Futures Trading Commission (“CFTC”) under the U.S. Commodity Exchange Act of 1936, as amended (“CEA”), and a member of the National Futures Association (“NFA”) and subject to its rules and bylaws. LGIMA is also a provincially registered Portfolio Manager in the Canadian Provinces of Ontario and Quebec. As such, we owe our clients fiduciary duties, including the highest duty of trust and fair dealing, and must place clients’ interests ahead of our own. Therefore, investment adviser personnel, when making their own investment and other personal decisions, may not place their personal interests ahead of or in conflict with those of our clients.

LGIMA has adopted this Code of Ethics (“Code”) to satisfy such fiduciary obligations and comply with Applicable Law, particularly Advisers Act Rule 204A-1.

Rule 204A-1 requires SEC registered investment advisers to adopt, maintain and enforce a written code of ethics that sets forth standards of conduct and require compliance with the Advisers Act and the other federal securities laws. Our Code has five core requirements:

1. establish standards of conduct for us and Covered Persons (as defined below);

2. require Covered Persons to comply with Applicable Law (as defined below);

3. impose certain requirements on Covered Persons and their personal investment activities, and on our Chief Compliance Officer (“CCO”) to review such activities;

4. ensure that Covered Persons receive this Code, acknowledge receipt, understand it and comply fully with it; and

5. require Covered Persons to report Code violations.

Our Code is reasonably designed to help ensure compliance with Applicable Law. Our Code is not meant to inhibit responsible personal investments and other personal activities by employees but rather imposes reasonable restrictions designed to address conflicts of interests and to prevent potential violations of Applicable Law. However, this Code does not encompass all possible areas of potential liability that employees may experience under Applicable Law, which all of us are required to observe. For instance, the federal securities laws preclude investors from trading on the basis of inside information or communicating this information in breach of a fiduciary duty. Although this Code includes requirements designed to protect and prevent the misuse of material non-public information (i.e., “inside information,” or “MNPI”), it does not cover all personal liability scenarios that could apply to Covered Persons. Therefore, Covered Persons are advised to obtain advice before engaging in any transactions or activities other than the regular performance of their normal business duties if the transaction or activity directly or indirectly involves or could affect any LGIMA client or holdings of LGIMA clients.

Questions about this Code should be addressed to the LGIMA CCO, or his/her designee.

When in doubt, ask.

Under SEC Rule 204A-1, the Code applies to a registered investment adviser’s supervised persons,¹ and the personal investment activities provisions of such code apply to the registered investment adviser’s access persons.² To ensure consistency in our Compliance program, the LGIMA Board of Directors has decided to apply the regulatory definitions and requirements of supervised persons and access persons equally to all involved with LGIMA, with the exception of our non-executive directors.³ This means that every LGIMA officer, executive director, employee as well as any other person who provides investment advice on LGIMA’s behalf and is subject to LGIMA’s supervision and control, will be subject to all requirements set forth in this Code. The CCO will determine whether any third parties engaged by LGIMA (including interns or consultants (whether full or part-time)) should be subject, in whole or in part, to this Code. For ease of reference, this Code refers to all such persons subject to the requirements of this Code as “Covered Persons”.

LGIMA has entered into, and may from time to time enter into, participating affiliate arrangements with one or more of its affiliates (each, a “Participating Affiliate Arrangement”) pursuant to which certain affiliate personnel provide services to, or act for or on behalf of, LGIMA under a written participating affiliate agreement (each, a “Participating Affiliate Agreement”). Any natural person who, pursuant to a Participating Affiliate Agreement, (i) provides investment advisory services to LGIMA clients, (ii) supports or participates in LGIMA’s advisory activities, or (iii) otherwise acts for or on behalf of LGIMA (including any seconded personnel, shared-services personnel, dual employees, or other individuals performing functions for LGIMA under such Participating Affiliate Agreement) will be deemed a “Covered Person”. The CCO or his/her designee will maintain a list of individuals operating pursuant to a Participating Affiliate Arrangement.

“Automatic Investment Plan” means a program in which regular periodic purchases (or withdrawals) are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation. An Automatic Investment Plan includes a dividend reinvestment plan.

“Applicable Law” means the Advisers Act, the Investment Company Act of 1940, as amended (the “Company Act”), the U.S. Securities Act of 1933, as amended (“Securities Act”), the U.S. Securities Exchange Act of 1934, as amended (“Exchange Act”), and the rules and regulations adopted by the SEC under any of these; the CEA and the rules and regulations adopted by the CFTC under the CEA; the Bank Secrecy Act as it applies to funds and investment advisers, and any rules adopted thereunder by the SEC or the U.S. Department of the Treasury; the U.S. Employee Retirement Income Security Act of 1974, as amended (“ERISA”), and any rules and regulations adopted thereunder by the U.S. Department of Labor (“DOL”); and any applicable laws in Canada.

“Beneficial ownership” is interpreted in accordance with Rule 16a-1(a)(2) of the Securities Exchange Act of 1934, as amended (“Exchange Act”).Beneficial ownership exists if a person, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise has a direct or indirect pecuniary interest in the securities (i.e., an opportunity, directly or indirectly, to profit or share in any profit derived from a transaction in the securities). Under this definition, beneficial ownership by a person includes securities held by members of a person’s immediate family sharing the same household, securities held in certain trusts, and a general partner’s proportionate interest in the portfolio securities held by a general or limited partnership. A person will not be deemed to be the beneficial owner of securities held in the portfolio of a registered investment company solely by reason of his or her ownership of shares or units of such registered investment company.

“Connected Person” means a spouse, live-with partner, minor child, step-child, relative or others who reside with or are dependent on a Covered Person; a company, trust or partnership in which a Covered Person or a Connected Person is directly or indirectly the owner of 25% or more of the equity, or controls more than 25% of the voting power of the organization; a trustee of any trust in which a Covered Person or Connected Person has a beneficial interest (excluding trustees of pension plans); an executor or administrator of any estate in which a Covered Person or Connected Person has a beneficial interest; or any person that, in the opinion of the CCO, should be deemed to be a Connected Person.

“Control” means the power, directly or indirectly, to direct the management or policies of a person, whether through ownership of securities, by contract, or otherwise. A firm’s officers, partners, or directors exercising executive responsibility (or persons having similar status or functions) are presumed to control the firm. A person is presumed to control a corporation if the person: (i) directly or indirectly has the right to vote 25% or more of a class of the corporation’s voting securities; or (ii) has the power to sell or direct the sale of 25% or more of a class of the corporation’s voting securities. A person is presumed to control a partnership if the person has the right to receive upon dissolution, or has contributed, 25% or more of the capital of the partnership. A person is presumed to control a limited liability company (“LLC”) if the person: (i) directly or indirectly has the right to vote 25% or more of a class of the interests of the LLC; (ii) has the right to receive upon dissolution, or has contributed, 25% or more of the capital of the LLC; or (iii) is an elected manager of the LLC. A person is presumed to control a trust if the person is a trustee or managing agent of the trust.

“IPO” means an offering of securities registered under the Securities Act where, before the IPO, the issuer of the securities did not have Exchange Act reporting requirements.

“Private Placement” means an offering that is exempt from Securities Act registration.

“Provider” means any person or entity that does, or may desire to do, business with LGIMA or its clients.

“Reportable Fund” is any fund of pooled assets advised by a Legal & General Group plc (“L&G Group”) entity or is any investment company registered under the Company Act for which LGIMA is the investment adviser or sub-adviser or whose investment adviser or principal underwriter controls LGIMA, is controlled by LGIMA or is under common control with LGIMA

“Reportable Security” means a Security (as defined in Section 202(a)(18) of the Advisers Act⁴) but excludes (a) direct obligations of the U.S. Government; (b) bankers’ acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements; (c) shares issued by money market funds; (d) shares issued by open-end funds other than Reportable Funds; (e) shares issued by unit investment trusts invested exclusively in one or more open-end funds, and (f) 529 Plans,⁵ none of which are Reportable Funds. The CCO may designate a security as a “Reportable Security” that would otherwise fall within one of these six exceptions. LGIMA deems all exchange-traded funds (“ETFs”) to be Reportable Securities.

“Self-Directed” is the ability of a person to effect a transaction in a Reportable Security. A person has discretion where they give an order to buy or sell a Reportable Security. A person does not have discretion over the securities underlying a mutual fund; if a person holds shares of a mutual fund, they have discretion over the shares of the fund that they actually hold but not the securities in the portfolio of the mutual fund because the actual fund manager of the mutual fund has discretion over those underlying assets.

“Transaction in a Reportable Security” includes any activity, whether discretionary or not, that affects the holding of a Reportable Security (e.g., buy, sell, exchange, tender, stock dividend and so on).

good faith; avoidance or the proper handling of conflicts of interest; and fair dealing. No Covered Person shall:

1. Prohibitions:

2. Requirements:

3. Exceptions and Compliance:

Notwithstanding anything herein to the contrary, the CCO or his/her designee has the discretion to determine that no further Gifts and Entertainment or charitable donations may be provided to or received from a specific Covered Person, Provider or client for a period of time should the cumulative amount be determined to be excessive or for other reasons in the CCO’s or such designee’s discretion.

In accordance with Section XV of this Code, violations shall be referred to Compliance for the appropriate sanction.

The SEC’s “Pay-To-Play” Rule 206(4)-5 “Political Contributions by Certain Investment Advisers” (“Pay-to-Play Rule”) seeks to eliminate payments designed to secure business for investment advisers. LGIMA has implemented policies and procedures to mitigate the risk of pay-to-play violations. Covered Persons are required to pre-clear all State and Local political contributions as set forth herein.

A “Covered Associate” of an investment adviser generally means any general partner, managing member, or executive officer (also a defined term), or other individual with a similar status or function; any employee who solicits a government entity for the investment adviser; and any political action committee controlled by the investment adviser. LGIMA has designated all employees as Covered Associates as they relate to this policy.

Covered Persons must pre-clear outside business activities. Outside Business Activities (“OBAs”) are defined as any activity outside of your employment with LGIMA that involves:

All the foregoing pre-clearances must be submitted for approval through StarCompliance. Covered Persons must wait for approval prior to accepting a position. The CCO or his/her designee shall determine whether the OBA raises conflicts of interest or is inconsistent with the interests of our clients. The CCO or his/her designee, at a minimum, shall establish appropriate information barriers or, if required, other procedures to isolate the person participating in an OBA from those within LGIMA making investment decisions as to the securities of any such company. The CCO or his/her designee may determine that no procedures can adequately eliminate the conflicts and may require the Covered Person to resign from or not participate in an OBA.

Once an OBA is approved, Covered Persons are responsible for keeping their status updated in StarCompliance. Any change to the status of an OBA (including resignations and terminations) must be updated in StarCompliance within 10 days of the change. In addition, Covered Persons will be required to confirm any OBAs on an annual basis. Approval for any OBA may not necessarily be granted and may be revoked at any time.

For OBAs of either the Covered Person or his/her Connected Person(s) that involve 25% ownership of a for-profit company as outlined in (3) above, the Covered Person shall:

Employees are required to obtain written pre-approval from Compliance prior to running for any public office. Employees are not allowed to hold a public office if it presents any actual or apparent conflict of interest with LGIMA’s business activities. Failure to comply with this restriction will put LGIMA at risk from managing future state or local pension plans or from collecting fees from existing plans.

Conflicts of interest arise when certain investment adviser personnel (e.g., those with knowledge of client positions or impending client transactions) buy and sell securities for their own accounts or those of their Connected Persons (“personal investment activities,” “personal account transactions,” or “PA dealing”). Currently, LGIMA treats all personnel as subject to this potential conflict of interest and therefore as Covered Persons to which personal account investing restrictions apply. For the avoidance of doubt, these procedures apply to Connected Persons and references to Covered Persons in this Section VIII also include Connected Persons. Violations constitute a breach of this Code and will be dealt with pursuant to Section XV of the Code.

(i) Trade Request for Personal Account Trading

Every individual proposing to trade a Reportable Security, including Reportable Funds, per Section VIII.A., must obtain prior written clearance from Compliance. Every request must be submitted via StarCompliance by creating a new trade request. A list of Reportable Mutual Funds can be found on StarCompliance under Document Library. Questions on how to navigate the system should be directed to Compliance. Compliance also ensures all Covered Persons receive proper training on StarCompliance.

L&G Group shares received as part of an employee’s compensation package are subject to trade reqyest requirements if the employee elects to take ownership of the shares and sell at a later date. As there are blackout periods for L&G Group throughout the year, employee sales of L&G stock may be restricted and must be approved by Compliance prior to the sale.

Covered Persons who have a private, non-public encounter with an issuer in his or her capacity as a Covered Person are restricted from trading the Reportable Security within thirty (30) business days of the encounter with the issuer.

Compliance shall review the trade request as soon as practicable, but no later than one full business day after its receipt, to determine whether to approve or reject said request. Every request is reviewed and considered by the CCO or his/her designee; however, if the CCO submits a pre-trade clearance request, the CEO or CFO will be responsible for reviewing the request. A clearance to trade is valid for the same trading day starting from the time the clearance approval was given. A pre-trade clearance that is approved after the 3:00 PM market close is valid for the next trading day. In determining whether to give a clearance, the CCO (or their designee) shall consider, among other factors:

Compliance reviews the trading activity of all Covered Persons on a periodic basis to ensure required trade requests were obtained and executed in the manner specified above. Records shall be maintained of all clearances and non-clearances.

(ii) Reporting Requirements

Records shall be maintained of all clearances and non-clearances.

(iii) Exclusions from Trade Request and Reporting Requirements.

Covered Persons do not need to obtain a trade request under Section VIII(i) or provide the reports under Section VIII (ii) with respect to the following:

Covered Persons are required to report promptly to the CCO or in the case of the CCO to the CEO, any violations of the Code. Reports will be treated confidentially to the extent permitted by law and will be investigated promptly. Reports may be made anonymously. A violation of this Code is a breach of Advisers Act Rule 204A-1 and our written policies and procedures. Retaliation against any person reporting a violation is prohibited and is a breach of this Code that may result in the sanctions set forth in Section XV of this Code. Covered Persons should review LGIMA’s Whistleblowing Policy.

The CCO or other designated personnel will monitor all personal investment activities, including the reports and confirmations filed by every Covered Person. The criteria for monitoring and testing shall remain confidential.

No Covered Person may cause or attempt to cause any client to purchase, sell or hold any security for the purpose of creating any personal benefit for the Covered Person. Sections 206(1) and 206(2) of the Advisers Act prohibit LGIMA from employing a “device, scheme or artifice” to defraud clients or engaging in a “transaction, practice or course of business” that operates as a “fraud or deceit” on clients. Both sections have been construed broadly by the SEC and used to regulate many types of adviser behavior that the SEC deems to be not in the best interest of clients or inconsistent with fiduciary obligations. One such category of behavior is taking advantage of investment opportunities for personal gain that would be suitable for clients.

Advisers Act Section 208(d) prohibits any person from doing indirectly that which cannot be done directly. Accordingly, Covered Persons may not take personal advantage of any opportunity properly belonging to LGIMA or any client. This applies to the acquisition of securities of limited availability for a Covered Person’s account that would be suitable and could be purchased for the account of a client, or the disposition of securities from a Covered Person’s account prior to selling a client position.

A Covered Person may not cause or attempt to cause any client to purchase, sell, or hold any security for the purpose of creating any benefit to LGIMA’s accounts or to a Covered Person’s accounts.

If a Covered Person believes that he/she (or a Connected Person) stands to benefit from an investment decision for a client that LGIMA or the Covered Person is recommending or making, that individual must disclose that interest to the Compliance Team. The disclosure must be made before the investment decision and should be documented by the Compliance Team. Based on the information given, the CCO or his/her designee will make a decision on whether to restrict that Covered Person’s participation in the investment decision. In making this determination, the CCO or his/her designee will consider at least the following factors: (i) was any client legally and/or financially able to take advantage of this opportunity; (ii) whether any client would be disadvantaged in any manner; (iii) whether the opportunity is de minimis, and (iv) whether the opportunity is clearly not related economically to the securities to be purchased, sold or held by an client.

A memorandum concerning the investment opportunity and the disposition of the approval request will be prepared promptly and maintained by the Compliance Team.

A. Law and Policy

Whether or not in the course of business and whether or not voluntarily, LGIMA and its Covered Persons may obtain inside information about issuers, securities or the potential effects of LGIMA’s own investment and trading in securities. LGIMA forbids any Covered Person to trade, personally or on behalf of others, including clients and Connected Persons, while having material inside information, or to communicate such material inside information to others. This is called “insider trading” and “tipping”, respectively. These apply to all Covered Persons and extend to activities within and outside their duties at LGIMA.

The term “insider trading” is not defined in the federal securities laws; rather, it is a judicially created theory of fraud outlined in case law interpreting Section 10(b) of the Exchange Act and Rule 10b-5 thereunder. Insider trading refers to the use of material inside information to trade in securities (whether or not one is an “insider”) in breach of a duty of trust or confidence or to communicate, or tip, material inside information to others.

The law concerning insider trading is dynamic and the SEC brings cases on a regular basis. The law prohibits:

Concerns about the misuse of inside information by LGIMA or Covered Persons may arise primarily in two ways.

First, LGIMA may come into possession of inside information about another company, such as an issuer in which it is investing for clients or in which its own personnel might be investing for their own accounts. As further set forth below, if it is determined that LGIMA has inside information about an issuer, investments in that issuer on behalf of clients and by LGIMA personnel, in any securities of the issuer, will be prohibited.

Second, LGIMA as an investment adviser, has inside information in relation to its own business. The SEC has stated that the term “inside information” may include information about an investment adviser’s recommendations and client securities holdings and transactions. It is the policy of LGIMA that all such information is to be kept in strict confidence by those who receive it, and may be divulged only within LGIMA to those who have an established need for it in connection with the performance of services to clients. Despite this, some trades in which LGIMA has invested for clients may be permitted because of the fact that LGIMA has made such investments may not be viewed as material (e.g., trades in highly liquid securities with large market caps). The personal trading procedures in this Code establish circumstances under which such trades will be considered permissible or restricted and the procedures to follow in making such trades.

Who is an Insider? The concept of “insider” is broad. It includes officers, directors and employees of a company. A person can be a “temporary insider” if he or she enters into a special confidential relationship in the conduct of a company’s affairs and as a result is given access to information solely for the company’s purposes. A temporary insider can include, among others, a company’s attorneys, accountants, consultants, bank lending officers, and the employees of such organizations. In addition, a person who advises or otherwise performs services for a company may become a temporary insider of that company. An employee of LGIMA, for example, could become a temporary insider to a company because of LGIMA’s and/or employee’s relationship to the company (e.g., by having contact with company executives while researching the company). A company must expect the outsider to keep the disclosed non-public information confidential, and the relationship must at least imply such a duty before the outsider will be considered an insider or temporary insider.

It may also be the case that a Connected Person of a Covered Person may have inside information and be deemed to be an insider. Accordingly, the Covered Person might be deemed to be an insider. One must be cautious in such situations in order to avoid liability for tipping or misappropriating inside information.

What is Material Information? Trading on inside information is not a basis for liability unless the information is material. “Material information” generally is defined as information for which there is a substantial likelihood that a reasonable investor would consider it important in making his or her investment decisions, or information that is reasonably certain to have a substantial effect on the price of a security. It “alters the total mix of information available.” Such information includes, but is not limited to: dividend changes, earnings, estimates, changes in previously released earnings and estimates, significant merger or acquisition proposals or agreements, major litigation, liquidation problems, knowledge of an impending default, knowledge of an impending change in a rating by a rating agency, and/or extraordinary management developments.

What is non-public information? Information is non-public until it has been effectively communicated to the marketplace. One must be able to point to a fact to show that the information is generally public. For example, information in a report filed with the SEC, or appearing in Dow Jones, Reuters, The Wall Street Journal or other publications of general circulation would be considered public.

What is Tipping? Tipping is giving or making available inside information to anyone who might be expected to trade while in possession of that information. A Covered Person may become a “tippee” by acquiring inside information from a tipper, which would then require the Covered Person to follow the procedures below for reporting and limiting use of the information.

Penalties. Penalties for trading on or communicating inside information are severe for individuals involved in such unlawful conduct and their employers, which may include fines or damages up to three times the amount of any profit gained, or loss avoided. A person may be subject to some or all of the applicable penalties even if he or she does not personally benefit from the violation.

B. Procedures

Identification and Prevention of Insider Information. If a Covered Person believes that he or she has information that is material and non-public, or has questions as to whether information is material and non-public, he or she must:

Watch List and Restricted List. If the CCO determines a Covered Person has inside information or that a security should be restricted (there may be no inside information but it becomes necessary to restrict dealings in that security), the CCO will follow the process and procedures set forth in the Information Barrier Policy and Watchlist Procedure (the “Info Barrier Policy”) and take steps to ensure that the individual(s) in possession of inside information understands that he shall refrain from any activity – trading or tipping. The CCO will take steps to monitor the activities of all other Covered Persons that do not have the inside information while they engage in activities normal to the business. All decisions about whether to add or delete a security to the Watch List or Restricted List or amend an entry shall be made in accordance with the Info Barrier Policy. All activity in any security placed on the Restricted List shall cease, unless approved in writing by the CCO and subject to the Info Barrier Policy. A security shall be removed from the Restricted List in accordance with the Info Barrier Policy if the CCO determines that no insider trading issues remain with respect to such security (for example, if the information becomes public or no longer is material).

Restricting Access to Inside Information. Care should be taken so that such information is secure. For example, files containing inside information should be sealed, access to computer files containing inside information should be restricted, and relevant conversations should take place behind closed doors.

Detecting Insider Trading. To detect insider trading, the Compliance Team will, among other things, review the trading activity reports of client accounts and Covered Persons. It is also the responsibility of each Covered Person to notify the CCO of any potential insider trading issues. The Compliance Team will investigate any instance of possible insider trading and fully document the results of any such investigation. An investigation record should include at least: (i) the name of the security; (ii) the date the investigation commenced; (iii) an identification of the account(s) involved; and (iv) a summary of the investigation disposition.

Violations of the Code of Ethics are taken very seriously by the Board of Directors and Executive Committee of LGIMA. Sanctions due to violations in personal account trading are implemented to ensure that Covered Persons understand the severity of their actions. As such, the following “Three Strikes” Policy will be enforced for personal account trading violations.

The CCO will determine penalties, in consultation with Human Resources where appropriate. Any disgorgement of profits would be directed to a charity that has no conflict of interest with LGIMA or its affiliates.

A second (or third) offense occurring more than one year after the first or second violation, as applicable, would be treated as a first offense.