January 2024________________________________________________________________

Policy for Managing Conflicts of Interest in Relation toInvestment ResearchIntroduction
This policy applies to investment research published by the global Equity
Research and Fixed Income Research departments of RBC Capital Markets andits member companies including the U.S. Equities Portfolio Advisory Group(“PAG”) division of RBC Wealth Management1 , ("RBC,” “CM,” “RBCCM,” “we” or“us”). In the UK, the policy applies to “Investment Research” and “InvestmentRecommendations relating to Investment Research” as defined by the UK
Financial Conduct Authority.
We reserve the right to amend or supplement this policy at any time. This policy
is a summary of the principal provisions of more detailed internal RBC policies on
research applicable to RBC Capital Markets as a whole and to specific affiliatedbusiness units.
In this policy, we use the terms "Research Analyst" and "Analyst"
interchangeably to describe research analysts who publish research reports. Weuse the term Research Management to describe the senior management teamsof the respective research departments.

1

RBC Wealth Management is a division of RBC Capital Markets, LLC, which is a n indirect wholly-owned subsidiary of theRoyal Bank of Canada and, as such, is a related issuer of Royal Bank of Canada and part of the RBC Financial Group.
The research produced by PAG at RBC Wealth Management is intended primarily for the benefit of ret ail clients.

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1. Identification and disclosure of actual, apparent and potential conflicts

Our policies and internal procedures are designed to assist us in identifying
actual, apparent and potential conflicts of interest, or the appearance of conflictsof interest, that might affect or raise questions about the impartiality of ourresearch.
We provide training for Research Analysts and other RBCCM personnel,including RBC Wealth Management personnel, with whom Analysts interact, on
the identification of potential conflicts. Research Management and Complianceprovide assistance and guidance to RBCCM and RBC Wealth Management
personnel as issues arise.
Compliance monitors the application of RBCCM's and RBC WealthManagement’s policies regarding the publication of research in the period before,
during and after investment banking transactions, as described further in "Timingand content of research". We also have automated systems that facilitate therequired disclosures in research reports of interests and activities of RBCCM
which may appear to represent a conflict of interest (see "Disclosure ofinterests").
The primary Analyst responsible for a research report is required to ensure thatthe views expressed in each research report accurately reflect his or her
personal views (see "Inducements and inappropriate influences - Certification oneach research report").

2. Supervision and remuneration of Research Analysts

Supervision and reporting lines: Analysts who publish research reports aresupervised by, and report to, Research Management. Research Analysts do notreport to, and are not supervised by, any investment banking staff or personnel
from RBC Wealth Management, whose interests or functions may conflict withthose of the Research Analysts. The evaluation and appraisal of Research
Analysts for purposes of career advancement, remuneration and promotion isstructured so that non-research personnel do not exert inappropriate influence
over Analysts.
Remuneration: The remuneration of Research Analysts is determined on thebasis of a number of factors, including various performance factors, seniority,compensation level from the prior year(s) and market factors. Analysts'
remuneration, however, may not be directly linked to specific investment banking
transactions or investment banking groups, but will in part reflect the overallprofitability of RBCCM and/or RBC Wealth Management as a whole, including

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the profitability of Global Investment Banking. We do not permit investmentbanking personnel to participate in RBCCM's or RBC Wealth Management’sevaluations of Research Analysts.

3. Activities of Analysts

We restrict Research Analysts from performing roles which could prejudice, orappear to prejudice, the independence of their research.
Pitches: Research Analysts are not permitted to participate in sales pitches forinvestment banking mandates. Pitch materials may not contain the promise offavourable research coverage.
No promotion of issuers' transactions: Research Analysts may not be involved inpromotional or marketing activities in connection with an investment banking
transaction of an issuer. For this reason, Analysts are not permitted to attend"roadshow" presentations by issuers relating to offerings of securities or any
other investment banking transaction.
In connection with a securities offering or other investment banking transaction
and during the course of such an offering or transaction, our policies permit
Analysts to meet and speak with potential investors, at meetings and inconversations not involving the issuer or investment banking colleagues, forpurposes of investor education and information.
Analysts' personal dealings: RBCCM has personal dealing policies andprocedures in place which are applicable to the Research Department in order toavoid perceived or actual conflicts of interest. Research Employees shall nottrade in any security of any company about which they are in possession ofconfidential, non-public information. Further, in order to eliminate any perceived
conflict of interest, Research Analysts (and their Household Members, as definedin our internal Research policies) shall ordinarily not hold or trade the securities
of any company that they cover or anticipate covering, or any company in thecoverage sector that they cover 2. Research Employees are also required to seek
pre-approval for personal trading. Approval decisions are at the discretion of
Research Management and/or Compliance, as appropriate.
Outside Business Activities and Private Investments: RBCCM has an Outside
Business Activities Policy and a Private Investments Policy, designed to mitigate
any risks or potential conflicts of interest associated with any outside businessactivities or private investments that Research Analysts may undertake. Any

2In exceptional circumstances, RBCCM may approve such a holding which will be disclosed in the Research Analyst’s
research reports.

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outside business activities or private investments must not conflict with an
Analyst’s role at RBCCM and require disclosure or pre-approval, as appropriate.
4. Inducements and inappropriate influences
We prohibit Research Analysts from soliciting or receiving any inducement inrespect of their publication of research. RBCCM’s internal policies andprocedures are designed to ensure that whenever RBCCM pays or accepts any
fee or commission, or provides or receives any inducement, it acts honestly,fairly, professionally, in accordance with the best interests of the Client andappropriately manages any resulting conflicts of interest.
Remuneration and other benefits: Our procedures prohibit Analysts fromaccepting any remuneration or other benefit from an issuer or any other party inrespect of the publication of research and from offering or accepting anyinducement (including the selective disclosure by an issuer of material
information not generally available) for the publication of favourable research.
These restrictions do not preclude the acceptance of reasonable hospitality inaccordance with RBCCM's general policies on gifts and entertainment.
Inappropriate influences and information barriers: We have implemented policies
and procedures, where appropriate, to regulate communications between ourResearch Analysts and investment banking personnel.
We restrict certain communications between Research Analysts and RBC WealthManagement as well as investment banking personnel within RBCCM whichmight be perceived to result in inappropriate influence on Analysts' views.
Equity Research Analysts have office space separate from that of investmentbankers. There are also security restrictions on access to the equity Analysts'
areas by non-Analysts and to investment banking areas by Analysts. In addition:•Investment bankers, salespeople and traders are prohibited fromattempting to influence the timing or content of an Analyst's research
report, and Research Analysts are prohibited from disclosing to any otherbusiness area of RBCCM, including RBC Wealth Management (other thanResearch Management, Compliance or the Law Group), the timing orcontent of a research report prior to its publication (see "Timing andcontent of research").

•Analysts may not be provided with material or confidential non-public
information regarding an issuer or investment, unless the Analyst isbrought "over the wall" in accordance with our procedures. This requires
the prior consent of Research Management and a record to be made byCompliance, and potentially results in restrictions on the Analyst's

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activities until the relevant non-public information has become public orstale. Investment bankers are also prohibited from inappropriatelypressuring an Analyst to initiate coverage of an issuer or security (see"Coverage decisions").
•Conversations between investment bankers and equity Research Analysts
may require pre-approval by Research Management.

Coverage decisions: Decisions to initiate, resume, suspend or discontinue
research coverage of an issuer or investment are made by Research
Management in conjunction with the Research Analyst concerned. Research
Management is permitted to take into account input with respect to researchcoverage from senior management staff of other business areas, including
investment banking and sales and trading.
Certification on each research report: The primary Analyst responsible for a
research report on a specific issuer or issuers of securities is required to certify,
at the time of publication, that the views expressed in the report accurately reflect
his or her personal views about the subject securities, instruments or issuers,
and that no part of his or her compensation was, is or will be directly or indirectly
related to the specific views or recommendations contained therein. Thiscertification can be found on each such research report.

5. Review and comment on research

Our policies are designed to ensure that parties with interests which may
potentially conflict with those of recipients of research are not able to review orcomment on research in a manner which might affect the impartiality of theresearch.
Review of research: Prior to publication, all research reports relating to securities
are reviewed by a Supervisory Analyst, Research Management or theirdesignate. The purpose of these reviews is to confirm compliance with RBCCM'sand RBC Wealth Management’s editorial guidelines and regulatory requirements,
including the requirement that research be clear, fair and not misleading. All suchreports that contain any discussion of a company or other entity in relation towhich we have an investment banking mandate (which would not necessarily belimited to the issuer RBCCM represents in that mandate) may also be reviewed
by Compliance to monitor compliance with any legal or policy restrictions on
timing or content as described in "Timing and content of research".
Our policies do not permit subject companies to review research reports prior topublication. However, subject companies may review factual statements
excerpted from a research report prior to publication where necessary to verif yRBC Capital Markets

the factual accuracy of the report, and provided that all appropriate approvals
have been obtained from Research Management and Compliance and certain
other procedures followed.
Complaints: Any complaints concerning the content of research reports should
be referred to Research Management. Complaints will be handled in accordancewith RBCCM's and RBC Wealth Management’s complaints handling procedures.
6. Timing and content of research

Our policies are designed to ensure that decisions on the timing and content ofresearch are not made, or inappropriately influenced, by persons with interests
conflicting with those of users of research and that new research and othermaterial statements of a Research Analyst's views are not disclosed selectively
before being made generally available.
The timing of publication of a research report is determined primarily by theAnalyst on the basis of events affecting the issuer or investment concerned,perceived investment opportunities for research clients and developments in theAnalyst's opinion. Investment bankers and sales and trading personnel have nocontrol over, or input into, decisions on timing of publication of individual research
reports.
RBCCM has policies that may restrict the publication of research or the inclusionof opinions and/or recommendations in research, relating to the issuer or its
related parties, at certain times when RBCCM is involved in investment banking
transactions.
In relation to offerings of securities, we follow the customary practice, and insome jurisdictions we are required by law, to impose a "quiet period" or "blackout
period" before and/or after the offering.
Dissemination of research and updated views: Research reports that areapproved for distribution to our global client base are made available to clients
through the RBC global research portal. Any material update of a Research
Analyst's view, for example an immediate response to issuer news in advance ofa full research report, is made available to clients through the portal. Our policies
do not allow research reports to be made available to non-research personnel ofRBCCM or RBC Wealth Management, including our traders, before they are
made available to our clients.
Updating: With respect to investment recommendations on equity securities
covered by an Analyst, it is RBCCM’s policy that the Analyst revise and publish
financial estimates, valuations, price targets and recommendations for allcompanies covered at least quarterly and as soon as possible after all relevant

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events. With respect to other research reports, RBCCM does not undertake toupdate or revise any such research or recommendations in respect of securities
or issuers either periodically or in response to issuer, industry, economic or otherevents, but may do so where practicable.
Disclosure of interests: RBCCM discloses in its research reports, in accordancewith applicable law and regulation, particulars of interests, including those ofRBCCM and the Analyst, that are or may be material in the context of therelevant report.

Important Notes
This policy is supplemented by more detailed policies and procedures adopted
by RBCCM. Variations and exceptions to this policy may be approved by
Research Management and Compliance in individual cases, with a view topromoting the objectives of this policy in the particular circumstances.

Last updated January 2024