EXHIBIT 99p20

Ninety One NA. Code of Ethics

U.S. Compliance | Business Confidential| For internal use only

This U.S. Code of Ethics is confidential you may not distribute this U.S. Code of Ethics or any portion of it to anyone not employed by Ninety One North America, Inc. or its advisory affiliates without express permission of the Chief Compliance Officer.

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Ninety One NA. Code of Ethics

This Ninety One North America, Inc. (“Ninety One NA”) U.S. Code of Ethics (the “Code of Ethics”) sets forth the standards for business conduct and guidelines for personal investing and business activities that are required by Rule 204A-1 for Registered Investment Advisers registered under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The Code of Ethics is also intended to comply with Rule 17j-1 under the Investment Company Act of 1940, as amended (the “1940 Act,” and together with the Advisers Act, the “Rules”) which applies to Ninety One NA because we serve as an investment adviser to registered investment companies (each, a “Registered Fund”). Rule 17j-1 specifically requires us to adopt a Code of Ethics that contains provisions reasonably necessary to prevent an Access Person from engaging in fraudulent conduct and any unlawful actions, including insider trading. This Code of Ethics applies in addition to the Policy and Procedures Manual (the “Compliance Manual”) for Ninety One NA. Together, the Code of Ethics and the Compliance Manual underscore Ninety One NA’s commitment that in all our dealings, we will act with fairness, decency and integrity, and adhere to the highest standards of ethics. The success of this commitment depends on the conduct of each Ninety One NA employee.

In order to comply with the requirements set forth in the Rule 204A-1 of the Advisers Act, Ninety One NA has adopted this Code of Ethics which:

All capitalized terms not otherwise defined herein have the meanings ascribed to them in the Glossary.

Ninety One NA must comply with the requirements set forth under the Advisers Act, the rules thereunder, and relevant provisions of other U.S. laws, if applicable, such as regulations pursuant to Employee Retirement Income Security Act of 1974 (“ERISA”), the 1940 Act, Commodity Futures Trading Commission (“CFTC”) and the Financial Industry Regulatory Authority, Inc. (“FINRA”) and, if relied upon, Securities Exchange Commission (“SEC”) guidance, including exemptive, no-action and interpretive positions. The Code of Ethics states the applicable U.S. requirements. All of Ninety One NA’s officers, directors, partners and employees (or other persons occupying a similar status or performing a similar function) (each, a

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“Supervised Person”) are expected to read, understand and comply fully with all requirements herein. The personal account reporting or pre-clearance mandates applies to Access Persons. On an annual basis, Supervised Persons are required to acknowledge receipt of the Code of Ethics and represent in writing that they have read and understood it. Ninety One NA also considers consultants, temporary employees, interns and individuals who occupy similar roles as Supervised Persons who are subject to this Code of Ethics.

In particular, Ninety One NA expects all Supervised Persons to act with fairness, integrity and adhere to the highest standards of ethics, avoiding any activity, interest, or external association that could impair or give the appearance of impairing the Supervised Persons ability to perform their work objectively. Ninety One NA expects all Supervised Persons to exercise sound judgment in the performance of their duties.

Ninety One NA’s reputation for integrity is its most important asset. Ninety One NA, therefore, must enforce the standards outlined in the Code of Ethics vigorously. Every Supervised Person has a responsibility for knowing and following these policies and procedures. Each Supervised Person in a supervisory role (each, a “Supervisor”) is also responsible for those individuals under his/her supervision. Supervisors are responsible for instituting reasonable measures to ensure that employees understand them, are kept up-to-date of any changes, and comply with them. The Chief Compliance Officer (“CCO”) has the responsibility for creating and disseminating Ninety One NA’s compliance policies and procedures to the various business units and teams, as well as ensuring efficiency and enforcement of these policies and procedures through adequate monitoring and testing.

Please note that this Code of Ethics does not address Ninety One UK’s compliance with any Financial Conduct Authority (“FCA”) rules, regulations or policies as a separate manual exists for such purposes. In addition, there are a number of global policies that are applicable to Ninety One NA and its Supervised Persons, who are expected to read and comply with such policies. In case of discrepancies between local and global laws, generally, the more restrictive law should get precedence. Supervised Persons should bring any possible regulatory conflict promptly to the CCO’s attention.

When in doubt, ask before you act. The Code of Ethics cannot cover every possible situation that may arise in the course of conducting business in the United States or managing the assets of clients. You may be unsure about application of the policies and procedures in a particular situation. Do not try to resolve difficult questions yourself. Instead, please contact the CCO or the CCO’s designee. In addition, all Supervised Person are told to contact the CCO if there is any reason to believe that a violation of the requirements set forth in the Code of Ethics has occurred or is about to occur. Our integrity is of the utmost importance and critical to our long-term success.

Technical compliance with the requirements set forth in the Code of Ethics will not insulate anyone from scrutiny for any actions that create the appearance of a violation. Supervised Persons are expected to also

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abide by the spirit of the requirements set forth in the Code of Ethics. Ninety One NA may impose penalties for breaches of the Code of Ethics. Depending on the nature of the breach, penalties may include a breach memo to the Supervised Person’s file, a formal letter of censure, disgorgement of profits, civil or criminal fines and penalties, referrals to regulatory or self-regulatory bodies, including and up to termination of employment.

The Advisers Act requires the registration of certain investment advisers and imposes detailed requirements on the activities of registered investment advisers.

Fiduciary Duty

Under the laws and regulations governing advisers, the SEC has consistently taken the view that an adviser owes a “fiduciary duty’’ to its clients. It is the policy of Ninety One NA to act in a manner consistent with this position. Consistent with this obligation to act in the best interest of its clients, the interests of Ninety One NA clients take priority over the investment or business interests of Ninety One NA, its affiliates and its personnel. An investment fiduciary duty encompasses both the duty of care and the duty of loyalty as described below.

Duty of care includes without limitation, at least three duties:

Duty of loyalty: An adviser must not place its own interests ahead of its client’s interests. To meet its duty of loyalty, the adviser must either eliminate or provide full and fair disclosure of all conflicts of interest which might incline an investment adviser—consciously or unconsciously—to render advice which is not disinterested. Such that a client can provide informed consent to the conflict.

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The Adviser is also subject to antifraud provisions. The Rules prohibits misstatements or misleading omissions of material facts and other fraudulent acts and practices in connection with the conduct of an investment advisory business.

Section 206 of the Advisers Act makes it unlawful for advisers to, directly or indirectly:

Among the many types of activities that have been found to violate Section 206 of the Advisers Act (this is not an exhaustive list) are:

Supervised Persons must conduct themselves in a manner consistent with the principles, requirements and procedures set forth in this Code of Ethics. Supervised Persons must never improperly use their position with Ninety One NA for personal or private gain to themselves, their family or any other person. Supervised

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Persons are reminded that Federal Securities Laws have antifraud provisions, most notably, Section 10(b) of the Exchange Act and Rule 10b-5 thereunder.

Ninety One NA and its Supervised Persons owe a fiduciary duty to its clients. As noted earlier, a fiduciary must avoid activities, interests and relationships that interfere or appear to interfere with its ability to make decisions in the best interests of its clients.

Supervised Persons are required to satisfy the fiduciary duty placed on advisers including, but not limited to, the following standards of contact:

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Supervised Persons must maintain the confidentiality of sensitive information entrusted to them by Ninety One NA or its affiliates or their respective clients and must not disclose such information to any persons except when disclosure is authorized by Ninety One NA or mandated by law other than to (1) other of Ninety One NA’s or its affiliates’ Supervised Persons who have an “need to know” in connection with their duties, or (2) persons outside Ninety One NA (such as attorneys, accountants or other advisers) who need to know in connection with a specific mandate or engagement from Ninety One NA or its affiliates or who otherwise have a valid business or legal reason for receiving it and have executed appropriate confidentiality agreements. Confidential information includes all non-public information that is not known to the general public. It also includes our intellectual property (such as confidential product information, trade secrets, patents, trademarks and copyrights), business, marketing and service plans and processes, databases, records, salary information, unpublished financial data and reports as well as information that joint venture partners, suppliers or customers have entrusted to Ninety One NA.

The obligation to preserve Confidential Information continues even after a Supervised Person’s employment with Ninety One NA ends.

Types of Confidential Information

“Proprietary Information” is information that is internal to Ninety One NA about its internal workings, its asset management operations, its internal operations and its financial information. This includes information not known to the public that may have intrinsic value or that may provide Ninety One NA with a competitive advantage. Proprietary Information includes information that is obtained, developed or utilized during the ordinary course of employment, whether by the Supervised Person or someone else, such as professional service providers (e.g., lawyers, accountants, consultants or auditors).

Examples of Proprietary Information include intellectual property and proprietary processes, materials supplied to vendors or third-party suppliers that are not available to the public, minutes of meetings and conference calls. It also includes all non-public information that might be of use to competitors, or harmful to Ninety One NA or its affiliates or their respective customers, if disclosed. It also includes Ninety One NA’s intellectual property (such as confidential product information, trade secrets, patents, trademarks and copyrights), business, marketing and service plans, databases, records, salary information, unpublished financial data and reports as well as information that joint venture partners, suppliers or customers have entrusted to us Proprietary Information may be present in various media and forms, including written documents, computer files, diskettes, videotapes, audiotapes and oral communications.

“Confidential Client Information” includes the names of clients, contract details, client positions, orders

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being worked for client and advice or recommendations prepared for used for clients. This also includes non-public information regarding potential clients.

“Other Confidential Information” is any other information not known to the public that is not classified as client, inside or proprietary information.

The term Confidential Information is used herein to refer to all three types of above information.

Please note that Ninety One NA has special requirements to handle Inside Information (as defined below). Generally, Inside Information is material, non-public information, as defined in relevant U.S. court cases under and for the Federal Securities Laws and the rules and regulations thereunder.

Handling Confidential Information

Supervised Persons must maintain the confidentiality of sensitive non-public and other confidential information entrusted in them by Ninety One NA or its affiliates or their respective clients and must not disclose such information to any persons except when disclosure is authorized by Ninety One NA or mandated by law other than to (1) those Supervised Persons who have an “need to know” in connection with their duties, or (2) persons outside Ninety One NA (such as attorneys, accountants or other advisers) who need to know in connection with a specific mandate or engagement from Ninety One NA or its affiliates or who otherwise have a valid business or legal reason for receiving it and have executed appropriate confidentiality agreements.

Special precautions must be taken when handling Confidential Information. Supervised Persons should adhere to the following guidelines in situations involving Confidential Information (other than Inside information for which there are special rules more fully described below):

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Post-Employment Use of Confidential Information

Supervised Persons must not misuse, disclose, provide or take Confidential Information when seeking employment or after termination. Ninety One NA reserves the right to review all materials that an Supervised Person plans to take with him or her when leaving and to impose conditions as are proper and reasonable to protect such information. Ninety One NA will seek appropriate injunctive or legal relief if warranted.

The CCO may impose disciplinary measures for serious breaches and possible impose disciplinary measures for any breach at the discretion of Ninety One NA.

Please note that this section is supplemented by Ninety One’s Market Conduct Policy.

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The Gramm-Leach-Bliley Act (“GLBA”) requires all financial institutions, defined to include advisers, investment companies and broker-dealers, to establish procedures and systems to ensure privacy of client and financial information. The privacy requirements set forth herein apply only to individual, non-entity clients, including U.S. individuals who invest in the Funds. Ninety One NA does not provide investment advice to individual, non-institutional clients. Compliance will periodically review this policy to determine whether Ninety One NA has any individual, non-entity clients, and will update this policy in accordance with GLBA.

Further, outside business providers, including Ninety One NA’s attorney’s, auditors and administrators, may be given access to NPPI concerning U.S. individual investors necessary to effect, administer, or enforce a transaction authorized by clients or in connection with the provision of services to Ninety One NA and the Funds. It is Ninety One NA’s reasonable belief that such service providers are capable of maintaining and have in place appropriate safeguards to protect client information.

Please note that this section is supplemented by Ninety One’s Secure & Acceptable Usage Policy.

From time to time, Supervised Persons may become recipients of material, nonpublic information (“MNPI”). Ninety One NA is required to establish, maintain and enforce policies and procedures to prevent the misuse of MNPI. These requirements are included in the Insider Trading and Securities Fraud Enforcement Act of 1988. Ninety One NA and its affiliates have established policies and procedures reasonably designed to prevent the misuse of MNPI considering Ninety One NA’s business, structure, size and other relevant factors. In all instances, MNPI shall be protected and preserved in strict compliance with this policy.

Definition and Application of Inside Information and Tipping

Material, nonpublic Information and the terms “insider trading” and “tipping” are not defined in the Federal Securities Laws but were developed through case law under the Exchange Act and Rule 10b-5 thereunder. Other provisions of the Exchange Act and the Advisers Act and the rules thereunder also address the misuse of MNPI; in particular, Section 204A and Rule 204A-1 of the Advisers Act.

The law concerning MNPI, insider trading and tipping is dynamic, and the SEC enforces cases on a regular basis. U.S. authorities do not hesitate to sue persons outside the United States and are often able to detect and take action within hours.

Broadly, the law prohibits any misuse of MNPI, including:

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At Ninety One NA concerns about the misuse of Inside Information may arise primarily in two ways. First, a Supervised Person may come into possession of MNPI about another company, such as an issuer in which he or she (or his or her personnel) will invest either for clients or his or her own account. If a Supervised Person has or believes to have such MNPI, he or she must notify the CCO immediately and must not act on that that information.

Second, Ninety One NA as an adviser might acquire or have MNPI in relation to its own business activities. In this context, the SEC has stated that the term “MNPI” may include information about an adviser’s recommendations and client securities holding and transactions – this clearly is confidential client information. It is our policy that all such Confidential Client Information is to be kept in strict confidence by those who receive it and may be divulged only within Ninety One NA on a need to know basis in connection with the performance of services to Ninety One NA’s clients.

Who is an Insider?

The concept of “insider” is broad. It includes officers, directors and employees of a company. Ninety One NA may be deemed an insider when it comes into possession of Inside Information through its various business activities or through a Supervised Person who has been tipped off outside Ninety One NA’s activities. Ninety One NA will remain an insider as long as it has Inside Information. A person can be a “temporary insider” if he or she enters into a confidential relationship in the conduct of Ninety One NA’s affairs and, as a result, is given access to information solely for Ninety One NA’s purposes. A temporary insider can include, among others, a company’s attorneys, accountants, consultants, bank lending officers, and the employees of such organizations. In addition, a person who advises or otherwise performs services for a company may become a temporary insider of that company. An employee, for example, could become a temporary insider to a company because of such employee’s relationship to the company (e.g., by having contact with company executives while researching the company). Such company must expect Ninety One NA as the adviser to keep the disclosed MNPI confidential, and the relationship must at least imply such a duty before Ninety One NA will be considered an insider or temporary insider.

It may also be the case that a connected person of an access person may have MNPI and be deemed to be an insider. Supervised Persons are cautioned in such situations in order to avoid liability for tipping or misappropriating MNPI and must notify the CCO immediately if they believe to have been tipped off with MNPI.

What is “Material” Information?

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“Material” information is generally defined as information for which there is a substantial likelihood that a reasonable investor would consider it important in making his or her investment decisions, or information that is reasonably certain to have a substantial effect on the price of a security. The information is deemed to “alter the total mix of information available.” Such information includes, but is not limited to:

Material information does not have to relate to company’s business. For example, certain information about the contents of a forthcoming newspaper column that was expected to affect the market price of a security has been considered material by U.S. courts. More specifically, a Wall Street Journal reporter was found criminally liable for disclosing to others the dates that reports on various companies would appear in the WSJ and whether those reports would be favorable or not.

What is “Non-Public” Information?

Information is non-public until it has been effectively communicated to the marketplace. One must be able to point to a fact to show that the information is generally public and not “just released within a few moments.” For example, information in a report filed with the SEC, or appearing in Dow Jones, Reuters, The Wall Street Journal or other publications of general circulation would be considered public.

What is Tipping?

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

Penalties and Consequences of Misusing MNPI

The improper use or unauthorized disclosure of MNPI by any employee, including trading while in possession of the MNPI, can inflict great damage on Ninety One NA, its clients, affiliates and employees. At a minimum, the misuse of MNPI can create a negative impression in the eyes of clients, regulators, the public and the business community. Penalties for trading on or communicating MNPI are severe. For both individuals involved in such unlawful conduct and their employers the penalties may include fines or damages up to three times the amount of any profit gained or loss avoided. A person may be subject to some or all of the applicable penalties even if he or she does not personally benefit from the violation. Penalties include civil injunctions, treble damages, disgorgements of profits, jail sentences or fines for the

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person who committed the violation of up to three times the profit gained or loss avoided, whether or not the person actually benefited. Fines for the employer and other controlling persons can total up to the greater of $1,000,000 or three times the amount of the profit gained or loss avoided. Any violation of this policy can be expected to result on serious sanctions by Ninety One NA, including dismissal of the person(s) involved.

It is the duty of every Supervised Person to remain constantly alert to possible violations of this policy regarding the use of dissemination of Inside Information. All employees who suspect such improper use by any other person must immediately communicate the relevant facts to the General Counsel or the CCO.

Guidelines on the Treatment of MNPI

Learning of MNPI: It is not illegal to learn MNPI. It is, however, illegal to trade on such MNPI or to pass it on to others who have no legitimate business reason for receiving such MNPI.

Steps to Follow When You Think You Have MNPI: If, after consideration of the above, a Supervised Person believes that they have learned MNPI, or if a Supervised Person has questions as to whether the information is MNPI, you should contact only Compliance immediately. Supervised Persons are prohibited from trading on or disclosing the potential MNPI the Supervised Person has learned without consulting Compliance.

Investigation of Trading Activities: From time to time, various stock exchanges, FINRA and the SEC may request information from Ninety One NA concerning trading in the specific securities that may coincide with market news. Requests from a stock exchange or regulator for this type of information should be referred directly to the CCO. The Supervised Person may be asked to sign a sworn affidavit stating that at the time of the trading, the employee did not have any MNPI about the securities in question. Ninety One NA may submit these affidavits to the applicable stock exchanges, FINRA or SEC.

Procedures to Detect and Prevent Insider Trading

The role of Compliance is critical to the implementation and maintenance of Ninety One NA’s procedures against insider trading. Supervisory procedures can be divided into two classifications, prevention of the insider trading and detection of insider trading.

Detection of Insider Trading

To detect insider trading, the compliance department will (i) periodically review the personal trading activity of Access Persons and (ii) review trading activity of Ninety One NA’s accounts.

Prevention of Insider Trading

To prevent insider trading, Compliance will:

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Ninety One NA’s insider trading procedures.

The Use of Expert Networks

The use of Expert Networks may result in an employee obtaining MNPI. We have instituted Expert Network procedures to prevent the actual, or appearance of, misuse of MNPI. These procedures apply to all employees who utilize Expert Networks. The Expert Network procedures include conducting due diligence on the proposed Expert Network, Compliance calendaring of calls, employee training and guidelines on how an employee must conduct themselves on an Expert Network call.

Please note that this section is supplemented by Ninety One’s Market Conduct Policy.

Conflicts of interest may exist between Ninety One NA or Supervised Persons, on the one hand, and its clients, on the other. Conflicts of interests may also exist between clients.

Every adviser must identify its material conflicts, the effect(s) that they have on the adviser, Supervised Persons and its clients and the means to mitigate or resolve them. This means keeping and maintaining a conflicts policy, developing procedures for when conflicts of interest arise, and disclosing such conflicts of interest and the means to address them.

The disclosure in Form ADV Part 2 of such material conflicts and the means to address them must be sufficiently clear and concrete so that a reasonable prospect or client understands clearly the conflict and how it is addressed. There have been severe penalties resulting from SEC enforcement actions for deficient disclosure or failure to act in accordance with disclosures. Advisers may also be sued if their disclosures are

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materially incorrect, in particular, if there is a material omission, such as an undisclosed conflict of interest.¹

Examples of conflicts of interest and means to address them include the following (although we note that this is not an exhaustive list of conflicts of interest, in general, or the conflicts facing Ninety One NA or Supervised Persons, more specifically):

Supervised Persons are responsible for and have a duty to identify and escalate to line management and Compliance any potential or actual conflicts of interest of which they become aware.

Please note that this section is supplemented by Ninety One’s Conflicts of Interest Policy.

A Supervised Person may not maintain a Material Outside Business Affiliations without the prior written approval of Compliance and, where appropriate, such Supervised Person’s Supervisor and/or the CEO. Each Supervised Person must also submit an annual declaration of his or her Material Outside Interests.

Policies and procedures designed for Supervised Persons to declare any material outside interests are set forth in the Compliance Manual.

Please note that this section is supplemented by Ninety One’s Outside Business Activity Policy.

¹ See e.g. SEC v. Gabelli, 2011 WL 3250556 (2d Cir. Aug. 1, 2011).

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Supervised Persons’ personal securities transactions must be conducted in such a manner to avoid any actual, potential or perceived conflicts of interest or any abuse of an individual’s position of trust and responsibility. Therefore, Supervised Persons or persons designated as Access Persons must comply with the personal trading guidelines set forth in the Code of Ethics. These guidelines are supplemented by Ninety One’s Personal Account Dealing policy (the “PAD Policy”).

As a general matter, it is a violation of Federal Securities Laws and the policies of Ninety One NA for any of its Supervised Persons to engage in any act, practice or course of business in connection with the purchase and sale of any Securities for a Supervised Person Account which violates any of the Federal Securities Laws designated to prevent fraudulent, deceptive, or manipulative acts. Two common examples of such prohibited activities are described below. However, any fraudulent practice in connection with the purchase or sale of Securities for an Access Person Account is prohibited by the Federal Securities Laws and the Compliance Manual.

Front-Running: The practice of trading on the basis of the anticipated market effect of trades for Client Accounts, which is known as “front-running” or “scalping,” is a violation of the Federal Securities Laws. Examples of front-running or scalping include:

Trading Client Accounts to Benefit Access Persons: The practice of trading a Client Account for the purpose of benefiting an Access Person’s Account is prohibited by the Federal Securities Laws.

If you are designated as an “Access Person” you are subject to both the Code of Ethics’ Personal Securities Transactions procedures below and the PAD Policy.

Access Persons are under the duty to provide the reports described below unless specifically exempted by

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the CCO.

All securities are “Reportable Securities”. There are exceptions to reporting requirements, or “Non-Reportable Securities” and these are detailed in the PAD Policy.

All Access Persons are required to submit holdings in Reportable Securities in which the Access Person has any direct or indirect Beneficial Ownership Interest as follows:

Initial Holdings Reports and Annual Holdings Reports must contain, at a minimum, the following information:

Initial Holding Reports and Annual Holding Reports are submitted through StarCompliance unless your broker is not supported by Star Compliance, in which case Access Persons need to arrange and provide duplicate account statements. For a list of brokers supported by StarCompliance please consult the CCO.

Within 30 days after the end of each calendar quarter, each Access Person must submit a quarterly transaction report of all Reportable Securities transactions (a “Quarterly Transaction Report”) to the CCO or

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designee that contains, at the minimum, the following information (if applicable) regarding each transaction in a Reportable Security in which the Access Person has a Beneficial Ownership Interest:

If you have questions about the Beneficial Ownership Interest in a security, please contact Compliance. Quarterly Transaction Reports are captured through StarCompliance for Access Persons with brokers who are supported by StarCompliance. If the broker is not supported by StarCompliance the Access Person must arrange and provide duplicate statements to Compliance.

An Access Person is not required to submit:

Any Access Person who has a brokerage account, even if such account contains only Non-Reportable Securities, must arrange for copies of duplicate statements of such brokerage account to be sent to Compliance via StarCompliance if it is a broker supported by StarCompliance. If the broker is not supported by StarCompliance the Access Person must arrange and provide duplicate statements to Compliance.

Access Persons must pre-clear all trades in their Access Person Accounts including, without limitation, transaction in Initial Public Offerings and private placements in the manner described in Ninety One’s Personal Account Dealing (PAD) Policy. These pre-clearance requirements do not apply (i) to the receipts of gifts and bequests of securities (i.e., those which are not entirely controlled by the owner of the Access Person Account) or (ii) to Non-reportable Securities.

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Access Persons must obtain approval prior to investing in an initial public offering (“IPO”) or private placement.

In addition to the 15-Day Restrictive Rule, several other restrictions apply:

A blackout period applies to Access Persons’ Accounts related to certain trades (the “15-Day Restrictive Rule”), in which Supervised Persons are restricted from trading a security within 15 days, on either side, of a client trade involving the same security.

Access Person Accounts are not allowed to profit from the purchase and sale of the same security or to have a “round trip” purchase and sale of the same security within six months (each, a “Short Term Trade”) without the prior consent of one of the co-Chief Investment Officers. Any profits realized on Short Term Trades may be required to be disgorged. Note that the six-month holding period starts with the most recent purchase of the same security, (e.g., if you purchase 100 shares of Stock A on March 1, then purchase additional 100 shares of Stock A on August 1, you must now hold all 200 shares of Stock A for six months from August 1).

Ninety One NA reserves the right to require an Access Person to liquidate or otherwise close-out a position in an Access Person Account at the Access Person’s expense if it is determined that any of his or her investments violate the provisions of the Code of Ethics. Even though a particular transaction may not be explicitly prohibited by the Code of Ethics, Ninety One NA reserves the right to restrict trading in any financial instrument and/or require an Access Person to liquidate any position held in any Access Person Account (whether at a profit or loss) and disgorge any profit earned.

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Account statements, confirmations, pre-clearance requests and reports required to be submitted pursuant to the Code of Ethics are monitored and reviewed for compliance with this procedure. Any breaches are escalated to the CCO.

Ninety One NA is required by law to keep a record of all violations of this Code of Ethics, including the failure by an Access Person to submit a transaction or holding report required by this of Ethics in a timely fashion. If you become aware of any violations or potential violations of any of the provision of the Code of Ethics you must report such violations or potential violations promptly to the CCO. Failure to report any violations of the Code of Ethics that you are aware of in a prompt manner will be considered itself a violation of the Code of Ethics and subject to remedial action at the discretion of Board. If in doubt about the legality or ethics of any conduct, please contact the CCO to request guidance. If you have witnessed the violation of Federal Securities Laws, you may be eligible to participate in the SEC’s whistleblowing program as outlined in the Compliance Manual.

Please note that this section is supplemented by Ninety One’s Personal Account Dealing (PAD) Policy.

Annually, Ninety One NA Supervised Persons will be required to acknowledge receipt of the Code of Ethics and represent in writing that they have read and understood it and will adhere to it. Understanding and complying with this Code of Ethics and truthfully completing the written acknowledgment are the obligation of all Ninety One NA Supervised Persons.

The Ninety One NA’s CCO and their designee shall have the right to make final and binding interpretations of this Code of Ethics and may grant an exception to certain of the above restrictions, as long as no abuse or potential abuse is involved. Each Supervised Person must obtain written approval from Compliance before taking action regarding such exception.

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If you have any questions about this Code of Ethics or any matter discussed herein, please contact Compliance as follows:

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