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Codes of Ethics

Funds, their advisers, distributors, and subadvisers are required to have a written code of ethics that contains provisions reasonably necessary to prevent fraudulent, deceptive, or manipulative acts and requires reporting of personal securities transactions. A fund’s board must approve the code of ethics, as well as any material change to the code within six months of the change. In addition, the board must review, at least annually, a written report describing any issues that arose since the last report and certifying that processes are in place to prevent future violations. Key reporting requirements of a code of ethics include an annual holdings report, quarterly reporting of transactions, and certifications relating to adherence to the code of ethics.

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