CODE
OF ETHICS FOR PRINCIPAL EXECUTIVE AND
SENIOR FINANCIAL
OFFICERS OF PRINCIPAL
Revised on September 15,
2026
I. Covered Officers/Purpose of the Code
The
Principal Funds code of ethics (this "Code") for the registered
investment companies within the Principal Funds complex
(collectively "Funds" and each, "Company") applies to each
Company's Principal Executive Officer, Principal Financial Officer and Treasurer
(the "Covered Officers" each of whom is set forth in Exhibit A) for
the purpose of promoting:
honest
and ethical conduct, including the ethical handling of actual or apparent
conflicts of interest between personal and professional relationships;
full,
fair, accurate, timely, and understandable disclosure in reports and documents
that a registrant files with, or submits to, the Securities and Exchange
Commission ("SEC") and in other public communications made by the
Company.
compliance
with applicable laws and governmental rules and regulations;
the
prompt internal reporting of violations of the Code to an appropriate person or
persons identified in the Code; and
accountability
for adherence to the Code.
Each Covered Officer should adhere
to a high standard of business ethics and should be sensitive to situations
that may give rise to actual as well as apparent conflicts of interest.
II. Covered Officers Should Handle Ethically Actual and Apparent
Conflicts of Interest
Overview. A "conflict
of interest" occurs when a Covered Officer's private interest interferes
with the interests of, or his service to, the Company. For example, a conflict
of interest would arise if a Covered Officer, or a member of his family,
receives improper personal benefits as a result of his position with the
Company.
Certain conflicts of interest arise
out of the relationships between Covered Officers and the Company and already
are subject to conflict of interest provisions in the Investment Company Act of
1940 ("Investment Company Act") and the Investment Advisers Act of
1940 ("Investment Advisers Act"). For example, Covered Officers may
not individually engage in certain transactions (such as the purchase or sale
of securities or other property) with the Company because of their status as
"affiliated persons" of the Company. The Company's and
Principal Global Investors, LLC’s (the
"Investment Adviser") compliance programs and procedures are designed
to prevent, or identify and correct, violations of these provisions. This Code
does not, and is not intended to, repeat or replace these programs and
procedures, and such conflicts fall outside of the parameters of this Code.
Although typically not presenting an
opportunity for improper personal benefit, conflicts arise from, or as a result
of, the contractual relationship between the Company and the Investment Adviser
of which the Covered Officers may also be directors/trustees, officers or
employees. As a result, this Code recognizes that the Covered Officers will,
in the normal course of their duties (whether formally for the Company or for
the Investment Adviser, or for both), be involved in establishing policies and
implementing decisions that will have different effects on the Investment
Adviser and the Company. The participation of the Covered Officers in such activities
is inherent in the contractual relationship between the Company and the
Investment Adviser and is consistent with the performance by the Covered
Officers of their duties as officers of the Company. Thus, if performed in
conformity with the provisions of the Investment Company Act and the Investment
Advisers Act, such activities will be deemed to have been handled ethically.
In addition, the Funds' Boards of Directors/Trustees ("Boards")
recognize that the Covered Officers may also be officers or employees of one or
more other investment companies covered by this or other codes.
The Code covers other conflicts of
interest, even if such conflicts of interest are not subject to provisions in
the Investment Company Act and the Investment Advisers Act. The following list
provides examples of conflicts of interest under the Code, but Covered Officers
should keep in mind that these examples are not exhaustive. The overarching
principle is that the personal interest of a Covered Officer should not be placed
improperly before the interest of the Company.
Each
Covered Officer must:
not
use his personal influence or personal relationships improperly to influence
investment decisions or financial reporting by the Company whereby the Covered
Officer would benefit personally to the detriment of the Company;
not
cause the Company to take action, or fail to take action, for the individual
personal benefit of the Covered Officer rather than the benefit the Company;
not
retaliate against any other Covered Officer or any employee of the Funds or
their affiliated persons for reports of potential violations that are made in
good faith.
There are some conflicts of
interest it is advisable for Covered Officers to discuss in advance with
Counsel for the Funds, if material. Examples of these include:
service
as a director on the board of any public or private company;
any
ownership interest in, or any consulting or employment relationship with, any
of the Company's service providers, other than its principal underwriter,
administrator, the Investment Adviser or any affiliated person thereof;
a
direct or indirect financial interest in commissions, transaction charges or
spreads paid by the Company for effecting portfolio transactions or for selling
or redeeming shares other than an interest arising from the Covered Officer's
employment such as compensation or equity ownership.
III. Disclosure and Compliance
each
Covered Officer should be familiar with the disclosure requirements generally
applicable to the Company;
each
Covered Officer should not knowingly misrepresent, or cause others to
misrepresent, facts about the Company to others, whether within or outside the
Company, including to the Company's directors/trustees and auditors, and to
governmental regulators and self-regulatory organizations;
each
Covered Officer should, to the extent appropriate within his or her area of
responsibility, consult with other officers and employees of the Funds and the Investment
Adviser with the goal of promoting full, fair, accurate, timely and
understandable disclosure in the reports and documents the Funds file with, or
submit to, the SEC and in other public communications made by the Funds; and
it
is the responsibility of each Covered Officer to promote compliance with the
standards and restrictions imposed by applicable laws, rules and regulations.
IV. Reporting and Accountability
Each Covered Officer must:
upon
adoption of the Code (or thereafter as applicable, upon becoming a Covered
Officer), affirm in writing to the Board that he has received, read, and
understands the Code;
annually
thereafter affirm to the Board that he or she has complied with the
requirements of the Code; and
notify
Counsel to the Funds promptly if he or she knows of any violation of this
Code. Failure to do so is itself a violation of this Code.
report
at least annually possible conflicts of interest by completing the Principal
Funds Director and Officer Questionnaire.
Counsel to the Funds is responsible
for applying this Code to specific situations in which questions are presented
under it and has the authority to interpret this Code in any particular
situation. However, any approvals or waivers sought by the Covered Officers
will be considered by the Audit Committee (the "Committee").
The Funds will follow these
procedures in investigating and enforcing this Code:
Counsel
to the Funds will take all appropriate action to investigate any potential
violations reported to Counsel;
if,
after such investigation, Counsel to the Funds believes that no violation has
occurred, Counsel is not required to take any further action;
any
matter that Counsel believes is a violation will be reported to the Committee;
if
the Committee concurs that a violation has occurred, it will take appropriate
action, which may include review of, and appropriate modifications to,
applicable policies and procedures; notification to appropriate personnel of
the Investment Adviser or its board; or a recommendation to dismiss the Covered
Officer;
the
Committee will be responsible for granting waivers, as appropriate; and
any
changes to or waivers of this Code will, to the extent required, be disclosed
as provided by SEC rules.
V. Other Policies and Procedures
This
Code shall be the sole code of ethics adopted by the Funds for purposes of
Section 406 of the Sarbanes-Oxley Act and the rules and forms applicable to
registered investment companies thereunder. Insofar as other policies or
procedures of the Funds, the Funds' Investment Adviser, principal underwriter,
or other service providers govern or purport to govern the behavior or
activities of the Covered Officers who are subject to this Code, they are
superseded by this Code to the extent that they overlap or conflict with the
provisions of this Code. The Funds' and their Investment Adviser's and
principal underwriter's codes of ethics under Rule 17j-1 under the Investment
Company Act are separate requirements applying to the Covered Officers and
others, and are not part of this Code.
VI. Amendments
Any amendments to this Code, other
than amendments to Exhibit A, must be approved or ratified by a majority vote
of the Committee.
VII. Confidentiality
All reports and records prepared or
maintained pursuant to this Code will be considered confidential and shall be
maintained and protected accordingly. Except as otherwise required by law or
this Code, such matters shall not be disclosed to anyone other than the
Committee, Board, Counsel to the Funds and officers of the Investment Adviser.
VIII. Internal Use
The
Code is intended solely for the internal use by the Funds and does not
constitute an admission, by or on behalf of any Company, as to any fact,
circumstance, or legal conclusion.