Daily Recording of Business Transactions

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This policy was developed to comply with regulations and demonstrate our commitment to the highest standards of business ethics. Taking time to fully understand the policy is critical and you must consult it whenever you are unsure about appropriate activity concerning your investments. As an integral part of the global financial system, BNY Mellon processes millions of transactions a day for clients. Therefore, it is imperative that we hold ourselves to unwavering standards in our personal trades.

This reflects on our personal and professional integrity and safeguards the hard work by previous generations of employees to build our reputation. As you can see, all our personal investments must be free from conflicts of interest and in full compliance with the laws and regulations of all jurisdictions in which we do business.

That principle is implicit in our shared values of Client Focus, Trust, Teamwork and Outperformance — and it is central to our reputation.

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Gerald L. Policy Administration The Policy is developed, interpreted, and administered by the Ethics Office in coordination with other personnel of the Company. Amendments of the Policy, will be made, or waivers of its terms will be granted, at the discretion of the Manager of the Ethics Office only, and with the concurrence of other officers or directors of the Company, where required e. Any waiver or exemption will be official only if evidenced in writing. The company formed an Investment Ethics Council IECwhich is composed of investment, legal, risk management, compliance and ethics representatives of the company and its affiliates.

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General Covered Activities All employees of the company that are deemed to be controlled by the company or have otherwise agreed to be bound by its provisions are subject to this Policy.

This includes all full-time, part-time, benefited and non-benefited, exempt and non-exempt employees.

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The provisions of the Policy have worldwide applicability and cover trading in any part of the world, subject to the provisions of any controlling local law. To the extent any particular portion of the Policy is inconsistent with, or in particular less restrictive than such laws, you should consult the Manager of the Ethics Office.

Your Compliance is Required Generally, as an employee of the company, you may be held personally liable for any improper or illegal acts committed during the course of your employment; non-compliance with this Policy may be deemed to encompass one of these acts. Accordingly, you must read the Policy and comply with the spirit and the strict letter of its provisions.

Failure to comply may result in the imposition of serious sanctions, which may include, but are not limited to, the disgorgement of profits, cancellation of trades, selling of positions, suspension of trading signals for binary options paid trading privileges, dismissal, and referral to law enforcement or regulatory agencies.

The company provides you with online access to the Policy and its amendments through MySource, or has otherwise made the Policy available to you. Should you have difficulty accessing the Policy, or have not received a copy of the Policy, the Ethics Office will provide copies upon request.

Therefore, such documents will be available for inspection by appropriate regulatory agencies and by other parties within and outside the company as are necessary to evaluate compliance with or sanctions under the Policy or other requirements applicable to the company.

The inclusion of a company on the Restricted List provides no indication of the advisability of an investment in the company's securities or the existence of material nonpublic information with respect to the company. Occasionally, such trading restrictions may be appropriate to protect the company and its employees from potential violations, or the appearance of violations, of securities laws.

Nevertheless, the contents of the Restricted List are confidential.

Daily Recording of Business Transactions

In addition to these standards, you must comply with the requirements applicable to your classification under this Policy.

Your Responsibility Every employee must follow the General Standards of Conduct set forth in this Policy or risk serious sanctions, up to and including dismissal. If you have any questions about these standards, you should consult the Ethics Office or your Compliance Officer. Fiduciary Duties In some circumstances, the company and its employees may owe a fiduciary duty to a client.

Among the duties that one owes clients when one is acting as a fiduciary on their behalf is not to engage in personal securities transactions that may be deemed to take inappropriate advantage of your position in relation to those clients.

You must be mindful of this obligation, use your best efforts to honor it, and report promptly to the Ethics Office and your Compliance Officer any company employee that fails to meet this obligation. Protecting Material Nonpublic Information and Compliance with Securities Laws In carrying out your job responsibilities, you must, at a minimum, comply with all applicable legal requirements, including applicable securities laws.

As an employee, you may receive information about the company, its clients, or other parties that for various reasons must be treated as confidential. You are expected to comply strictly with measures necessary to preserve the confidentiality of information.

Following are guidelines to determine when information is nonpublic or material. If you have determined the information to be material, but there is no announcement of it in any of these sources, it is likely to be nonpublic.

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Information received under circumstances indicating that it is not yet in general circulation and may be attributable, directly or indirectly, to the issuer or its insiders is likely to be deemed nonpublic information. Information that would affect the market price of a security price sensitive information would be material.

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All relevant circumstances must be considered when determining whether an item of information is material. If there is a doubt, you should always err on the side of caution and consider information material or nonpublic.

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Questions on material nonpublic information should be referred to your business unit Compliance Officer. The Securities Firewall policy also requires any employee who believes he or she may have received material nonpublic information to refrain from acting upon the information and immediately call their business unit Compliance Officer. When You Trade in BNY Mellon Securities General Restrictions All employees who trade in company securities should be aware of their responsibilities to the copy transactions earnings trader and should be sensitive to even the appearance of impropriety.

Short Sales — You are prohibited from engaging in short sales of company securities.

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Short-Term Trading - You are prohibited from purchasing and selling or from selling and purchasing, any company securities within any 60 calendar day period.

In addition to other potential sanctions, you will be required to disgorge any profits on such short-term trades as calculated in accordance with procedures established by the Ethics Office.

Option Transactions — You are prohibited from engaging in any derivative transaction involving or having its value based upon any securities issued by the Company or the values thereofincluding buying and writing of over-the-counter and exchange-traded options.

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This prohibition expires 48 hours after a public announcement is made. When You Trade in Non-Company Securities General Restrictions You must be sensitive to any impropriety in connection with your personal securities transactions in securities of any issuer, including those owned indirectly see Indirect Ownership in Glossary.

Daily Recording of Business Transactions

Scalping - the purchase or sale of securities for clients for the purpose of affecting the value of a security owned or to be acquired by you or the company. Spread Betting - Taking bets on securities pricing to reflect market movements activities as a mechanism for avoiding the restrictions on personal securities trading arising under the provisions of the Policy.

Such transactions themselves constitute transactions in securities for the purposes of the Policy and are subject to all of the provisions applicable to other non-exempted transactions. Approval is only given when the allocation comes through copy transactions earnings trader employee of the issuer, who has a direct family relation to copy transactions earnings trader BNY Mellon employee.

Approval may not be available to employees of registered broker-dealers due to certain laws and regulations for example, FINRA rules in the U. If you have any questions as to whether a particular offering constitutes an IPO, consult the Ethics Office before submitting an indication of interest to purchase the security.

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Subsequent Actions Should you participate in any subsequent consideration of credit for the issuer, or of an investment in the issuer, for an advised account you copy transactions earnings trader required to disclose your investment to your Compliance Officer.

The decision to transact in such securities for an advised account will be subject to independent review. The IEC will take into account the specific facts and circumstances of the request prior to reaching a decision on whether to authorize a private placement investment. These factors include, among other things, whether the opportunity is being offered to an individual by virtue of their position with the company or its affiliates, or their relationship to a managed fund or account and whether or not the investment opportunity being offered to the employee could be re-allocated to a client.

Approval to Continue to Hold Existing Investments Within 90 days of being designated an ADM, employees holding private placement securities must request and receive written authorization from the IEC to continue to hold these securities. Managers should inform consultants, independent contractors, and temporary copy transactions earnings trader of the provisions of the Policy and, unless otherwise determined by the Manager of the Ethics Office, require the consultant, contractor or temporary employee to contractually agree to comply with this Policy.

Employees will be designated into one or more of the following classifications:.