Nuveen Compliance |  9 August 2021 Code of Ethics SUMMARY AND SCOPE What the Code is about Helping to ensure that Nuveen personnel place the interests of  Nuveen clients ahead of their own personal interests. Who the Code applies to and what the  implications are This Code applies to individuals in the following categories: • Nuveen Employees based in the US or Canada (except  employees of Gresham Investment Management LLC,  Westchester Group Investment Management, Inc., and any  employees of Greenwood Resources, Inc. who are based  outside of Portland, Oregon). • Employees of any US-registered investment adviser who  are based outside the US, except Gresham Investment  Management LLC and Greenwood Resources, Inc. • Consultants, interns, and temporary workers based in the  US or Canada whose contract length is 90 days or more,  unless the Nuveen Ethics Office determines otherwise. TIAA employees designated as Access Persons by the TIAA- CREF Funds Chief Compliance Officer or the Nuveen Ethics  Office are subject to the TIAA Corporate Code of Ethics with  the same restrictions and requirements as this Code. Independent directors and trustees of the TIAA-CREF Funds  Complex and Nuveen-sponsored or -branded funds have their  own Code of Ethics and are not subject to this one. For individuals who are subject to the Code, there are two  designations with different implications: Access Person and  Investment Person. ACCESS PERSON All Nuveen Employees who are subject to the Code are  considered Access Persons, since they have, or could have,  access to non-public information about securities transactions  and other investments, holdings, or recommendations for  Affiliate-Advised Accounts or Portfolios. Key characteristics of this designation. An individual  may be considered an Access Person of multiple advisers  affiliated with Nuveen, or of only one. If your regular duties  give you access to non-public information, or you are an officer  of a Nuveen or TIAA-CREF sponsored or branded fund, your  personal trading is generally monitored only against the  trading activity of the specific adviser(s) or Affiliated Funds  with which you are involved. For other employees, personal  trading is typically monitored against the trading activities  of all advisers affiliated with Nuveen. You will generally not  be permitted to execute transactions in a security on any day  when an Affiliate-Advised Account or Portfolio managed by the  adviser(s) that you are monitored against has a pending buy or  sell order for that security. INVESTMENT PERSON An Access Person who meets any of the following criteria will  in addition be considered an Investment Person: • The Access Person is a Portfolio Manager, Research Analyst  or Research Assistant, or they otherwise participate in  making recommendations or decisions concerning the  purchase or sale of securities in any Affiliate-Advised  Account or Portfolio. • The Access Person has been designated an Investment  Person by the affiliate Chief Compliance Officer or the  Nuveen Ethics Office. Key characteristics of this designation. The vast  majority of Investment Persons are employees of Nuveen’s  affiliated investment advisers. An Investment Person is prohibited from transacting  in securities during the period starting 7 calendar days  before, and ending 7 calendar days after, any trade in an  Affiliate-Advised Account or Portfolio for which he/she has  responsibility. In addition, an Investment Person’s personal  transactions will be reviewed for conflicts in the period  starting 7 calendar days before, and ending 7 calendar days  after, all trades by their associated investment adviser(s). In  some cases, the Investment Person may be required to reverse  a trade and/or forfeit an appropriate portion of any profit as  determined by the Nuveen Ethics Office. These consequences  can apply whether or not the trade was pre-cleared. The personal trading of Investment Persons is generally only  monitored against the trading activity of the specific adviser(s)  for which they have been designated an Investment Person. WHO TO CONTACT Nuveen Ethics Office (Americas)  Hotline: 1 800 842 2733 extension 22-5599   nuveenethicsoffice@nuveen.com
 Code of Ethics Page 2 of 8 Important to understand Some of our affiliated investment advisers may  have supplemental policies of their own that impose  additional rules on the same topics covered in this  Code. Check with your manager or local/designated Chief  Compliance Officer if you have questions. Personal trading is a privilege, not a right. Nuveen  Employees are expected to follow the law and adhere to the  highest standards of behavior—including with respect to  personal trading. Any violation of the Code could have severe  adverse effects on you, your co-workers, and Nuveen. You may  be held personally liable for your conduct and be subject to  fines, regulatory sanctions, and even criminal penalties. Because Nuveen can restrict your trading or take actions such  as forcing you to hold a position or to disgorge profits, personal  trading carries risks beyond normal market risks. Some requirements in this Code apply to Household  Members. Each Household Member (see “Terms with Special  Meanings” at right) is subject to the same personal trading  restrictions and requirements that apply to his/her related  Nuveen Employee. The Code does not address every ethical issue that  might arise. If you have any doubt at all after consulting the  Code, contact the Nuveen Ethics Office for direction. The Code applies to appearance as well as substance.  Always consider how any action might appear to an outside  observer (such as a client or regulator). You are expected to follow the Code both in letter  and in spirit. Literal compliance, such as pre-clearing a  transaction, does not necessarily protect you from liability  for conduct that violates the spirit of the Code. If you have  questions about how to comply with this Code, consult the  Nuveen Ethics Office. TERMS WITH SPECIAL MEANINGS  Within this policy, these terms are defined as follows: Affiliate-Advised Account or Portfolio  Any  Affiliated Fund, or any portfolio or client account advised  or sub-advised by Nuveen. Affiliated Fund  Any TIAA-CREF or Nuveen branded or  sponsored open-end fund, closed-end fund, or Exchange  Traded Fund (ETF), and any third-party fund advised or  sub-advised by Nuveen. Automatic Investment Plan  Any program, such  as a dividend reinvestment plan (DRIP), under which  investment account purchases or withdrawals occur  according to a predetermined schedule and allocation. Beneficial Ownership  Any interest by which you or  any Household Member—directly or indirectly—derives   a monetary benefit from purchasing, selling, or owning a  security or account, or exercises investment discretion. You have Beneficial Ownership of securities held  in accounts in your own name, or any Household  Member’s name, and in all other accounts over which  you or any Household Member exercises or may  exercise investment decision-making powers, or other  influence or control, including trust, partnership, estate,  and corporate accounts or other joint ownership or  pooling arrangements. Code  This Code of Ethics. Domestic Partner  An individual who is neither a  relative of or legally married to a Nuveen Employee, but  shares a residence and is in a mutual commitment similar  to marriage with such Nuveen Employee. Federal Securities Laws  The applicable portions of  any of the following laws, as amended, and of any rules  adopted under them by the Securities and Exchange  Commission or the Department of the Treasury: • Securities Act of 1933. • Securities Exchange Act of 1934. • Investment Company Act of 1940. • Investment Advisers Act of 1940. • Sarbanes-Oxley Act of 2002. • Title V of the Gramm-Leach-Bliley Act. • The Bank Secrecy Act. Household Member  Any of the following who reside,  or are expected to reside for at least 90 days a year, in the  same household as a Nuveen Employee: • Spouse or Domestic Partner. • Sibling. • Child, stepchild, grandchild. • Parent, stepparent, grandparent. • In-laws (mother, father, son, daughter, brother, sister). Independent Director  Any director or trustee of  an Affiliated Fund who is not an “interested person”  within the meaning of Section 2(a)(19) of the Investment  Company Act of 1940, as amended. Managed Account  Any account, including robo- advised accounts, in which you or a Household Member  has Beneficial Ownership and for which you have  delegated full investment discretion in writing to a third-  party broker or investment manager.
 Code of Ethics Page 3 of 8 TERMS WITH SPECIAL MEANINGS (continued) Nuveen  Nuveen, LLC and all of its direct or indirect  subsidiaries worldwide. Nuveen Employee  Any full- or part-time employee of  Nuveen, and any consultants, interns or temporary workers  designated by the Nuveen Ethics Office. Private Placement  Any offering exempt from registration  under the Securities Act of 1933, such as a private equity  investment, hedge fund, or limited partnership. A private  investment in public equity (PIPE) is also considered a  Private Placement. Reportable Account  Any account for which you or  a Household Member has Beneficial Ownership AND  in which securities can be bought, sold or held. This  includes, among others: • All brokerage, IRA, custodial and trust accounts. • All Managed Accounts. • All 529 College Savings Plan accounts. • Any TIAA 401(k) plan account. • Any 401(k) plan account from a previous employer that  permits transactions in any Reportable Security. • Any direct holding in an Affiliated Fund. • Any health savings account (HSA) that permits the  purchase of any security. • Any employee stock purchase plan (ESPP) or employee  stock ownership plan (ESOP). The following are NOT considered Reportable Accounts: • Charitable giving accounts. • Any 401(k) plan account or any other account held  directly with a mutual fund complex or mutual fund-only  platform in which open-end, non-Affiliated Funds are the  only possible investment. • Any cash management account with a broker in which a  security cannot be purchased or sold. • Any accounts that can invest only in cryptocurrency such  as Bitcoin or Ethereum.  Reportable Security  Any security EXCEPT: • Direct obligations of the US government (indirect  obligations, such as Fannie Mae and Freddie Mac  securities, are reportable). • Certificates of deposit, bankers’ acceptances, commercial  paper, and high quality short-term debt (including  repurchase agreements). • Money market funds. • Open-end funds that are not Affiliated Funds. • Note that closed-end funds are Reportable Securities. Reportable Transaction  Any transaction involving a  Reportable Security EXCEPT: • Transactions in Managed Accounts. Section 16 Persons:  Transactions involving Nuveen closed-end funds in any of  your Managed Accounts are reportable. • Transactions under an Automatic Investment Plan; note  that transactions that override the pre-set schedule or  allocation are reportable. • Dividends. • Interest Accrued. Section 16 Person  Section 16 of the Exchange Act and   the rules thereunder impose certain obligations on persons  specified in section 30(h) of the Investment Company Act of  1940, as well as insiders of any public company that trades  on a national stock exchange (such as a Nuveen closed-end  fund). For purposes of Section 16, an “insider” is: • A director of a public company. • A designated officer of a public company. • A person who beneficially owns 10% or more of any class  of equity security that is registered under Section 12 of  the Exchange Act. • A portfolio manager of a Nuveen closed-end fund. Persons subject to Section 16 include portfolio managers of  the Nuveen closed-end funds. GENERAL RESTRICTIONS AND REQUIREMENTS BASIC PRINCIPLES 1. Never abuse a client’s trust, rights, or interests. This means you must never do any of the following: • Engage in any plan or action, or use any device, that  would defraud or deceive a client. • Make any material statements of fact that are incorrect  or misleading, either as to what they include or omit. • Engage in any manipulative practice. • Use your position (including any knowledge or access to  opportunities you have gained by virtue of your position)  to personal advantage or to a client’s disadvantage. This  would include, for example, front- running or tailgating  (trading directly before or after the execution of a large  client trade order), or any attempt to influence a client’s  trading to enhance the value of your personal holdings. • Conduct personal trading in any way that could be  inconsistent with your fiduciary duties to a client (even if  it does not technically violate the Code). 2. Handle conflicts of interest appropriately. This  applies not only to actual conflicts of interest, but also to  any situation that might appear to an outside observer to be  improper or a breach of fiduciary duty. 3. Keep confidential information confidential. Always  properly safeguard any confidential information you obtain  in the course of your work. This includes confidential  information related to any of the following: •  Any Affiliate-Advised Account or Portfolio and any other  financial product offered or serviced by Nuveen.
 Code of Ethics Page 4 of 8 • New products, product changes, or business initiatives. • Past, current, and prospective clients, including their  identities, investments, and account activity. “Keeping information confidential” means using  discretion in disclosing information as well as guarding  against unlawful or inappropriate access by others.  This includes: •  Making sure no confidential information is visible on  your computer screen and desk when you are not there. • Not sharing passwords with others. • Using caution when discussing business in any  location where your conversation could be overheard.  Confidential information may be released only as  required by law or as permitted under the applicable  privacy policy(ies). Consult the Nuveen Ethics Office  or your local/designated CCO before releasing any  confidential information. 4. Handle Material Non-Public Information properly.  Follow all of the terms described in “Material Non-Public  Information” below. Be aware that any failure to handle  such information properly is a serious offense and may lead  to disciplinary action from Nuveen as well as serious civil or  criminal liability. 5. Comply with Federal Securities Laws. Any violation  of these laws is punishable as a violation of the Code. 6. Never do anything indirectly that, if done directly,  would violate the Code. Such actions will be considered  the equivalent of direct Code violations. 7. Promptly alert the Nuveen Ethics Office or your  local/designated CCO of any actual or suspected  wrongdoing. Examples of wrongdoing include violations  of the Federal Securities Laws, misuse of corporate assets,  misuse of confidential information, or other violations of  the Code. If you prefer to report confidentially, call the  TIAA Confidential Helpline at 1-877-774-6492. Note that  failure to report suspected wrongdoing in a timely fashion  is itself a violation of the Code. PRE-CLEARANCE AND  HOLDING REQUIREMENTS 8. Pre-clear any trade in Reportable Securities,  including certain Affiliated Funds (see box on next  page for additional information). If your trade requires pre-clearance, request approval  through the Protegent PTA system (PTA) before you or  any Household Member places an order to buy or sell any  Reportable Security. Any approval you receive expires at  the end of the day it was granted; however, you may place  after-hours trades in international markets until 11:59 PM  local time on that day. When requesting pre-clearance,  follow this process: • Request pre-clearance on the same day you want to  trade, during standard US trading hours (9:30 AM to  4:00 PM ET). Be sure your pre-clearance request is  accurate as to security and direction of trade. • Wait for approval to be displayed before trading. If you  receive approval, you may only trade that same day, and  only within the scope of approval. If you do not receive  approval, do not trade. • Place day orders only. Do not place good-till-canceled  orders or limit orders that expire beyond the day of  pre-clearance approval. You may place orders for an  after-hours trading session or in foreign markets using  that day’s pre-clearance approval, but you must not place  any order that could remain open into the next day’s  trading session. 9. Hold positions in securities that are subject to pre- clearance for 60 calendar days, or be prepared to  forfeit any gains. Several things to note: • You may be required to surrender any gains realized (net  of commissions) through a violation of this rule. • The 60-day holding requirement is tested on a last-  in-first-out basis, across all of your holdings (not just  within individual accounts). • The 60-day holding requirement extends to any options  or other transactions that may have the same effect  as a purchase or sale, and to all Reportable Securities  except Exchange Traded Funds (ETFs), Exchange  Traded Notes (ETNs), Unit Investment Trusts (UITs),  and open-end Affiliated Funds. Nuveen-branded or  sponsored closed-end funds are subject to the 60-day  holding requirement. • You may sell the security on the 60th day after purchase,  provided you obtain pre-clearance or an approved  exemption applies. • You may re-purchase a security immediately after  executing a sale of that same security, which will trigger  a new 60 calendar day holding period. • You may close a position at a loss at any time provided   pre-clearance approval has been obtained, or an  approved exemption applies. If your pre-clearance has  been denied, it is advisable that you contact the Nuveen  Ethics Office if you are seeking to sell at a loss within 60  days of your purchase. 10. Comply with trading restrictions described in the  prospectuses for all Affiliated Funds. This includes  restrictions on frequent trading in shares of any open-end  Affiliated Fund. 11. Pre-clear any transaction in a Managed Account  that involves your influence. You must also  immediately consult with the Nuveen Ethics Office to  discuss whether the account in question can properly  remain classified as a Managed Account.
 Code of Ethics Page 5 of 8 12. Obtain the required approvals before any  transaction in a Private Placement, including  PIPEs. Participation and approval for all transactions in  Private Placements advised or sub-advised by Nuveen, is  facilitated by the Nuveen Employee Investment Program  (NuveenEIP@nuveen.com).   For all other Private Placements, you must obtain approval  for initial and subsequent commitments to invest but not  sales/redemptions. Be aware that sales/redemptions are  Reportable Transactions. Approval is required even if the  investment is made in a Managed Account. WHAT NEEDS TO BE PRE-CLEARED  Pre-clearance required • All actively initiated trades in Reportable  Securities, except those listed here under “No pre-  clearance required.” • The sale of restricted stock or employee stock options  accrued during prior employment or a Household  Member’s employment require pre-clearance. If pre-  clearance is denied, you may contact the Nuveen Ethics  Office to request reconsideration. Be aware that pre-clearance can be withdrawn even after  it has been granted, and even after you have traded, if  Nuveen later becomes aware of Affiliate-Advised Account  or Portfolio trades whose existence would have resulted in  denial of pre-clearance. In these cases you may be required  to reverse a trade and/or forfeit an appropriate portion of  any profit, as determined by the Nuveen Ethics Office. Be aware that trades initiated by a broker to address the  financial standing of an account can result in violations  and will generally not be protected by the Code’s “actively  initiated trade” language for trades requiring pre- clearances. Example include, but are not limited to, brokers  initiating trades in margin accounts, brokers initiating  trades to cover account fees, and brokers initiating  trades to remediate a minimum or negative cash balance  in an account. Pre-clearance not required • Shares of any open-end mutual fund (including  Affiliated Funds). • ETFs, ETNs, UITs (including options on ETFs and ETNs). • CDs and commercial paper. • Securities acquired or disposed of through actions  outside your control or issued pro rata to all holders of  the same class of investment, such as automatic dividend  reinvestments, stock splits, mergers, spin-offs, or rights  subscriptions. • The automatic exercise or liquidation by an exchange of a  derivative instrument upon expiration or the delivery of  securities pursuant to a written option that is exercised  against you, and the assignment of options. • Sales pursuant to a bona fide tender offer. • Trades made through an Automatic Investment  Plan that have been disclosed to the Nuveen Ethics  Office in advance. • Trades in a Managed Account (except that you must  pre-clear any trades that involve your influence, any  initial purchases of Private Placements, purchases in  any equity IPO, and any sales or redemptions of Private  Placements that are branded, sponsored, advised or sub- advised by Nuveen). • Foreign currencies, including futures. • Commodity instruments. • Index options and index futures. • Direct investments in cryptocurrencies. • Crypto instruments that are comprised of and invest solely in  cryptocurrencies. OTHER RESTRICTIONS 13. Never knowingly trade any security being traded  or considered for trade by any Affiliate-Advised  Account or Portfolio. This applies to employee  transactions in securities that are exempt from pre- clearance, and includes equivalent or related securities. For example, if a company’s common stock is being  traded, you may face restrictions on trading any of  the company’s debt, preferred, or foreign equivalent  securities, and from trading or exercising any options  based on the company’s securities. 14. Always prioritize client trades over personal  trades. Your fiduciary duties to the client are far  more important than your personal trading, which  is a privilege and not a right. Never delay or in any  way alter the timing or terms of a client trade for your  personal benefit. 15. Do not engage in trading that involves single  stock futures. 16. Do not engage in uncovered short sales of  individual securities. 17. You may trade options on individual securities,  subject to the 60-day holding period. Options  traded must have an expiration of at least 60 days from  the date that you enter into the contract. You are not  permitted to close an option at a profit within 60 days of  having entered into the contract. The option contract can  be closed in less than 60 days at a loss, provided pre- clearance approval has been obtained. 18. Never participate in an investment club or  similar entity.
 Code of Ethics Page 6 of 8 19. Do not engage in excessive or inappropriate  trading activity. Never let personal trading  interfere with your professional duties. The  Nuveen Ethics Office and/or your local/designated CCO,  in consultation with your manager, will determine what  constitutes excessive or inappropriate trading. 20. Pre-clear the sale of securities in a margin  account. Margin accounts are permitted, however you  must obtain pre-clearance when selling to meet a margin  call, even if the transaction is initiated by a broker. 21. Never purchase an IPO without advance  approval. This includes Managed Accounts. Equity IPO  participation is generally prohibited but approval may be  granted in special circumstances, such as when: • You already have equity in the company and are  offered shares. • You are a policy holder or depositor in a company that  is demutualizing. • A Household Member has been offered  shares  as an employee. Purchases of initial offerings of SPACs, fixed income  securities, convertible securities, preferred securities,  open- and closed-end funds, commodity pools, and  secondary equity offerings are generally permitted subject  to prior approval from the Nuveen Ethics Office. MATERIAL NON-PUBLIC INFORMATION  What is Material Non-Public Information? Material Non-Public Information is defined as information  regarding any security, securities-based derivatives or  issuer of a security that is both material and non-public.  Information is material if both of the following are true: • A reasonable investor would likely consider it important  when making an investment decision. • Public release of the information would likely affect the  price of a security. Information is generally non-public if it has not been  distributed through a widely used public medium, such  as a press release or a report, filing or other periodic  communication. Restrictions and requirements • Any time you think you might have, or may be about to,  come into possession of Material Non-Public Information  (whether in connection with your position at Nuveen or  not), alert the Nuveen Ethics Office. Alternatively, you  may alert your local/designated CCO or Legal office, who  in turn must promptly notify the Nuveen Ethics Office.  Follow the instructions you are given. • Until you receive further instructions from the Nuveen  Ethics Office, your local/designated CCO, or Legal, do not  take any action in relation to the information, including  trading or recommending the relevant securities or  communicating the information to anyone else. • Never make decisions on your own regarding potential  Material Non-Public Information, including whether such  information is actually Material Non-Public Information or  what steps should be taken. • If the Nuveen Ethics Office, your local/designated CCO  and/or Legal determine that you have Material Non-  Public Information:  – Do not buy, sell, gift, or otherwise dispose of the issuer’s  securities, whether on behalf of an Affiliate-Advised  Account or Portfolio, yourself, or anyone else.  – Do not in any way recommend, encourage, or influence  others to transact in the issuer’s securities, even if you do  not specifically disclose or reference the Material Non-  Public Information.  – Do not communicate the Material Non-Public  Information to anyone, whether inside or outside Nuveen,  except in discussions with the Nuveen Ethics Office and  Legal and as expressly permitted by any confidentiality  agreement or supplemental policies and procedures of  your business unit. • Please refer to Nuveen’s Material Non-Public Information  and Insider Trading Policy for detailed information. REPORTING REQUIREMENTS  UPON BECOMING A NUVEEN EMPLOYEE 22. Within 10 calendar days of starting at Nuveen,  acknowledge receipt of the Code. This includes  certifying that you have read the Code, understand it,  recognize that you are subject to it, have complied with  all of its applicable requirements, and have submitted all  Code-required reports. 23. Within 10 calendar days of starting at Nuveen,  use PTA to report all of your Reportable  Accounts and holdings in Reportable Securities. For each Reportable Account that permits the purchase of  Reportable Securities, upload the most recent statement,  making sure that it includes information about the broker,  dealer, or bank through which the account is held and the
 Code of Ethics Page 7 of 8 type of account. For each Reportable Security, provide  the security name and type, a ticker symbol or CUSIP, the  number of shares or units held, and the principal amount  (dollar value). This information must be no older than 45 calendar days  before your first day of employment. Note that there are separate procedures for Managed  Accounts, as described below in item 24. Within 10  calendar days of starting at Nuveen, report  all current investments in Private Placements  (limited offerings). Limited offerings are  Reportable Securities. 24. Within 30 calendar days of starting at Nuveen,  move or close any Reportable Account that is  not at an approved firm. This does not include  Reportable Accounts that are 401(k), HSA, ESPP/ESOP,  or 529 plans. Accounts held directly with a mutual fund  complex or mutual fund only platform in which open-end  non- Affiliated Funds are the only possible investment  are not reportable. Contact the Nuveen Ethics Office  if you are unsure whether your account must be held  with an approved firm. The list of approved firms is  maintained by the Nuveen Ethics Office and may be  accessed on PTA. Under very limited circumstances, it may be possible to  obtain a waiver to keep a Reportable Account at a non-  approved firm. Examples include: • An account owned by a Household Member who works  at another financial firm with comparable restrictions. • An account that holds securities that cannot  be transferred. • An account that cannot be moved because of a  trust agreement. To apply for an exception, contact the Nuveen Ethics  Office. For any account granted an exception, you are  required to upload statements for the account in PTA  based on the frequency with which a statement is  generated for the account (e.g. monthly, quarterly). In all  cases, if your accounts are not held at an approved firm,  you must manually enter all Reportable Transactions in  PTA within 5 days of execution. Consultants and temporary workers are generally not  required to move or close Reportable Accounts. 25. Within 30 calendar days of starting at Nuveen,  seek approval to liquidate any securities held  prior to starting at Nuveen that you do not wish  to continue to hold. If you wish to liquidate securities  that you held prior to joining Nuveen, seek approval by  contacting the Nuveen Ethics Office within 30 calendar  days of starting at Nuveen. If you do not liquidate  securities during this time, you will generally forfeit this  consideration for liquidation. WHEN OPENING ANY MANAGED ACCOUNT 26. Get pre-approval for any new Managed Account  before any trading activity commences and report  the account within 10 calendar days of the date you or  a Household Member opens the account or an account  becomes a Reportable Account through marriage,  cohabitation, divorce, death, or another event. Using  the appropriate form which may be accessed in PTA,  provide representations that support the classification of  the account as a Managed Account. For an account to be  classified as a Managed Account, the account owner must  have no direct or indirect influence or control over the  securities in the account. The form must be signed by the  account’s broker or investment manager and by all account  owners. You may be asked periodically to confirm these  representations or submit an updated form to confirm such. Note that upon request, you are also responsible for  providing duplicate statements for the Managed Account  to the Ethics Office WHEN OPENING ANY NEW  REPORTABLE ACCOUNT  27. Report any new Reportable Account, including  Managed Accounts. Do this in PTA within 10 calendar days  of the date you or a Household member opens the account  or an account becomes a Reportable Account through  marriage, cohabitation, divorce, death, or another event.  EVERY QUARTER 28. Within 30 calendar days of the end of each  calendar quarter, verify in PTA that all  Reportable Transactions made during that  quarter have been reported. PTA will display  all transactions of yours for which it has received  notice (except transactions in your TIAA pension and  retirement plan accounts, which you are not required  to report because the firm accesses this information  directly). For any other Reportable Transactions not  displayed, or displayed inaccurately, you are responsible  for making any necessary revisions in PTA prior to  completing your certification. 29. For each Reportable Transaction, you must provide,  as applicable, the transaction date, security name and  type, ticker symbol or CUSIP, interest rate (coupon)  and maturity date, number of shares, price at which the  transaction was effected, principal amount (dollar value),  the nature of the trade (buy or sell), and the name of the  broker, dealer, or bank that effected the transaction. It  is very important that you carefully review and verify  the transactions and related details displayed on PTA,  checking for accuracy and completeness. Once again, if  you find any errors or omissions, correct or add to your  list of transactions in PTA.
 Code of Ethics Page 8 of 8 EVERY YEAR 30. Within 45 calendar days of the end of each  calendar year, acknowledge receipt of the most  recent version of the Code and certify in PTA as  to your annual Reportable Security holdings and  Reportable Accounts. The reporting must contain the information described  in item 23 above, and include your certification that you  have reported all Reportable Accounts, and all holdings  in Reportable Securities at year end. You are responsible  for ensuring that all of your Reportable Accounts have  been accurately reported in PTA. If any of your holdings  in Reportable Securities are not displayed in PTA or are  displayed inaccurately, you are responsible for entering  adjustments and trade confirms or making any necessary  revisions in PTA to complete your certification. In addition, you must affirm each year through PTA that  each Managed Account is properly classified as a Managed  Account, for yourself and on behalf of any Household  Member. This separate certification does not require  broker or investment manager involvement. You also must acknowledge any amendments to the Code  that occur during the course of the year. ADDITIONAL RULES FOR  SECTION 16 PERSONS • Pre-clear (through PTA) any transactions in Nuveen  closed-end funds and any other closed-end funds of  which you are a Section 16 Person. Your request will be  reviewed by Legal. • Pre-clear buy/sell transactions involving any Nuveen  closed-end funds within your Managed Account(s). • When selling for a gain any securities you buy that are  issued by the entity of which you are a Section 16 Person,  make sure it is at least 6 months after your most recent  purchase of that security. This rule extends to any  options or other transactions that may have the same  effect as a purchase or sale, and is tested on a last-in-  first-out basis. You may be required to surrender any  gains realized through a violation of this rule. Note that  for any fund of which you are a Section 16 Person, no  exception from pre-clearance is available. • Promptly email details of all executed transactions in  these securities to the appropriate contact in Legal. • See the Nuveen Funds Section 16 Policy and Procedures  for additional information. If you are unsure whether you are a Section 16 Person,  contact Legal or the Nuveen Ethics Office. CODE ADMINISTRATION Training You will be required to participate in training on the Code  when joining Nuveen as well as periodically during the  time you are subject to the Code. Exceptions The Code exists to prevent violations of law. The Nuveen  Ethics Office may, under certain circumstances, grant  waivers from a Code requirement. No waivers or exceptions  that would violate any law will be granted. Monitoring The Nuveen Ethics Office is responsible for monitoring  accounts, transactions, holdings and certifications for any  violations of this Code. Consequences of violation Any individual who violates the Code is subject to penalty.  Penalties could include, among other possibilities, a written  warning, restriction of trading privileges, unwinding or  reversing trades, disgorgement of trading profits, fines, and  suspension or termination of employment. Applicable rules The Code has been adopted in recognition of Nuveen’s  fiduciary obligations to clients and in accordance with  various provisions of Rule 204A-1 under the Investment  Advisers Act of 1940 and Rule 17j-1 under the Investment  Company Act of 1940. This Code is also adopted by the  Affiliated Funds advised by Nuveen Fund Advisors, LLC,  TIAA-CREF Investment Management, LLC and Teachers  Advisors, LLC under Rule 17j-1. Some elements of the Code also constitute part of Nuveen’s  response to Financial Industry Regulatory Authority  (FINRA) requirements that apply to registered personnel of  Nuveen Securities, LLC.