Conflict of Interest Policy Summary
January 2021

REQUIREMENT
BNP Paribas Asset Management (“BNPP AM”) must take all appropriate steps
to identify conflicts of interest between itself, its managers and employees orany person directly or indirectly linked to them by control (“relevant person”),
and a client or between one client and another.

DEFINITION OF A CONFLICT
In identifying conflicts that may arise and whose existence may entail a material
risk of damage to the interests of a client, BNPP AM must take into account
whether it or a relevant person:

 is likely to make a financial gain, or avoid a financial loss, at the expenseof the client; Where BNPP AM places orders with affiliated broker dealers; Where BNPP AM allocates the cost of errors to clients’/funds’ accounts
instead of BNPP AM;

 Where BNPP AM recommends an investment product to a client which
may not be the most suitable solution for the client

Policies on the selection/use of brokers, on errors’ handling and on suitabilityof products have been implemented to address these potential conflicts.

BNPP AM EMPLOYEE VS. CLIENT CONFLICTS
Where gifts and entertainment (including non-monetary gifts) are received
that may influence behaviour in a way that conflicts with the interests of theCompany’s clients;

 has an interest in the outcome of the service provided to the client or of atransaction carried out on behalf of the client, which is distinct from theclient’s interest in that outcome; has a financial or other incentive to favour the interest of another client orgroup of clients over the interests of the client; carries on the same business as the client; or receives or will receive from a person other than the client an inducement
in relation to the service provided to the client other than the standard
commission or fee for that service.

Where a BNPP AM employee engages in personal account dealing
in respect of securities and BNPP AM has a client or fund with aninterest that potentially conflicts with such dealing;

Where a BNPP AM employee has outside business interests thatconflict with the interests of the BNPP AM’s clients.
March 2011
Policies on Personal Account Dealing and Outside Business Interests and Gifts
have been implemented to address these potential conflicts.

IDENTIFICATION OF CONFLICTS OF INTEREST
All employees are required to identify any potential conflict of interest and report
it to their manager and to Compliance.

CLIENT VS. CLIENT CONFLICTS

The following is a non-exhaustive list of typical examples of situations whereconflicts may arise:

BNPP AM VS. CLIENT CONFLICTS

Where BNPP AM allocates executed orders, carried out on behalfof more than one client/fund, in such a way that may result in a
disadvantage to one or more clients/funds

Policies on best execution, aggregation and fair allocation of orders have been
implemented to address these potential conflicts.

MANAGEMENT OF CONFLICTS

 giving clients clear, honest and non-misleading information and, if soBNPP AM has implemented an organisational structure and a number ofprocedures so as to ensure that conflicts of interest are prevented from giving
rise to a material risk of damage to the interests of its clients.

 provide quality service that preserves the client’s best interests;

DISCLOSURE OF CONFLICTS
In the event that a conflict of interest arises where the implemented policies andprocedures are not sufficient to ensure, with reasonable confidence, that risksof damage to the interests of a client will be prevented, BNPP AM must clearly
disclose the general nature and sources of the conflict to the client before
undertaking business for the client. Such disclosure must be made in a durable
medium and include sufficient detail to enable the client to make an informed
decision with respect to the service in the context of which the conflict of interest
arises. The form of any such disclosure must be approved by Compliance.
Under BNPP AM’s policy over-reliance on disclosure without adequate
consideration as to how conflicts may be managed appropriately is notpermitted.

INFORMATION BARRIERS
BNPP AM is appropriately segregated from other businesses within BNPParibas Group. BNPP AM utilises ring fenced IT systems for the conduct of its
business. Decisions taken within BNPP AM must be taken in the interests of its
clients only even if such decisions may be detrimental to, or conflict with, theinterests of a client of some other business area or a proprietary interest of BNPParibas. Staff working for BNPP AM must remain independent and neutral in
the performance of their duties and responsibilities.
The governance arrangements for the asset management activities of BNPParibas Asset Management also functions on an independent basis to the BNPParibas group. This includes BNPP AM’s hierarchical reporting line which isseparate to those of other BNP Paribas businesses and converges only at thelevel of the Executive Management Committee of BNP Paribas Group.

PRIMACY OF CLIENTS’ INTEREST
All employees are bound by the Code of Conduct of BNP Paribas Group, which
imposes obligations to work in clients’ best interests by: providing clients with the most suitable products and services, withregard to their aims, resources, knowledge and experience;

requested, an opinion, in particular relating to expected performance,
associated risks and pricing; treating clients fairly, without giving any client (or other counterparty)
unduly preferential treatment; behave transparently, notably by making available, at the client’s request,
any information relating to the execution of its transactions.

Senior Management of BNPP AM has embedded a culture throughout theBusiness Line where clients’ interests must be given priority such that no client
will be disadvantaged.

CONFLICTS REGISTERA mapping exercise to identify potential conflicts of interest is conductedperiodically by the BNPP Group, the results of which have been used to createa Conflicts Register for BNPP AM which is maintained by Compliance. This
Register contains details of actual or potential conflicts that may arise between
BNPP AM and its clients (or between clients of BNPP AM) and is an essential
tool for the management of actual or potential conflicts of interest. It is theresponsibility of each employee to ensure that Compliance is notified
immediately of any actual or potential conflict so that it is: managed appropriately; and recorded in the Register.

EMPLOYEE AWARENESS
Employees are reminded of applicable policies and procedures during training
sessions and by the frequent distribution of relevant regulatory actions. In
addition there is a requirement to review/update the procedures in place(including those relating to conflicts management) as the need occurs and as
a matter of policy.

SENIOR MANAGEMENT
Senior management must receive on a frequent basis – and at least annually– written reports on the situations contained in the conflicts of interest records.
Moreover, senior managers must take appropriate steps in their oversight ofthe business and are required to demonstrate their accountability: this mustalso include conflicts of interest management.