MSCI CODE OF
ETHICS AND
BUSINESSCONDUCT
MSCIJanuary 2024

© 2024 MSCI Inc. All rights reserved.

MSCI CODE OF ETHICS AND BUSINESS CONDUCT | JANUARY 2024

Code of ethics and business conduct
This Code of Ethics and Business Conduct (the “Code of Ethics”) is a statement of
MSCI’s commitment to integrity and the highest ethical standards in all that we do. It
sets forth the principles and standards of conduct that we expect from all directors,
officers and employees of MSCI Inc. or its subsidiaries ("MSCI").
The Code of Ethics does not address every legal or ethical issue that you may face at
the firm. However, the principles and standards set forth in the Code of Ethics provide
guidance to help us do the right thing and make good decisions when performing ourfunctions. You are expected to act ethically and with sound, reasoned judgment evenin the absence of a specific law, regulation or policy. By following the Code of Ethics
and other MSCI policies and procedures, by adhering to the letter and the spirit of all
applicable laws, regulations and policies, and above all by applying sound judgment toyour activities, you can demonstrate your commitment to our business principles andethics.

Follow both the letter and the spirit of the law
We strive to adhere to the highest standards of ethical conduct and we will notcompromise the legal or regulatory requirements that govern our activities. As a global
business, MSCI is subject to the laws of numerous jurisdictions around the world. It isyour responsibility to understand the laws applicable to your responsibilities and tocomply with both the letter and the spirit of these laws. This requires that you avoid
not only actual misconduct but also the appearance of impropriety. Assume that any
action you take ultimately could be publicized, and consider how you and MSCI would
be perceived in that event. When in doubt, stop and reflect. Ask questions. If you areunclear about the application of the law or MSCI policies to your responsibilities, or if
you are unsure about the legality or integrity of a particular course of action, you mustseek the advice of the Legal and Compliance Department. You will be held personallyresponsible for any improper or illegal acts you commit during your employment at orservice to the firm.

Act in the best interests of clients, the firm and the public
Fair Dealing
MSCI seeks to outperform its competition fairly and honestly through superior
performance. Every director, officer and employee must protect the firm's reputation
by dealing fairly with clients, the public, competitors, suppliers and one another. No
one should take unfair advantage of anyone through manipulation, concealment,
abuse of privileged information or misrepresentation of facts.

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MSCI CODE OF ETHICS AND BUSINESS CONDUCT | JANUARY 2024

Conflicts of Interest
Potential Business Conflicts
Conflicts of interest may arise as a consequence of MSCI’s interests and its
relationships with multiple clients, counterparties, shareholders, competitors andsuppliers around the world. Conflicts, for example, can occur:•when an MSCI client is also an MSCI shareholder;•when an MSCI client is also a supplier or vendor to MSCI;•

when an MSCI competitor in one area is a client of or supplier to MSCI in anotherarea; or•when a client of MSCI is an index constituent or the subject of an ESG research
report.

Officers and employees are responsible for:•identifying and managing conflicts in accordance with legal requirements and
MSCI policies; and•escalating any conflicts or potential conflicts to their manager or other designatedperson, as appropriate.

Managers who identify conflicts of interest in the business or to whom conflicts areraised by employees should manage those conflicts in accordance with MSCI policies
whenever possible. There may be occasions, however, when a conflict is notaddressed by existing firm policies or is potentially significant with respect to not only
the manager's individual business area, but also the firm as a whole. In thosesituations, the conflict should be referred to senior management.

Personal Conflicts
Your day-to-day responsibilities may expose you to situations that potentially raise
personal conflicts of interest. A conflict of interest may arise, for example, if you or afamily or household member has an economic or personal interest that differs from(or that appears to differ from) MSCI’s, a client’s or a shareholder’s.
Avoid any personal investment, activity, interest or relationship outside MSCI that
could impair your judgment or interfere with (or give the appearance of interferingwith) your responsibilities on behalf of the firm or a clientor shareholder. Business
opportunities that arise because of your position with MSCI, or by using the firm's
property or information, belong to MSCI.

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MSCI CODE OF ETHICS AND BUSINESS CONDUCT | JANUARY 2024

While it is not possible to describe every situation in which a potential conflict ofinterest may arise, the following are examples of situations that may raise a personal
conflict of interest:•

Having a personal or family interest in a transaction involving MSCI where you ora family member may derive a personal benefit;•

Accepting a personal favor as a result of your position with MSCI from any personor organization with which the firm has a current or potential business relationship;•

Competing with MSCI for the purchase or sale of property, services or otherinterests;•

Receiving a personal loan or guarantee of an obligation as a result of your position
with MSCI, or granting personal loans or giving gifts to other directors, officers or
employees that could make or might be perceived as making the recipientbeholden to you (over and above repayment of the loan); or•

Working for a competitor, client or supplier while an employee of MSCI.

MSCI’s Code of Conduct provides that officers and employees must promptly disclose
any investment, activity, interest or relationship (including those involving family andhousehold members) that reasonably could be expected to give rise to or create an
appearance of a conflict of interest. Involvement in certain outside activities also may
require the prior approval of the firm.
Directors should disclose any actual or potential conflicts of interest to the Chairmanof the Board and the General Counsel, who will determine the appropriate resolution.
All directors must recuse themselves from any Board discussion or decision affecting
their personal, business or professional interests. Directors and executive officers are
required to comply with our Related Person Transactions Policy, which sets forth
MSCI’s framework for approval of transactions involving the firm's directors andexecutive officers, and certain persons and entities related to them, and MSCI.

Gifts and Entertainment
Gifts and entertainment can foster goodwill in business relationships. However,concerns arise when they compromise, or appear to compromise, the propriety of ourbusiness relationships, such as by creating an inappropriate obligation or expectationon the part of the recipient or provider. The MSCI Code of Conduct and related policies
set forth the limited conditions under which MSCI officers and employees may accept
or give business gifts or entertainment. Gifts and entertainment must be infrequent,unsolicited, reasonable and appropriate under the circumstances, in compliance withapplicable laws and regulations and must not be cash or cash equivalents.

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MSCI CODE OF ETHICS AND BUSINESS CONDUCT | JANUARY 2024

Compliance with Laws
MSCI endeavors to comply with all applicable laws and regulations. This includes
those related to bribery and corruption, antitrust, and money laundering.

Anti-Corruption
MSCI prohibits all forms of bribery and corruption. In particular, you must not:•offer, promise, give or authorize others to offer, promise or give anything of value,either directly or indirectly, to any party in order to gain an unfair or improper
business advantage, such as obtaining or retaining business; or•

receive, or agree to receive, anything of value that results or may result in
improperly influencing your duties as a director, officer or employee.

There are heightened risks when interacting with government officials. The term
“government official” is broadly defined and includes any employee, officer or otherindividual acting in an official capacity for or on behalf of:•any government or government-owned or controlled entity or agency;•

any political party, party official or political candidate; or•any public international or supra-national organization such as the World Bank orsimilar organization with government members.

Additionally, the term "bribe" is broadly defined and includes anything of value, suchas a payment, gift or benefit of any kind, offered or given with the purpose of
influencing a decision or action. MSCI's directors, officers and employees must nevergive or receive bribes (whether directly or through a third party) to or from any
government official or other person or entity doing or seeking to do business with
MSCI. Many government entities also have rules that severely limit or restrict theacceptance of gifts, travel and entertainment by their employees.
The Legal and Compliance Department must pre-approve providing gifts,
entertainment or anything else of value to government officials.
Some countries permit “facilitation payments” to government officials. A facilitation
payment is a small payment, usually in cash, given to expedite or guarantee a routine
process. It is against our policy to make any type of facilitation payment, even if
permitted by local law.

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Antitrust
MSCI succeeds by competing vigorously, but fairly, in the marketplace. MSCI always
complies with all antitrust and competition laws. If you have any questions about
whether an action is allowed under antitrust or competition laws, please contact theLegal and Compliance Department.

Anti-Money Laundering
It is MSCI’s goal to conduct operations in a manner designed to ensure that theemployees, facilities, products, and services of MSCI will be used only for legitimate
purposes. MSCI is committed to complying fully with all applicable statutory andregulatory requirements designed to assist governments in combating money
laundering and identifying criminal or suspicious activity. Every employee is
responsible for complying with MSCI’s anti-money laundering policies and procedures.

MSCI Systems and Assets
Generally, you should only use the firm's systems (e.g., telephones, computers,
networks, email, instant messaging, and remote access capabilities) and property for
MSCI business. Do not access systems that are not reasonably related to yourresponsibilities with the firm and report any suspected misuse or theft of MSCI assets.
Under no circumstances should you use the firm's systems to send or store unlawful,discriminatory, harassing, defamatory or other inappropriate materials.
You are responsible for safeguarding the tangible and intangible assets of the firm andour clients, suppliers and business partners that are under your control, or theemployees and functions you supervise. MSCI, client, supplier, business partner andother assets may be used only for approved purposes and in accordance withapplicable licenses, terms and conditions. Assets include cash, securities, physicalproperty, services, business plans, client and employee information, supplierinformation, intellectual property (code, programs, models and other items) and allother personal, proprietary and confidential information.
Misappropriation, misrepresentation, including fraudulent financial reporting, or
unauthorized disclosure of firm assets is a breach of your duty and may constitutefraud against the firm, even when such acts are committed without personal gain.
Similarly, carelessness, waste or unauthorized use in regard to firm assets is also a
breach of your duty.

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MSCI CODE OF ETHICS AND BUSINESS CONDUCT | JANUARY 2024

Prevent the misuse of confidential information
Confidential Information
Protecting confidential information that MSCI generates or receives in the course of
our business is critical to maintaining MSCI’s reputation for integrity, sustaining our
relationship with clients, ensuring our commercial success and complying withregulations governing the financial services industry. All confidential information,
regardless of its form or format, must be protected from the time of its creation orreceipt until its authorized disposal or disclosure.
Confidential information is information that you create, develop, receive, use, learn or
have access to in the course of your employment with, or service as a director of, MSCI
and that is not generally known to the public. This includes information about MSCI,
its affiliates, its products and services, its employees, its clients, or other persons withwhom we have a relationship and who have an expectation of confidentiality.
You are subject to MSCI’s policies on confidential information, as well as any
agreements between MSCI and third parties relating to confidential information.
Unauthorized access, use or distribution of confidential information violates MSCI
policy and could be illegal. Your obligation to protect the confidential information
continues even after you leave the firm, and you must return all such information inyour possession or control upon your departure.

Inside Information
You may never, under any circumstances, trade, encourage others to trade, or
recommend securities or other financial instruments while in the possession of
inside information related to those securities or instruments.
Inside information is any non-public information about MSCI, its products or services,or its clients or counterparties that may have a significant impact on the price of asecurity or other financial instrument, or that a reasonable investor would be likely toconsider important in making an investment decision. The determination of whether
non-public information is "inside information" in some circumstances may becomplex. Consult with the Legal and Compliance Department if you are uncertain
whether particular information is inside information.
The misuse of inside information will result in disciplinary action by MSCI, up to andincluding termination of your employment or service and may also give rise to civil andcriminal penalties.
In order to prevent the misuse of inside information and to avoid both real andperceived conflicts of interest, MSCI has established policies and procedures known
as Information Walls. The firm also has specific policies and procedures governing© 2024 MSCI Inc. All rights reserved.

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MSCI CODE OF ETHICS AND BUSINESS CONDUCT | JANUARY 2024

personal trading by directors, officers and employees, which may differ depending
upon your position and location at MSCI. You are subject to those policies andprocedures and are required to familiarize yourself with them. If you have any
questions about policies pertaining to your ability to buy or sell securities, you should
contact the Legal and Compliance Department.

Communications Protected by Law
Nothing in this Code of Ethics shall prohibit or restrict you from lawfully:•

Initiating communications directly with, cooperating with, providing relevant
information to or otherwise assisting in an investigation by any governmental or
regulatory body or official regarding a possible violation of any applicable law, ruleor regulation;•

Responding to any inquiry directed to you personally from any such governmental
or regulatory body or official; or•Testifying, participating or otherwise assisting in any regulatory or governmental
action or proceeding relating to a possible violation of a law, rule or regulation.

You do not have to notify MSCI of any such communications described above.

Be honest and fair in your communications
MSCI has a responsibility under the law to provide accurate and complete disclosure
regarding the firm to the investing public, and to the extent that you are involved in the
preparation of materials for dissemination to the public you must ensure that the
information is accurate and complete in all material respects. In particular, MSCI’s
senior financial officers, executive officers and directors must endeavor to promoteaccurate, complete, fair, timely and understandable disclosure in the firm's public
communications, including documents that MSCI files with or submits to the UnitedStates Securities and Exchange Commission and other regulators.
Officers and employees must consult the Legal and Compliance Department forstandards that apply to oral and written communications with the public, as well as
the circumstances under which communications must be reviewed and pre-approved.
If you become aware of a materially inaccurate or misleading statement in a public
communication, you must promptly report it in accordance with the procedures
outlined in the Reporting Misconduct section of this Code of Ethics.

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Maintain accurate books and records
MSCI is required to maintain accurate and complete books and records consistent
with legal requirements and business needs, and to ensure that financial information
included in our books and records is correct and complete in all material respects. You
must be candid and accurate when providing information about our business
transactions and never make false or misleading entries. Senior financial officers must
endeavor to ensure that financial information included in MSCI’s books and records iscorrect and complete in all material respects.

Treat others with dignity and respect
MSCI is committed to a work environment that values diversity and inclusion, andwhere everyone is treated with dignity and respect. Our policies promote equal
employment opportunities without discrimination or harassment on the basis of race,color, religion, creed, age, gender, gender identity or expression, sexual orientation,national origin, citizenship, disability, marital and civil partnership/union status,
pregnancy, legally protected parental or maternity leave, veteran or military status,
genetic information or any other characteristic protected by applicable law. MSCI
expects that all relationships among persons in the workplace will be business-likeand free of bias, harassment and violence.
Misconduct, including discrimination, harassment, retaliation or other forms of
unprofessional behavior will not be tolerated. Such behavior, even if not unlawful, may
subject you to disciplinary action by the firm, up to and including termination of youremployment or service. In addition, conduct that is unlawful may subject you to civil
and criminal penalties.
Officers and employees are required to comply with the Non-Discrimination and AntiHarassment Policy or Dignity at Work Policy applicable in their jurisdiction, including
with respect to any mandatory procedures for reporting discrimination or harassment.

Promote a safe and healthy working environment
MSCI is committed to conducting its business in compliance with all applicable
environmental and workplace health and safety laws and regulations. We strive toprovide a safe and healthy work environment for employees and to avoid adverse
impact and injury to the environment and communities in which we conduct ourbusiness.

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Enforcement and administration of the code of ethics
Reporting misconduct
MSCI’s reputation for integrity depends upon you. You are our first line of defense
against civil or criminal liability and unethical business practices. We each have an
obligation to speak up when faced with conduct or situations that raise legal or ethicalconcerns.
If you believe you may have violated the law or MSCI policies, you must promptly notify
your manager, the Human Resources Department and/or the Legal and ComplianceDepartment, as appropriate. In addition, if you observe or become aware of any illegal,
unethical, or otherwise improper conduct relating to the firm, or conduct that could
have an impact on MSCI’s reputation-whether by an employee, supervisor, client,consultant, supplier or other third party-you must promptly discuss your concerns withyour manager, the Human Resources Department, and/or the Legal and ComplianceDepartment, as appropriate.
If the discussion does not resolve the concern or if you would prefer to report theconcern through other channels, you may call the Integrity Hotline to report concerns
about matters, including accounting issues, that do not involve your employment
relationship with MSCI or discrimination or harassment (for those issues, please referto the applicable Non-Discrimination and Anti-Harassment Policy or Dignity at Work
Policy). Concerns may be reported confidentially and anonymously.
If your concerns relate to the conduct of the Chief Executive Officer, any other senior
executive or financial officer, or a member of the Board of Directors, you also mayreport your concerns to the General Counsel or the Head of Internal Audit. As
appropriate, they will notify the Board of Directors of the allegations. Concerns
involving the General Counsel or the Head of Internal Audit should be reported to theBoard of Directors.
If you are a manager, you have an additional responsibility to take appropriate steps,
in consultation with the Legal and Compliance Department, to stop any misconductthat you are aware of and to prevent its recurrence. Managers who do not takeappropriate action may be held responsible for failure to supervise properly.

Non-retaliation commitment
MSCI prohibits retaliation for reports or complaints regarding the misconduct ofothers that were made in good faith. Open communication of issues and concerns by
all without fear of retribution is vital to our continued success. To further ensure theprotection of whistleblowers, concerns are treated confidentially and may be reported
anonymously, if desired, through MSCI’s Integrity Hotline.

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Consequences of violating the code of ethics
If you are an officer or employee, this Code of Ethics, including any future
amendments, forms part of the terms and conditions of your employment at MSCI.
This Code of Ethics is not a contract guaranteeing your employment for a specificduration or entitling you to any special privileges or benefits.
Directors, officers and employees are expected to cooperate fully in connection withany audit, litigation or investigation conducted by or involving MSCI and to provide
truthful and complete information, including with respect to any allegations ofviolations of the Code of Ethics or other MSCI policies.
Violations of this Code of Ethics may subject you to the full range of disciplinary
sanctions available to the firm. MSCI also may report activities to regulators, which
could give rise to regulatory or criminal investigations. The penalties for regulatory andcriminal violations may include significant fines, permanent bar from employment in
the securities industry and imprisonment.

Waivers and amendments
Any waivers of the provisions of this Code of Ethics for directors or executive officers,
who are designated by the Board, may be granted only in exceptional circumstancesby the Board of Directors and will be promptly disclosed to MSCI’s shareholders.
Amendments to this Code of Ethics also must be approved by the Board of Directors.
It is your responsibility to be familiar with this Code of Ethics as it may be revised fromtime to time.

Questions
Questions regarding this Policy may be directed to the MSCI Legal and ComplianceDepartment.

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Your personal commitment
A truly great, visionary company continuously lives and defends its core values. Only
by doing so can MSCI realize the potential of our constituent parts and the talents ofour people around the world.
To reaffirm their commitment to MSCI's core values, MSCI requires that officers,
employees and directors acknowledge this Code of Ethics and Business Conduct.
Adopted as of January 2024

Acknowledged:

By:________________________________________________________________________ (Name)
Date:____/_____/_______© 2024 MSCI Inc. All rights reserved.

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