Code of Ethics

Personal Investing Standards

December 2025

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
	2

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

3

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 Business 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 by compliance 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 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, PGIM Multi-Asset Solutions, 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.

4

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

research analysts).

Information may consist of

supervision and control.

• Advisory client trading

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.

5

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 Business Unit Compliance 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.

7

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 individual securities.

10

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 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 directly on commodities markets rather than holding the physical commodity (e.g., gold bullion).

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.

11

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)
	PGIM Public and Private Fixed Income: Six months (180 calendar days)
Employees located in Japan
	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.

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.

12

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.

13

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.

14

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 Business Unit 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.

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 B 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
Complete new hire and other periodic certifications,		Required		Required		Required		Required
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
				(transaction		Required		Required
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
individual securities or Prudential Affiliated Funds		Not		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
		Does not		Does not		have knowledge		Required
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
	Applies in Full. In addition, local regulations may require more restrictive
Japan	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 Business 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
3000, S&P 100, S&P Europe 350, and S&P	No	Yes		No
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
speculative in nature: e.g., short sales; put or		PROHIBITED
call options
Derivatives of Sovereign Debt		PROHIBITED
Currency Related Derivatives (Futures, Swaps
and other structured products tied to		PROHIBITED
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

December 2025

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 Sector or Permitted Shared Resource senior officers and enumerated control functions as noted in Exhibit A may need access across Investment Sectors 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 Sector and their support teams; (b) prevent the misuse of MNPI; and (c) limit transacting while in possession of MNPI. These controls permit other Investment Sectors 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 Sector: At PGIM, MNPI resides primarily in our Investment Sectors. Investment Sector 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 Sectors are subject to the following Information Barrier Controls:

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

•Technological Separation: Access to Investment Sector trading systems and drives is limited.

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

Investment Sector Sub-Division: From time to time, we may designate a sub-division of an Investment Sector 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 Sector. The Sub-division Barrier should have sufficient managerial, physical, and technological separation from the rest of the Investment Sector 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 Sector unless the MNPI was intentionally or inadvertently shared.

Permitted Shared Resources: Business groups which support multiple Investment Sectors 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 Sector if they provide dedicated support to the Investment Sector 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 Sector co-location and systems access permissions may be granted to Permitted Shared Resources that provide support to an Investment Sector 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 Sector 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 Sector or a Permitted Shared Resource that supports another Investment Sector, you must receive pre-approval from Compliance to determine if the topic of discussion relates to MNPI. The relevant Compliance department will maintain a log of approved cross-barrier communications that involve MNPI.

Not all information that you have access to or, 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.

Examples of information that, depending on the circumstances, may be MNPI 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; and

•changes in auditors or senior management.

Examples of information that, depending on the circumstances is MNPI and cannot be shared with another Investment Sector include, without limitation:

•Issuer specific MNPI

•Restricted Lists

•Same day trade information (e.g., open market orders or intended trades) unless required to perform a business function (e.g., settlements, reconciliations).

•Valuations for fair valued transactions (public or private) where the valuation is based on MNPI (consult with Compliance)

•Investment Research that Includes MNPI.

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

Examples of information that, depending on the circumstances is not MNPI and can be shared on a need to know basis include, without limitation:

•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 (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.

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-sector transactions; c) supporting strategic initiatives such as product development, portfolio restructuring, or market response; and d) facilitating client-directed transactions requiring coordination between multiple sectors.

Except as noted below, Barrier Crossings require pre-approval from Compliance. 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. Trading restrictions 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 sector’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 Sector 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 Sector’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 business units or Investment Sectors. 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 Sectors

(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, Heads of Multi-Asset Solutions and Quantitative Solutions, Head of Public and Private Fixed Income, 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 of PGIM Fixed Income

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

PGIM Global

PGIM Fixed

PGIM Fixed

PGIM

Jennison

Deerpath

PGIM Real

Montana

Chief

PGIM Multi-

Income

Quantitative

Associates

Capital

Investment

Asset

Wealth

Income (Public)

Capital

Estate

(Private)

Solutions

LLC

Partners

Office

Solutions

PGIM

PGIM Fixed Income

PGIM Fixed

PGIM

Jennison

Deerpath

All PGIM

Montana

Chief Investment

PGIM Multi-

Investments

Public

Income

Quantitative

Associates

Capital

Real Estate

Capital

Office, including

Asset Solutions

(all units and locations,

(all units and

Private

Solutions

LLC

(all units and

(all units and

Partners

Global Hedge

(all units and

and investment sector

locations, and

(all units and

(all units and

(all units and

locations,

locations,

(all units and

Management

locations, and

support functions

investment sector

locations, and

locations, and

locations, and

and

including

locations, and

investment sector

deemed to be BU

support functions

investment

investment

investment

investment

GRES and

investment

Prudential Select

support functions

employees)

deemed to be BU

sector support

sector support

sector support

sector

investment

sector support

Strategies

deemed to be BU

employees

functions

functions

functions

support

sector

functions

employees)

PGIM Custom Harvest

deemed to be

deemed to be

deemed to be

functions

support

deemed to be

LLC

PGIM Japan Co. Ltd

BU

BU employees)

BU

deemed to be

functions

BU employees)

Sub-Division Barrier

employees)

employees)

BU

deemed to be

PGIM DC Solutions

Within FI:

employees)

BU

employees)

Strategic Investment

Capital Markets

Group (SIRG)

Group - Fixed

Income Employees

Impact &

(also known as the

Responsible

PGIM FI Private

Investing

Credit Team)

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

Prudential’s Code of Conduct

MAKING THE

RIGHT CHOICES

MTRC

Prudential’s Code of Conduct

MAKING THE

RIGHT CHOICES