WELLINGTON MANAGEMENT

Wellington Management
Stewardship Conflicts of Interest Policy……………………………………………………………………………………………………………………………………………………………………………………………………………………………

INTRODUCTION
As a fiduciary, we seek to place the interests of our clients first and avoid conflicts of interest. Some conflicts areinherent in any large, global investment management business, while others are a result of our business model. We
have adopted and implemented policies and procedures that we believe are reasonably designed to manage conflictsof interests that arise from our stewardship activities and seek to mitigate adverse impacts of such conflicts on ourclients.

POTENTIAL CONFLICTS IN RELATION TO STEWARDSHIP ACTIVITIESWe have identified three categories of conflicts of interest relating to our fiduciary activities:• conflicts between and among the interest of our clients;• conflicts between the interests of our clients and those of the firm; and• conflicts between the interests of our clients and the interests of our personnel as individuals.
Examples of situations where potential conflicts of interest could arise as part of our stewardship activities include:• an investee company is a significant client, lender, or vendor of Wellington Management;• there may be personal contacts and connections at an investee company; and• the views of internal portfolio managers may differ between each other.

MANAGEMENT OF CONFLICTS
Annually, the Investment Stewardship Committee (‘ISC’) sets standards for identifying material conflicts based onclient, vendor, and lender relationships, and publishes those standards to individuals involved in the proxy voting
process.
Potential conflicts may be resolved by voting in accordance with our published Global Proxy Voting Guidelines. Where
the published voting guideline is case by case, where no published guideline exists, or where the proposed voting
position is contrary to a published guideline, the matter must be reviewed by three disinterested ombudsmen from theISC, who will resolve the conflict and direct the vote. In certain circumstances, the ombudsmen may determine thatthe full ISC should convene. The role of the ombudsmen is to review the recommendations of the ESG Research
Team, oversee any discussion or debate with respect to the proposed votes, and ensure that votes are executed solely
in the best interest of our clients.
Where a material, self-disclosed personal conflict is identified in relation to proxy voting, the conflict may be mitigatedby assigning voting responsibility to another investment professional or directing it to three disinterested ombudsmen
from the ISC.
Wellington Management’s commitment to stewardship and active ownership means that we have regular engagementwith companies and our investment teams are not constrained when engaging on issues with companies.
As a community of investment boutiques, each of Wellington Management’s portfolio teams acts as a fiduciary for its
clients. Differences in investment philosophy and process across teams mean that the way in which stewardship……………………………………………………………………………………………………………………………………………………………………………………………………………………………
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WELLINGTON MANAGEMENT……………………………………………………………………………………………………………………………………………………………………………………………………………………………

activities are incorporated into the investment decision-making process may vary across investment approaches. We
believe that this structure best enables us to meet the investment objectives of our diverse client base and encourages
individual responsibility for investment performance. It does, however, result in situations where actions taken for one
client account directly contradict those taken for others.

ANNUAL REVIEWThe ISC is responsible for reviewing and updating this policy at least annually and otherwise as appropriate to ensure it
adequately reflects the types of conflicts that may arise and to take measures to remove or mitigate any adverse
impacts of these conflicts in an appropriate manner.

Dated: June 2022
Last reviewed: December 2022……………………………………………………………………………………………………………………………………………………………………………………………………………………………
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