T. Rowe Price (Luxembourg) Management S.à r.l. - Remuneration Policy Disclosure
Effective date: as at February 3rd, 2023

T. Rowe Price (Luxembourg) Management S.à r.l (TRPLUX) acts as the management company for a numberof funds that qualify either as Alternative Investment Funds (AIFs) under the Alternative Investment FundManagers Directive 2011/61/EU, as amended, (AIFMD) or as Undertaking for Collective Investment inTransferable Securities (UCITS) under Directive 2009/65/EC, as amended, (the UCITS Directive).
TRPLUX is also authorized as an Alternative Investment Fund Manager (AIFM) under AIFMD and ispursuant to Art. 101 (3) of the 17 December 2010 Law to provide discretionary portfolio management andinvestment advisory services.
TRPLUX has adopted a Remuneration Policy Statement (RPS) which sets out the policies, practices andprocedures followed by the firm in order to comply with:
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the European Securities and Markets Authority’s “Guidelines on sound remuneration policies
under the UCITS Directive and AIFMD”, (the AIFMD Guidelines), andthe associated European Securities and Markets Authority’s “Guidelines on sound remuneration
policies under the UCITS Directive”, (the UCITS Guidelines and together with the AIFMD
Guidelines referred to as the Guidelines),
CSSF Circular 10/437 regarding “Guidelines concerning the remuneration policies in the financialsector” (the Circular), published February 1st, 2010,
The UCITS Directive as transposed into Luxembourg by means of the law of 17 December 2010
relating to undertakings for collective investment (the 2010 Law),
The AIFMD as transposed into Luxembourg by means of the law of 12 July 2013 (the AIFM Law),
andESMA Q&As on the application of the UCITS Directive and the AIFMD.

TRPLUX is a wholly owned subsidiary of T. Rowe Price Group, Inc. (TRPG), and the policies, practices andprocedures described herein are predominately reflecting those of TRPG. References within thisdisclosure statement to “T. Rowe Price” and the “company” refer to TRPG; references to the “firm”,“UCITS management company” or the AIFM refer to TRPLUX.
The RPS aims to ensure that:• the firm can attract and retain top quality, highly motivated associates;• compensation practices provide incentives to associates that are consistent with good risk
management and the appropriate management of potential conflicts of interest;• associates know in advance what sort of behaviours and actions will be positively rewarded in
the remuneration review process;• the total amount of remuneration distributed by the Group/firm is sustainable and is consistent
with sound financial management.
Components of Remuneration:••

Fixed basic salary – Based on role of each individual associate, including the extent ofresponsibility, job complexity and local market conditions.
Variable Cash bonus – Varies according to the type of role undertaken and is based upon theperformance of the individual associate in respect of a number of factors as well as the company’sfinancial performance.

•Long Term Incentive Program – Under this program, associates may be granted stock
appreciation rights, restricted stock awards, restricted stock units and stock options. The
primary form of long-term equity for all recipients is restricted stock units. Restricted stock unit
awards vest equally over a five-year period, beginning on or around December 10th of the year
following grant•Pension contributions –Varies to some extent according to local market practice but aims toprovide associates with an appropriate pension provision through a non-discretionary pension
plan aligned with the business strategy, objectives, values and long-term interests of the firm,
the UCITS and AIFs it manages.
Other benefits – Varies to some extent according to local market practice but would typically
include medical, sickness and life cover.

•Governance and performance evaluation
In determining the structure of the firm’s compensation program and the appropriate levels of incentive
opportunities, TRPLUX along with the Management Compensation and Development Committee (theMCDC) and the Executive Compensation and Management Development Committee (ECMDC) of theTRPG Board consider whether the program rewards reasonable risk-taking and whether the incentive
opportunities achieve the proper balance between the need to reward employees and the need to protect
stockholder returns. While the design of our compensation program is performance-based, we do notbelieve that it encourages excessive risk-taking. Indeed, the MCDC supports an approach of on-going
discussions with management regarding progress on short and long-term goals to enable informed
decisions while avoiding the risks sometimes associated with managing short-term results to achieve predetermined formulaic outcomes.
An individual’s performance is evaluated through a range of financial and non-financial factors; including
risk reduction/mitigation, customer satisfaction, operational effectiveness, process enhancements; levelsof cooperation; developments to the firm’s reputation; and the individual’s compliance with business
policies and procedures.
The ECMDC is comprised solely of the outside directors of T. Rowe Price Group’s Board of Directors. The
TRPG CEO, and the Head of Human Resources of TRPG (each a member of the MCDC) are typically invited
to present at each meeting. The ECMDC has also retained an independent compensation consultant toassist in its important governance responsibilities.
In addition to the above committees, the Human Resources department plays a key role in vettingcompensation decisions across the company, both during the year and in the year-end incentive award
processes. Human Resources also has firm wide compliance oversight for the RPS to ensure the RPS andour practices are in agreement.
Consistency with sound and effective risk management
It is intended that the RPS is consistent with, and promotes, sound and effective risk management anddoes not encourage risk-taking that is inconsistent with the risk profile, rules or governing documents of
the investment funds managed.
In determining an individual’s compensation, we analyze the goals, objectives and the results of eachindividual. Inherent in that analysis is reviewing “how” the individual achieved his or her results. Thus, risk
analysis is imbedded in how we evaluate an associate’s performance. Any risk management or complianceconcerns which are raised about an associate may be taken into consideration when assessing theassociate’s performance. For example, a regulatory or Code of Ethics breach by an associate, which isidentified by Legal & Compliance, is reported to the associate’s line manager. Based on the circumstances,such breaches may be taken into consideration when assessing an individual associate’s performance, andultimately therefore impacting their compensation. Likewise, if an associate contributes to inappropriate
risk taking that resulted or could have resulted in a material exposure to the firm, its AIFs or its UCITS, it
would be taken into consideration in the determination of both annual cash and equity-based
compensation adjustments.
In addition, investment staff are responsible for incorporating sustainability risks and otherenvironmental, social and governance (ESG) factors into their investment recommendations andinvestment decisions, as appropriate to the mandate. T. Rowe Price holds its portfolio managers andanalysts accountable for doing so by incorporating the extent of the integration of such analysis into
their individual investment processes as part of the assessment criteria in year-end performance reviews
and compensation. ESG integration and sustainability risks incorporation are considered as qualitative
components of the end of year performance assessment.
Investment discretion for the UCITS and all the AIFs is strictly controlled within mandated parameters.
These parameters are generally coded within the Investment Manager’s automated compliance system,
strictly limiting the amount of risk that can be taken within the UCITS and each AIF.
Interest alignment and the management of Conflicts of Interest
As noted above, the ECMDC is comprised solely of non-executive directors of the company. The company
believes that its compensation programs are designed to reward executives and other senior officers forbuilding and strengthening the very core of our company’s long-term viability, which contributes to longterm value creation for our clients and stockholders. We seek to accomplish this through a balance ofshort-term fixed and variable cash compensation, and long-term equity-based incentives. This includes
integration of sustainability risks and Environmental, Social and Governance (ESG) objectives into ourinvestment process and investment professional remuneration. We believe the stability of ourmanagement team over long periods of time, our executives’ and staff-wide level of ownership in thecompany, and our unwavering focus on generating outstanding long-term performance for our clients areevidence that we have created a powerful alignment of incentives between our executive team, ourassociates, our clients and our stockholders. The fixed element of each associate’s compensation is
sufficiently high to allow for a fully flexible policy on the variable component.
In order to educate associates, protect the firm’s reputation, and ensure that the firm’s integrity remains
as a principle by which we conduct business, TRPLUX has adopted TRPG’s Code of Ethics and Conduct("Code"). The Code establishes standards of conduct that we expect each associate to fully understandand agree to adopt, including the appropriate management of conflicts of interest. Any identified
regulatory or Code breaches by an associate are reported to the associate’s line manager and are be taken
into consideration when assessing an individual associate’s performance, and ultimately therefore
impacting their compensation.
Proportionality
Paragraphs 23 - 31 of the AIFMD Guidelines and paragraphs 22 - 27 of the UCITS Guidelines provide
guidance on how AIFs and UCITS respectively can apply proportionality in complying with the Guidelines.
The Guidelines allow AIFMs and UCITS management companies to comply with the remuneration principles
in a way that is appropriate to their size, internal organisation and the nature, scope and complexity of theiractivities. The AIFMD Guidelines further set out that in order for an AIFM to disapply any of theremuneration requirements under AIFMD, the AIFM must be able to explain the rationale to the relevant

competent authority. The UCITS Guidelines state that not all management companies should have to give
substance to the remuneration requirements in the same way and to the same extent.
On the basis of proportionality and to the extent permitted, TRPLUX will disapply the remuneration
guidelines on:•••••Variable remuneration in instruments
Retention
DeferralEx-post incorporation of risk for variable remuneration
The establishment of a remuneration committee

Identified Staff
The Guidelines note that AIFMs and UCITS must identify the staff covered by the Guidelines and classify
them as “Identified Staff”. The definition of Identified Staff covers the following categories of staff unless
it can be shown that they have no material impact on the AIF’s or UCITS’ risk profile.
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Board members
Senior management
Control Functions (i.e. risk management, compliance, internal audit)
Staff responsible for portfolio management, administration, marketing and HR
Other risk takers who can exert a material influence on the TRPLUX’s risk profile
Individuals receiving equivalent remuneration to anyone already included as “Identified Staff’ fromthe criteria above
Staff of delegate entities whose professional activities have a material impact on the risk profile ofthe UCITS or AIF that the management company manages