T. ROWE PRICE GROUP, INC.
GLOBAL CODE OF CONDUCT
February 1, 2023

A MESSAGE FROM ROB SHARPS
Dear Colleagues:
T. Rowe Price is rooted in a culture of ethics and integrity that serves as the foundation of our longterm success. Our company adopted a code of conduct, consistent with our corporate values, long
before it was a regulatory requirement. Our values inform everything we do - every decision andevery action. Today, the Global Code of Conduct continues to guide us to act in a manner consistent
with, and in support of, our values.
Acting with integrity and honesty means speaking up and reporting actual or potential wrongdoing,even when it may be difficult or uncomfortable to do so. The Code highlights the methods(including anonymous reporting) for you to share your concerns regarding actual or perceived
wrongdoing.
This Code and related policies and procedures cannot anticipate every situation that you may faceas you perform your job. There may be situations where you may be unsure about a course ofaction related to specific conduct. In such a case, it is important to always exercise sound andethical judgement, comply with the spirit of the Code, and seek guidance from your manager or
Global Compliance.
Please take the time to reacquaint yourself with the Code and consider its meaning. The Code isan evergreen document, and we routinely look for ways to refresh it and ensure it reflects ourvalues. What we do today for our clients and each other is important; how we do it is just as
important.
Thank you for always acting with the highest level of integrity and ethical conduct, upholding ourvalues and ensuring the T. Rowe Price legacy continues for many years in the future.

Rob Sharps
Chief Executive Officer & President

T. ROWE PRICE GROUP, INC.
GLOBAL CODE OF CONDUCT
February 1, 2023
Table of Contents
ABOUT THE CODE .................................................................................................................................. 3
OUR VALUES ............................................................................................................................................ 3
Put clients first .......................................................................................................................................... 3
Act with integrity and accountability ........................................................................................................ 3
Cultivate intellectual curiosity and innovation ......................................................................................... 3
Embrace diversity and collaboration......................................................................................................... 4
Be disciplined and risk aware ................................................................................................................... 4
Pursue excellence with passion and humility ........................................................................................... 4
OUR COMMITMENT TO ETHICAL AND RESPONSIBLE BUSINESS PRACTICES .................. 4
Protecting client interests by avoiding conflicts of interest ...................................................................... 4❖ Personal securities transactions ..................................................................................................... 5❖ Giving and receiving gifts and business entertainment ................................................................. 5❖ Political activities .......................................................................................................................... 6❖ Outside activities ........................................................................................................................... 6❖ Charitable contributions ................................................................................................................ 7
Safeguarding information ......................................................................................................................... 7❖ Material, non-public information .................................................................................................. 8❖ Maintaining information barriers .................................................................................................. 8❖ Protecting against cyberattacks ..................................................................................................... 9Preventing financial crime ...................................................................................................................... 10❖ Anti-money laundering ............................................................................................................... 10❖ Anti-bribery and anti-corruption ................................................................................................. 10❖ Antitrust ...................................................................................................................................... 11
Recordkeeping ........................................................................................................................................ 11
OUR COMMITMENT TO ASSOCIATES ............................................................................................ 12
Provide a safe and healthy workplace ..................................................................................................... 12
Commitment to diversity, equity and inclusion ...................................................................................... 12
Anti-harassment ...................................................................................................................................... 12
No retaliation .......................................................................................................................................... 13
Speaking up............................................................................................................................................. 13
Manager responsibilities ......................................................................................................................... 14
EACH ASSOCIATE’S COMMITMENT TO ETHICAL AND RESPONSIBLE CONDUCT ......... 14
Business communication ........................................................................................................................ 14❖ Interaction with the media/speaking engagements ..................................................................... 14❖ Use of social media ..................................................................................................................... 15
Use of T. Rowe Price resources .............................................................................................................. 15
Personal disclosure.................................................................................................................................. 15
CONCLUSION ......................................................................................................................................... 16
Resources ................................................................................................................................................ 16❖ Policy portal ................................................................................................................................ 16❖ Associate Handbooks .................................................................................................................. 16❖ Contacts....................................................................................................................................... 16

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ABOUT THE CODE
This Global Code of Conduct (the “Code”) is rooted in the values established by T. Rowe Price
Group, Inc. and its subsidiaries1 (collectively, “T. Rowe Price”). It sets standards of ethical conduct
expected of all T. Rowe Price directors, employees, officers, contingent workers, agency
temporary workers, contractors, consultants, and any other personnel who are deemed to be subject
to the Code (collectively referred to as “Associates”) and provides the framework for conducting
business in a fair and ethical manner.
The Code has been approved by the T. Rowe Price Group, Inc. board of directors. Upon becoming
subject to the Code and every year thereafter, Associates must certify that they have read,understood, and they agree to comply with the provisions of the Code. Infractions or suspectedviolations of the Code are investigated promptly and may result in disciplinary action, up to andincluding termination of employment.

OUR VALUES
Our values shape our corporate culture and guide Associate behavior. These values are embeddedin the principles and practices that have served T. Rowe Price since its founding in 1937. They
ensure that efforts to create value for clients will be repeated far into the future. Each day, throughlarge and small decisions and tasks, Associates around the globe affirm these values.

Put clients first
We take our role as fiduciaries seriously. That means, as a matter of principle, we put our clients'
interests first. To justify the trust each client places with us, we work to deeply understand theirneeds and find solutions to satisfy those needs. Every day, we seek to nurture and reward client
confidence without ever taking it for granted. Our steadfast belief is that when the client succeeds,
the firm succeeds.

Act with integrity and accountability
We strive to do the right thing, always. Our high ethical standards and our culture of consciencedrive the choices we make every day. Our actions are consistent with our belief that trust andcandor benefit all. We honor our commitments and hold ourselves and each other accountable forachieving desired results. Ultimately, success is not just about the value we create for our clients,
but how we provide it.
.

Cultivate intellectual curiosity and innovation
The dynamics of our business and the needs of our clients require a commitment to lifelong
learning. We continuously look across our global platform for opportunities and connections,remain thoughtful and alert, and ask the questions that can unlock value for our clients. We spend
1 The term “subsidiaries” does not include Oak Hill Advisors, L.P. and its subsidiaries.

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time and resources to act on new and innovative ideas. We create forward thinking solutions toaddress areas for opportunity and remain agile in implementation.

Embrace diversity and collaboration
We seek to leverage the wisdom of multiple perspectives from our firm's associates worldwide byfostering an inclusive and collaborative environment. Our diverse global associates bring insight,
engage in open debate, and embrace the broad sharing of information that keeps our thinking freshand independent. By offering as well as challenging our best ideas, we arrive at carefully
considered, well-informed decisions for our clients.

Be disciplined and risk aware
Being strategic, decisive, and disciplined—in approach, processes, and goals– enables us toprovide effective and durable, long-term solutions. This intellectual rigor helps us to recognize andavoid short-term fads or inappropriate business practices. However, being disciplined does notmean that we don't take risks. Being risk aware means that we become thoughtful risk takers: we
carefully assess risks and manage them to develop innovative and effective solutions.

Pursue excellence with passion and humility
Consistent effort and superior results for all clients is our hallmark. We set high standards because
that's what our clients expect. We execute with operational excellence to meet and exceed ourcurrent goals. When we exceed our current goals, we set our future ones higher. Since we arecommitted to the continuous pursuit of excellence, our work is never done.

OUR COMMITMENT TO ETHICAL AND RESPONSIBLE
BUSINESS PRACTICES
Protecting client interests by avoiding conflicts of interest
T. Rowe Price acts as a fiduciary to many of its clients. A fiduciary is generally defined as “aperson who holds a legal or ethical relationship of trust with one or more parties.” In other words,
T. Rowe Price’s fiduciary responsibilities require it to place the interests of its clients ahead of its
own interests or those of Associates.
Associates must act in a manner that avoids actual or perceived conflicts of interest. Conflicts ofinterest may arise between clients, between clients and T. Rowe Price, between clients andAssociates, and among T. Rowe Price’s own entities or business divisions. T. Rowe Price takes all
reasonable steps to identify and manage conflicts.
Certain conflicts are easily identified. Others are not. Both may have long-term consequences to
T. Rowe Price, so Associates must seek guidance from their manager or Code Compliance when
they are uncertain about the correct course of action. When conflicts of interest are not properly4addressed or mitigated, they can subject T. Rowe Price and Associates to, among other things,
increased regulatory scrutiny, fines, loss of reputation, and litigation.
Conflicts or potential conflicts involving Associate actions may arise through, among otheractivities: (i) personal securities transactions; (ii) the giving and receiving of gifts and businessentertainment; (iii) political contributions and activities; (iv) outside activities; and (v) charitable
contributions.
❖ Personal securities transactions
Associates who engage in personal securities transactions must do so in compliance with allapplicable laws, regulations, and T. Rowe Price policies. An Associate’s personal investment
activities must not result in legal, business or ethical conflicts with T. Rowe Price or its clients andmay not be so excessive as to impact the Associate’s ability to perform their job function.
Transactions in T. Rowe Price securities are subject to pre-clearance and additional restrictions.
Associates may only transact in T. Rowe Price securities during designated “transaction periods”
published on the T. Rowe Price intranet site (the “Exchange”).
Associates must not:••••Transact in T. Rowe Price securities options (other than options granted by T. Rowe Priceto Associates);
Sell short T. Rowe Price securities;
Transact in T. Rowe Price securities outside the designated transaction period; andEnter into any contract or purchase any instrument designed to hedge or offset any decreasein the market value of T. Rowe Price securities.

Associates must never trade in their personal securities accounts while in possession of material,
non-public information, and must not use their internal access to T. Rowe Price systems, resources,
and/or personnel to conduct their personal transactions. See “Safeguarding information.”
For more detail on the requirements related to personal securities transactions, Associates shouldrefer to the Code of Ethics and Personal Transactions Policy.
❖ Giving and receiving gifts and business entertainment
Giving and receiving gifts and entertainment is an established business practice which, if usedappropriately, can help strengthen business relationships and foster new business opportunities.
However, Associates must avoid even the appearance of impropriety when giving or receiving
gifts or entertainment as they may appear to influence a business contact’s, or an Associate’s
decision-making regarding T. Rowe Price business.

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Associates may not offer, give, provide, or accept any gift or business entertainment unless suchgift or entertainment:
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Is reasonable and customary under the circumstances;
Is not lavish in value or excessive in frequency;
Cannot be construed as a bribe, payoff, or kickback to obtain or retain business;
Is an appropriate reimbursable business expense; andDoes not violate any applicable law, regulation or T. Row Price policy.

The exchange of gifts and entertainment involving certain entities, including defined benefit plan
fiduciaries and brokers, is highly regulated and our policies apply additional limitations wheninteracting with such individuals. There are specific provisions in T. Rowe Price and business unit
policies and procedures relating to these limitations.
For more detail on the requirements related to the exchange of gifts and business entertainment,
Associates should refer to the Global Gifts and Business Entertainment Policy and applicablebusiness unit policies and procedures.
is❖ Political activities
While T. Rowe Price acknowledges personal engagement in the political process, Associates must
be mindful that their actions in this regard could have a negative financial or reputational impact
on T. Rowe Price, if they fail to meet certain requirements. U.S. pay-to-play regulations restrict
personal political contributions by employees of financial services companies.
Associates must obtain prior clearance for their political contributions and activities related to
candidates for political office in the United States. Political contributions and activities undertaken
by Associates must always be lawful and consistent with T. Rowe Price and business unit policies.
Associates may not coordinate or solicit third parties to make a contribution or payment to any
candidate, officeholder, political party, political action committee, political organization or bondballot campaign in the U.S., unless authorized by Legal, Compliance & Audit. Furthermore,
Associates may not do anything indirectly that, if done directly, would violate T. Rowe Pricepolicies or applicable regulation.
For more detail on the requirements related to the limits on political contributions and activities,
Associates should refer to the Global Political Contributions and Activities Policy and applicablebusiness unit policies and procedures.
❖ Outside activities
Associates are expected to put their responsibilities at T. Rowe Price ahead of any other personal
business opportunities or second jobs and must avoid any activities, relationships or situations thatmight conflict with, or appear to conflict with, their duties on behalf of T. Rowe Price. When an
Associate is engaged in an approved outside activity, they must be vigilant about any changes in
the arrangement that may present a real or perceived conflict of interest with T. Rowe Price.

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Associates who are FINRA-registered representatives of a T. Rowe Price broker-dealer haveadditional reporting requirements with respect to outside activities.
For more detail on the requirements related to outside activities, Associates should refer to the
Global Outside Activities Policy and applicable business unit policies and procedures.
❖ Charitable contributions
Associates must be sensitive to a possible perception of undue influence before making orrequesting charitable contributions to or from a client, prospect, vendor, or other business contact.
Under certain anti-bribery laws, regulators may consider charitable contributions to be improper
payments, even when the person who has requested that the contribution be made receives nodirect monetary benefit. Accordingly, when making charitable contributions in response torequests from business contacts, Associates must be mindful of real or perceived conflicts ofinterest. In no case should charitable contributions be made on a quid pro quo basis.
For more detail on the requirements related to charitable contributions, Associates should refer tothe Global Charitable Contributions Policy and applicable business unit policies and procedures.

Safeguarding information
T. Rowe Price is committed to the appropriate collection, use, security and confidentiality of thefinancial, personal and business information (together, “confidential information”) entrusted to it
by clients, vendors, and Associates. When Associates handle confidential information correctly,
they protect T. Rowe Price’s reputation for integrity, promote business relationships, safeguard T.
Rowe Price’s and its clients’ assets, and help to ensure compliance with the complex laws andregulations governing T. Rowe Price’s business. These concepts include maintaining the qualityof confidential information and not retaining confidential information when no longer needed tocomply with law or other legitimate business purposes.
Confidential information includes information that is not known to the public about T. Rowe Price,
its employees, its clients or other parties with whom T. Rowe Price has a relationship and that havean expectation of confidentiality. No matter the form or format, Associates must protect the
information they manage on behalf of T. Rowe Price from theft, loss, or unauthorized access, use
or disclosure. The commitment to safeguarding confidential information applies whether the
Associate is working in the office or remotely from another location.
Associates must:•••

Follow applicable T. Rowe Price and business unit policies regarding the collection, use
and safeguarding of confidential information;
Access only the confidential information they need to know and are authorized to accessto perform their job function or as permitted by law;
Transmit confidential information only to other Associates or to third parties who have alegitimate business need to know the information and in compliance with applicablepolicies;
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•
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Take care to prevent unauthorized persons from obtaining confidential information;
Use confidential information solely for T. Rowe Price business, and maintainconfidentiality even when their relationship with T. Rowe Price ends;
Transact T. Rowe Price business exclusively through approved communication channels
and devices;
Refrain from using or bringing physical or electronic confidential information belonging
to another business (including past employers) to T. Rowe Price, unless authorized by theother business; andReport known or suspected data security incidents without delay to the Help Desk.

The firm has procedures to ensure individuals, regulators, and others are informed timely of data
security incidents when required. Through audits and internal reviews, T. Rowe Price regularly
assesses the effectiveness of controls to mitigate privacy and confidentiality risk.
For more detail on the requirements related to confidential information, Associates should refer tothe Global Information and Systems Security Policy, the Global Privacy Policy, the Confidential
Client Data Policy, the Global Material, Non-Public Information Policy and applicable business
unit policies and procedures.
❖ Material, non-public information
Material, non-public information (also referred to as “inside information”) is a form of confidential
information and includes all non-public information that may have a significant impact on the priceof a security or other financial instrument or that a reasonable investor would likely consider
important or relevant in making an investment decision.
Associates must never, under any circumstance, trade, encourage others to trade orrecommend securities or related financial instruments while in possession of material, nonpublic information related to those securities or instruments.
If an Associate believes they may be in possession of material, non-public information, they must
immediately contact Legal, Compliance and Audit and refrain from disclosing the information toanyone else, including T. Rowe Price colleagues, unless specifically instructed to do so by Legal,
Compliance and Audit.
For more detail on the requirements related to material, non-public information, Associates shouldrefer to the Global Material, Non-Public Information Policy and applicable business unit policies
and procedures.
❖ Maintaining information barriers
Information barriers are the physical and system controls established by T. Rowe Price to prevent
restricted investment data from being communicated or shared among certain legal entity affiliates.
Information barriers include, among other things:•

Separate office spaces for adviser affiliates;
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Controlled access to physical spaces through keycard permissions;
Systems entitlement restrictions, distribution list management, and similar technology
barriers; andAdherence to a “cooling off” period for investment personnel transferring roles acrossadviser entities.

Associates must exercise caution when using restricted investment data and ensure they do not
inadvertently share such information with their colleagues who are not authorized to receive it.
For more detail on the requirements related to maintaining information barriers, Associates shouldrefer to the Enterprise Disaggregation Policy, the Enterprise Disaggregation Physical Separation
Policy, the Enterprise Disaggregation Information Barrier Breach Policy, the Information
Barriers Policy and applicable business unit policies and procedures.
❖ Protecting against cyberattacks
Every Associate is responsible for cybersecurity. Cybersecurity is generally defined as the practiceof protecting critical systems and confidential information from digital attacks. Cybersecurity
measures are designed to combat threats against networked systems and applications, whether
those threats originate from inside or outside an organization.
A cyberattack has the potential to damage or impair the confidentiality, integrity or availability of
T. Rowe Price’s information, systems or networks. To protect these valuable assets, T. Rowe Pricemaintains a framework of safeguards to prevent, detect and respond to cyberthreats and incidents,
which includes certain monitoring of Associates’ actions regarding the Firm’s information systems
and networks.
Associates must:
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Be alert to phishing scams and other forms of social engineering and refrain from clicking
links or opening attachments from unknown senders;Protect their passwords and never share them with anyone, even someone they know;
Maintain the physical security of laptops and other mobile devices;
Refrain from accessing or downloading anything for installation or storage onto T. RowePrice’s computers unless it is approved by the T. Rowe Price;
Refrain from downloading firm information to their personal devices or personal cloudstorage sites;
Notify the Help Desk without delay when they detect suspicious activity or when T. RowePrice assets (such as laptops, mobile devices, flash drives containing confidential
information) are lost or stolen; andBe familiar with T. Rowe Price and business unit policies and procedures relating to
information security and the proper use of T. Rowe Price systems.

For more detail on the requirements related to cybersecurity and cyberattacks, Associates shouldrefer to the Global Information and Systems Security Policy and applicable business unit policies
and procedures.
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Preventing financial crime❖ Anti-money laundering
Money laundering is a crime that involves disguising funds obtained through illegal means bymoving them through legitimate channels in an effort to “clean” the assets. Failure to comply with
anti-money laundering laws is a crime. T. Rowe Price has designed its business operations toensure that our facilities, products, and services are used only for legitimate purposes. T. RowePrice will not knowingly engage in any activity that facilitates money laundering or the funding ofterrorist or criminal activities.
T. Rowe Price has developed policies and procedures to help detect and prevent money launderingfrom occurring and it will comply with all laws and regulations to which it is subject, including
those laws and regulations requiring the reporting of suspicious activity.
Associates must:••

Ensure clients provide accurate and complete information about themselves as required byapplicable law and T. Rowe Price and business unit policies; andEscalate promptly any unusual or suspicious activity that could involve money launderingor terrorist financing, has no apparent business or lawful purpose, or is not the type oftransaction in which the client would normally engage.

For more detail on the requirements related to anti-money laundering, Associates should refer tothe Global Anti-Money Laundering Policy and applicable business unit policies and procedures.
❖ Anti-bribery and anti-corruption
Associates must not offer, promise, pay or authorize the payment of, directly or indirectly, any
money or anything of value to any person to influence the person to obtain or retain business orgain any other improper business transaction. Likewise, a business partner of T. Rowe Price may
not engage in such activities, either independently or on our behalf. There is a heightened risk ofbribery or corruption when Associates interact with government officials (officers, employees orrepresentatives of a government entity).
Actions constituting a bribe or illegal payment are interpreted broadly and may include, among
other things (i) exchanging excessive or lavish entertainment and/or gifts, and (ii) hiring
individuals who are referred by, or related to, clients or government officials.
Associates must:••

Be familiar with T. Rowe Price and business unit policies and procedures regarding
interactions with government officials and anti-bribery and anti-corruption;
Ensure that appropriate due diligence has been conducted on all third-party business
partners with whom they interact; and10•

Offer or accept from clients and potential clients only those gifts and entertainment that areusual, customary and appropriate.

For more detail on the requirements related to anti-bribery and anti-corruption, Associates shouldrefer to the Global Anti-Bribery and Anti-Corruption Policy and applicable business unit policies
and procedures.
❖ Antitrust
Global antitrust laws are designed to ensure fair competition, preserve the free enterprise system,and prohibit the misuse of market power by individual companies.
Associates must not agree with a competitor to fix prices, refrain from hiring each other’s
employees, or otherwise distort the market and must never deal with anyone if the purpose of theinteraction is to impede another party from competing in the market.
For more detail on the requirements related to ensuring free and competitive markets, Associates
should refer to the Global Policy on Compliance with Antitrust Laws and applicable business unit
policies and procedures.

Recordkeeping
T. Rowe Price is required to maintain accurate and complete books and records of its businessactivities and is subject to a broad range of regulatory requirements in connection with the retention
and destruction of both physical and electronic records. Records created by Associates are theproperty of T. Rowe Price and must be maintained and destroyed in accordance with T. RowePrice and business unit policies and procedures.
To ensure recordkeeping requirements are maintained in accordance with applicable regulation,
Associates must conduct all T. Rowe Price business on T. Rowe Price-approved devices (e.g.,desktops, laptops, mobile phones) and through T. Rowe Price systems.
Associates must exercise care when disposing of records when it is appropriate and legal to do so.
There can be legal prohibitions from destroying any records that may be relevant to any current,
pending or threatened litigation, or regulatory investigation or audit. Associates must be prepared
to secure relevant records once they become aware that they are subject to litigation or regulatory
investigations or audits.
For more detail on the requirements related to record retention and destruction, Associates shouldrefer to the Global Electronic Communications Policy and applicable business unit policies andprocedures.

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OUR COMMITMENT TO ASSOCIATES
Provide a safe and healthy workplace
T. Rowe Price is committed to providing all Associates with a workplace that prioritizes both wellbeing and safety. Associates are responsible for following the direction of the firm’s security staff
and for bringing situations that threaten the health and safety of Associates to their attention
immediately.
Associates should refer to the applicable Associate handbook for additional details.

Commitment to diversity, equity and inclusion
T. Rowe Price is committed to fostering, cultivating, and preserving a global culture of diversity,
equity, and inclusion (“DEI”). Our diverse global workforce is one of our most valuable assets.
The collective sum of our individual Associates’ backgrounds, perspectives, talents, andexperiences contribute significantly to our culture, our reputation, our ability to deliver a strong
client experience, and our success. We embrace and encourage our differences in age, race,
disability, ethnicity, family or marital status, gender identity or expression, language, national
origin, physical and mental ability, political affiliation, race, religion, sexual orientation, socioeconomic status, veteran status, and other characteristics that make our associates unique. Our DEI
programs and expectations are woven throughout our practices and policies on recruitment, talentacquisition, and retention; compensation and benefits; professional development and training;
promotions; transfers; associate engagement, outreach, and advocacy; layoffs and terminations;and the ongoing development of an inclusive work environment that allows Associates to bring
their best selves to work every day.
Associates should refer to the applicable Associate handbook for additional details.

Anti-harassment
T. Rowe Price is committed to providing a safe working environment in which all individuals aretreated with respect and dignity. Associates have the right to enjoy a workplace that is conducive
to high performance, promotes equal opportunity, and prohibits discrimination, includingharassment. T. Rowe Price will not tolerate harassment, discrimination, or other types of
inappropriate behavior directed by or toward an Associate, supervisor, manager, contractor,
vendor, client, visitor, or other business partner. Accordingly, under the zero-tolerance policy, we
do not tolerate discrimination, sexual harassment, human rights violations, harassment or
intimidation of any Associate based on race, religion, creed, color, national origin, sex, gender,
age, physical and mental disability, marital status, sexual orientation, gender identity or expression,
citizenship status, military or veteran status, pregnancy discrimination, or any other status
protected by country, federal, state, or local law.
Associates may not engage in activities or conduct, in any setting, that is inconsistent with our
corporate values, particularly those related to our policy against harassment and discrimination.
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Actions that may embarrass, offend, insult or denigrate individuals or groups, or that may shock,insult or offend our community, clients or Associates will lead to disciplinary action up to andincluding termination of employment.
Associates should refer to the applicable Associate handbook for additional details.

No retaliation
T. Rowe Price does not tolerate retaliation or intimidation for any report of misconduct that is
made in good faith or in accordance with applicable laws. Anyone who retaliates against an
Associate for sharing concerns or participating in an investigation of misconduct will be subject
to disciplinary action, up to and including termination of employment.
For more detail related to speaking up and protection from retaliation, Associates should refer tothe Global Whistleblower Policy and applicable business unit policies and procedures.

Speaking up
Every Associate has an obligation to speak up if they encounter a situation that raises a real or
potential legal or ethical concern – potential fraud, a violation of this Code, a T. Rowe Price policy,
law or regulation, or any other wrongdoing. Reporting of an ethical matter should be factual, rather
than speculative, and should contain as much information as possible to allow for proper
assessment of the nature, extent and urgency of the matter being reported.
T. Rowe Price has established several ways that facilitate the sharing of concerns by an
Associate. Associates may escalate a concern to:••••

Their manager;
The General Counsel, respective chief compliance officer, senior compliance manager
or regional Head of Human Resources, verbally or in writing. This can be done on an
anonymous basis in writing using internal mail and a confidential envelope;
The anonymous reporting hotline at 1.888.651.6223, which is administered by a third
party vendor and available 24 hours a day/seven days a week. International dialing
codes may be necessary for calls originating outside the U.S.; andEthicsPoint, the confidential, anonymous reporting web-site administered by a thirdparty vendor and available 24 hours a day/seven days a week.

As Associate’s obligation to speak up is not intended to restrict, discourage, or interfere with an
Associate’s communications or actions that are protected or required by law or regulation.
T. Rowe Price will investigate promptly matters reported and will make every effort to maintainconfidentiality during the investigation, to the extent practicable and as permitted by law.

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Manager responsibilities
Managers must always lead with integrity and reinforce T. Rowe Price’s culture of ethical conduct
with the Associates they manage. Managers are typically the first resource for Associates who
have questions regarding ethical issues, or matters addressed in the Code or other applicable T.
Rowe Price or business unit policies and procedures. If a manager is unable to resolve an issue oris unsure of the correct course of action, they must direct the Associate to the appropriate resource.
Since managers may be the first place an Associate turns to escalate a concern regarding unethicalbehavior or wrongdoing, they must create an open environment where Associates feel comfortable
sharing concerns and asking questions. Associates must never feel uncomfortable or fear
retaliation for sharing concerns or their observations of misconduct.
Managers are also responsible for taking appropriate action, which may include escalation, when
they have concerns regarding an Associate. In some cases, a manager may be held responsible for
failing to report misconduct or to take steps to address or remediate an Associate’s misconduct.
Associates should refer to the Manager SourceBook for additional details.

EACH ASSOCIATE’S COMMITMENT TO ETHICAL ANDRESPONSIBLE CONDUCTBusiness communication
Any public statement or communication about T. Rowe Price must be fair, balanced and not
misleading, while simultaneously protecting the confidentiality of T. Rowe Price’s business andclient information. Communications that fail to meet these standards could have serious
repercussions for T. Rowe Price.
Only T. Rowe Price-approved messaging systems may be used to engage in electronic
communication about T. Rowe Price or to conduct T. Rowe Price business. Failure to comply withthis requirement may subject an Associate to sanctions, including termination of employment.
For more detail on the requirements related to appropriate use of mobile devices in connection
with business communications, Associates should refer to the Global Electronic Communications
Policy, the Mobile Device Acceptable Use and Security Policy and applicable business unit
policies and procedures.
❖ Interaction with the media/speaking engagements
Only certain Associates are authorized to communicate on behalf of T. Rowe Price. Please refer
all requests for information from the media concerning T. Rowe Price’s corporate affairs,
investment products and services, investment philosophy and policies, to the appropriate Corporate
Communications/Public Relations contact for reply. Speaking on industry panels at conferences
does not require approval, but Associates should notify their manager prior to accepting.
Invitations to speak at high-profile events should be reviewed with Legal, Compliance & Audit.
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For more detail on the requirements related to business communication and interactions with themedia, Associates should refer to the Global Media Engagement Guidelines and applicablebusiness unit policies and procedures.
❖ Use of social media
T. Rowe Price respects each Associate’s right to engage in social and professional dialogue outsideof working hours and acknowledges that such activity may involve the use of social media.
Associates must exercise good judgement when making personal statements on social media
platforms and must ensure that their activities on social media (whether personal or professional)
comply with the requirements of T. Rowe Price’s policy on the use of social media. Compliancewith the policy ensures compliance with applicable regulations when engaging on social media
platforms and protecting other Associates, clients and T. Rowe Price.
For more detail on the requirements related to the use of social media in the workplace, Associates
should refer to the T. Rowe Price Policy for U.S. Associate Use of Social Media, the T. Rowe Priceex-U.S. Policy for Associate Use of Social Media and applicable business unit policies andprocedures.

Use of T. Rowe Price resources
T. Rowe Price property and resources are intended to help Associates achieve T. Rowe Price’s
business objectives. Associates must protect and use T. Rowe Price property and resources
responsibly. T. Rowe Price does not tolerate careless, inefficient, fraudulent, or illegal use of its
resources.
Although T. Rowe Price recognizes that Associates may utilize T. Rowe Price systems foroccasional personal use, Associates should have no expectation of privacy with respect toinformation transmitted or stored on such systems.

Personal disclosure
Associates must not engage in any conduct that could jeopardize T. Rowe Price’s registration as aregulated entity under U.S. and global securities laws and must promptly notify the CodeCompliance Team if they are involved in, or become aware of, certain criminal, civil, regulatory
or financial events. Upon joining T. Rowe Price and annually thereafter, Associates are required
to complete a certification as to their personal disclosure requirements. Nevertheless, disclosure of
any change in the matters to which the Associate has certified must be promptly reported to CodeCompliance.

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CONCLUSION
The principles set forth in this Code provide the ethical framework for an Associate’s businessrelated decisions and interactions with other Associates, clients and business partners. When
Associates adhere to this ethical framework and conduct business with integrity and excellence,
T. Rowe Price’s reputation as a trusted adviser and business partner is affirmed. Strict compliancewith the provisions of this Code is considered a basic condition of employment or association with
T. Rowe Price.
The Code does not create, nor is it intended to create, an employment or other contractual
agreement. Unless otherwise provided by written agreement, Associates are employed “at will,”meaning that either the Associate or T. Rowe Price may end their arrangement without notice, at
any time, for any reason or for no reason at all.

Resources❖ Policy portal
Many of the principles and values discussed in the Code are described further in T. Rowe Pricebusiness unit and region-specific policies and procedures, which also provide detail on Associate
responsibilities. In some cases, our policies apply to the activities of an Associate’s family
members, such as those related to conflicts of interest and personal securities transactions.
Associates are expected to be familiar and comply with all policies and procedures applicable tothem. Policies and procedures can be found in C360 on the Exchange.
❖ Associate Handbooks
T. Rowe Australia Associate Handbook
T. Rowe Price China Associate Handbook
T. Rowe Price Hong Kong Associate Handbook

T. Rowe Price Singapore Associate Handbook
T. Rowe Price U.K. Associate Handbook
T. Rowe Price U.S. Associate Handbook

For all other Associate Handbooks, Associates should refer to myHR on the Exchange.
❖ Contacts
Code Compliance: Code_of_Ethics@TRowePrice.com
Business Unit Contacts: Business Unit Compliance Resources16