Global Conflicts of Interest Policy
Key Points• Conflicts of Interest can occur when the interests of a Barings entity or entities and Barings associates(“Associates”) interfere with, or have the potential to interfere with Barings' fiduciary obligations to its
clients (“Clients”).
• Each Barings entity is responsible for developing a process for identifying Conflicts of Interest andensuring that policies and procedures exist designed to sufficiently manage any potential Conflicts ofInterest.
• Each Barings entity is responsible for ensuring that appropriate disclosure of any potential Conflicts ofInterest is made to prospects and Clients.

Introduction/Policy Statement

When the interests of a Barings entity or entities and Barings Associates interfere with, or have the potential tointerfere with Barings' fiduciary obligations to its investment Clients a Conflict of Interest can occur.
Each Barings entity manages Client accounts in a manner that is consistent with the Client’s best interests andattempts to avoid and/or manage situations where there can be potential Conflicts of Interest. The purpose ofthis Global Conflicts of Interest Policy (“Policy”) is to establish a framework for:••••Identifying circumstances and relationships that are or could potentially be deemed a Conflict of Interest
between a Barings entity, its Clients, and or its Associates;
Assessing the impact of such potential Conflicts of Interest on Clients;
Ensuring policies and associated procedures are established by each Barings entity designed toaddress and sufficiently manage any potential Conflicts of Interest in a manner that is fair and equitable
to Clients and does not disadvantage a Client relative to a Barings entity; andMaking the appropriate disclosure of those potential Conflicts of Interest to Clients as required byrelevant local rules and regulations.

Types of Conflicts of Interest

The following list includes, but is not limited to, the types of potential Conflicts of Interest that may arise between
a Barings entity and/or its Associates and Clients:
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A Barings entity and/or its Associates are engaged in a business of selling products or services otherthan giving investment advice to Clients.
A Barings entity is the general partner or managing member of limited partnerships or limited liabilitycompanies and a Barings entity recommends to its Clients the purchase of interests in such entities.
A Barings entity engages in principal, brokerage or lending transactions with its Clients.
A Barings entity engages in cross transactions between its Clients.
A Barings entity recommends to its Clients the purchase or sale of securities or products in which a
Barings entity has a financial or ownership interest.
A Barings entity buys or sells securities for its own account that it is also recommending to Clients.
A Barings entity engages affiliated persons to solicit advisory Clients on its behalf.

RequirementsIdentifying and Assessing Conflicts of Interest

Individually, Associates of a Barings entity are required through various policies and procedures including but
not limited to, the Global Associates Ethics and Conduct Guide, and Global Code of Ethics policy, to escalate to
the relevant Barings' Compliance Department (“Compliance Department”) potential Conflicts of Interest related
to their own personal activities or business activities within the normal course of business. Should an Associate
Global Conflicts of Interest Policy-1External recipients should note that, given the proprietary nature of this document, Barings asks that it is not distributed to any other parties without our prior written consent andpresume said document was provided for the external recipient’s internal review and consideration only. These policies and procedures may be subject to change and/or
modified in whole or in part without prior notice. Policies and procedures are presumed to be general operating documents and as such, exceptions may be granted by therelevant Barings Chief Compliance Officer or designee.

identify an actual or potential Conflict of Interest, they should immediately either disclose such conflict using
PTA (an internal software system utilized by Barings) or contact the relevant Barings Compliance Department.
Each Barings entity has adopted a corporate governance structure (i.e. governance and oversight committees, aboard of directors or other similar body) which assist in the oversight of its investment management andbusiness activities. Under this corporate governance structure, each Barings entity may identify potential
Conflicts of Interest and is responsible for the ongoing management and/or resolution of any Conflicts of Interestfor those activities.
Each relevant Compliance Department will also review the relevant entity’s business activities at least annually
to reassess the current business environment and any related potential Conflicts of Interest and ensure that all
potential Conflicts of Interest have been identified and addressed in a fair and equitable manner. As part of thisreview, the Chief Compliance Officer (“CCO”) or designee for each Barings entity will also assess new businessarrangements proposed by said Barings to determine whether potential Conflicts of Interest exist that may
require modifications to existing policies or procedures. The review conducted by the relevant ComplianceDepartment of Conflicts of Interest can take different forms, and may include but not be limited to analyzing
governance and oversight committee reporting, conducting assessments or audits, and testing.
When reviewing and determining whether potential Conflicts of Interest exist, the following examples are some
types of questions that may be taken into consideration:
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Would the arrangement or initiative put Barings and/or its Associates in a position where they could
benefit to the detriment of any Client?
Would the arrangement or initiative cause Barings and/or its Associates to have an incentive to favor
one Client over another Client?
Would the arrangement or initiative create the appearance of a potential Conflict of Interest between
Barings and/or its Associates and any Client?
Would the arrangement or initiative involve business dealings with any Client other than the provision ofinvestment advisory 1 services (e.g., brokerage, custody, etc.)?
Would the arrangement or initiative involve an activity (or related activity) that has become the subject ofenhanced regulatory scrutiny or litigation?
Would the arrangement or initiative allow Associates to profit or otherwise benefit personally outside of
the compensation arrangements provided by Barings (e.g., an Associate may hold interests in private
funds managed by Barings)?
Would such arrangement or initiative involve Client participation or otherwise affect any Clients?

Addressing Conflicts of Interest
Upon being made aware of a potential Conflict of Interest, the relevant CCO or designee will determine whether
the relevant Barings entity has reasonable controls in place to address the potential Conflict of Interest in amanner that is fair and equitable to all of its Clients.
If it is determined that the relevant Barings entity does not have reasonable controls in place to address suchpotential Conflict of Interest, consideration will be given to supplementing policies and procedures and/or
existing controls designed to address potential Conflict of Interests in a manner that is fair and equitable forClients.

Documentation
Each Barings entity will document known potential Conflicts of Interests (e.g. conflict register or conflicts matrix)
and the steps taken to manage any identified conflicts appropriately. This documentation is reviewed andupdated on a regular basis as appropriate as noted above.

1 Advisory services means discretionary investment management.

Global Conflicts of Interest Policy-2External recipients should note that, given the proprietary nature of this document, Barings asks that it is not distributed to any other parties without our prior written consent andpresume said document was provided for the external recipient’s internal review and consideration only. These policies and procedures may be subject to change and/or
modified in whole or in part without prior notice. Policies and procedures are presumed to be general operating documents and as such, exceptions may be granted by therelevant Barings Chief Compliance Officer or designee.

Disclosing Conflicts of Interest
The relevant Barings’ CCO or designee will ensure that any potential Conflicts of Interest that have been
identified are appropriately disclosed as may be required to Clients in accordance with applicable policies andprocedures and regulatory requirements.

Conflict Resolution and Escalation Process

Associates should immediately report any issues they believe are a potential or actual breach of this Policy totheir relevant business unit management and to the relevant CCO or designee. The relevant CCO or designee
will review the matter and determine whether the issue is an actual breach and whether to grant an exception,
and/or the appropriate course of action. When making such determination, the relevant CCO may, as part ofhis/her review, discuss the matter with relevant business unit management, members of leadership team,governance and oversight committees, other Barings entities or other parties (i.e. legal counsel, auditor, etc).
The relevant Compliance Department can grant exceptions to any provision of this Policy so long as suchexceptions are consistent with the purpose of the Policy and applicable law, are documented and such
documentation is retained for the required retention period. Any questions regarding the applicability of thisPolicy should be directed to the appropriate Compliance Department or relevant CCO or designee.

Books and Records Retained

The table below identifies each Record that is required to be retained as it relates to this Policy unless adifferent retention period is required by local regulations in the relevant jurisdiction. Records may be unique tothe relevant jurisdiction or combined with records maintained by Barings LLC. In order for Barings to retain eachof the following records, all business should be conducted by Barings Associates on a Barings approved
corporate device and/or by using an approved and supported Barings platform (e.g. mail system, social media
account, recording technology, storage medium, trading platform, Barings supported application, etc.):
Description/Requirement

Barings Record

CreatorOwner

The ComplianceDepartment will review
Barings' businessactivities at least
annually

Annual Assessment Compliance
Report or otherDepartmentdocuments toevidence the review

ComplianceDepartment

7 Years

Barings Policy
requirement

Address or sufficiently
manage known or
potential Conflicts ofInterest

Documentation ofknown conflicts ofInterest (e.g.
Conflicts of Interest
log, matrix orregister for each
Barings entity)

ComplianceDepartment

7 Years

Barings Policy
requirement

ComplianceDepartment

Retention
PeriodSource

Original Date of Policy: October 2004 (Barings LLC)
Last Review Date: June 2023
Last Revision Date: May 2022

Global Conflicts of Interest Policy-3External recipients should note that, given the proprietary nature of this document, Barings asks that it is not distributed to any other parties without our prior written consent andpresume said document was provided for the external recipient’s internal review and consideration only. These policies and procedures may be subject to change and/or
modified in whole or in part without prior notice. Policies and procedures are presumed to be general operating documents and as such, exceptions may be granted by therelevant Barings Chief Compliance Officer or designee.