The benefits described on this page are available only to eligible employees, as defined by the plans, of certain Fidelity companies. From time to time, other than the mandatory annual review, the Company MAY publish revisions or supplements to the Company Policies as appropriate, based upon changes in the regulatory environment, changes in the Company’s business and other relevant factors. ö¬Õœ°¼)“³Žq›ÑŠN_’K. Certain rules, which are noted, apply both to

Moving holdings in Fraud may take many forms including theft of money or property, improper sale of Company information or assets, acceptance of illegal kickbacks and unauthorized travel or expense. At Fidelity, we are committed to safeguarding the health and well-being of our associates, clients, and candidates. Any suspected violation of an FIS policy or standard should be reported to either a management representative  or the FIS Chief Compliance Officer (

All employees, as a condition of employment or continued employment, are. During the review process, you may, at your own expense, engage an attorney to represent you. FIS does not tolerate any retaliation against anyone who, in good faith, reports a violation of FIS policy or law or cooperates with an investigation. On your next Quarterly Trade Verification, confirm that the list of disclosed securities accounts in the appropriate section of the report is accurate and complete. The Company will normally be the exclusive owner of all rights in intellectual property that is related to our businesses or is developed by employees and contractors in the course of their employment or service with the Company. Conflicts of Interest Requirement. This Code is designed to encourage the prompt internal reporting of violations of the Code, including applicable laws, rules and regulations, and to provide a method to report conduct that is suspected may be in violation of the Code. 01.01 Code of Business Conduct and Ethics, 01.01.01 A Message from Gary Norcross, FIS Chief Executive Officer, A Message from Gary Norcross, FIS Chief Executive Officer. You MAY also consult the Corporate Secretary to determine whether you or one of your employees possess inside information. transactions made during the preceding 60 days. When you place a call to the Helpline, the call center specialist SHALL capture your question or report and ask you to provide detailed information. If a gift is given by an FIS employee to another FIS employee and is purchased with personal funds, this purchase is not required to be entered in the Gifts and Entertainment Registry. Our recruiting team is committed to providing the support you need throughout the hiring and onboarding process. Contact the Ethics Office immediately to discuss any situation where these rules would work to the disadvantage of the funds. certain employees of Enterprise Compliance; employees of Pyramis Global Advisors in support functions not directly related to fund management; and employees, including temporary employees, with access to timely fund information (including access to Career. Please seek guidance from the Corporate Compliance team via if the situation in question is not addressed below. We are actively monitoring the situation related to COVID-19 and are continuing to hire in order to serve our clients around the globe. maintaining reasonable supervision over that person’s activities related to pre-clearance. For more information outlining the steps we have taken and our ongoing planned efforts to prevent modern slavery in our organization and supply chain, please review FIS’ Modern Slavery Act Transparency Statement posted on our external website within the Investors / Corporate Governance – Highlights webpage. The Company’s intellectual property includes inventions, improvements, ideas, information, software, models and programs, together with the related materials, documentation, patents, trademarks, copyrights, and other rights that go along with them. Those examples are not exclusive and are not intended to be a full description of all possible legal fines or penalties. The Company has published a Policy Governing Insider Trading and Tipping which is available on FIS and Me. covered securities that you or your covered persons give, donate, or transfer to another party, or that you or your covered persons receive from another party. For example, you may not influence a fund to buy, sell, or refrain from trading a security that would affect that Resolution ─ Ways to Mitigate a Conflict of Interest. With prior written approval from the Ethics Office, you or your covered person may participate if: you or your covered person has been offered shares because you already own equity in the company, you or your covered person has been offered shares because you are a policyholder or depositor of a mutual company that is reorganizing into a stock company, you or your covered person has been offered shares because of employment with the company. The toll-free numbers for each country are provided in Appendix A to this Code, or you may obtain the toll-free numbers from the following web site: To encourage employees both to seek guidance before engaging in behavior that is inconsistent with Company Policy and to report violations, the following principles, All FIS employees, contractors, and applicable third parties are required to adhere to established policies and standards. the details of the plan have been provided to the Ethics Office. Standard trading hours are from 9:30 a.m. to 4:00 p.m. Eastern Standard Time. The first option to mitigate a conflict of interest is to avoid them entirely. This Standard and the FIS’ Conflicts of Interest Registry (the “Registry”) are designed to provide criteria for the review of potential employee conflicts of interest.


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