Sponsor 
Guggenheim Partners Investment Management, LLC 
Chief Compliance Officer 
Owner 
GPIM Director of Policies & Procedures 
Contact 
Arik.Hirschfeld@GuggenheimPartners.com 
Effective Date 
February 1, 2018 
Code of Ethics 
Guggenheim Partners Investment Management, LLC 
Exhibit 14.2
 Table of Contents 
1. Objectives of the Code of Ethics .................................................................................................... 4 
2. Who is Subject to the Code? .......................................................................................................... 4 
3. Who Administers the Code? ........................................................................................................... 5 
3.1. Chief Compliance Officer ..................................................................................................... 5 
3.2. Code of Ethics Compliance Platform ................................................................................... 6 
4. Fiduciary Duty to Clients ................................................................................................................. 7 
4.1. Managing Conflicts ............................................................................................................... 7 
4.2. Confidentiality and Safeguarding Information ...................................................................... 7 
4.3. Prohibition on Front Running ............................................................................................... 7 
4.4. Compliance with the Code of Ethics .................................................................................... 7 
5. Reporting of Personal Trading ........................................................................................................ 8 
5.1. Which Investment Accounts Do Access Persons Need to Report? ..................................... 8 
5.2. Required Initial Holdings Reports and Certifications ............................................................ 9 
5.3. Required Quarterly Transaction Reports ............................................................................. 10 
5.4. Annual Holdings Reports and Certifications ........................................................................ 12 
5.5. New Investment Accounts .................................................................................................... 12 
6. Pre-clearance for Personal Trading ................................................................................................ 12 
6.1. Trades Requiring Pre-Clearance ......................................................................................... 13 
6.2. Trades Not Requiring Pre-Clearance ................................................................................... 13 
6.3. Prohibited Transactions ....................................................................................................... 14 
7. Trading Restrictions ........................................................................................................................ 14 
7.1. For All Trading ...................................................................................................................... 14 
7.2. Excessive Trading in Reportable Accounts ......................................................................... 15 
7.3. Holding Periods .................................................................................................................... 15 
8. Annual Review ................................................................................................................................ 16 
9. Retention of Records ...................................................................................................................... 16 
10. Sanctions ........................................................................................................................................ 16 
11. Interpretations and Exceptions ....................................................................................................... 17 
12. Supplement 1 – Transactions in Closed End Funds (“CEFs”) Advised or Sub-Advised by the 
Advisor ............................................................................................................................................ 18 
13. Supplement 2 – Transactions in Exchange Traded Funds (“ETFs”) Advised or Sub-Advised by the 
Advisor and Securities Traded by Such Funds .............................................................................. 20
 14. Supplement 3 – Transactions in Unit Investment Trusts (“UITs”) for Which the Advisor Assists with 
the Selection of Securities Traded by Such Trusts ........................................................................ 21
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1. Objectives of the Code of Ethics  
Guggenheim Partners Investment Management, LLC (“GPIM” or the “Advisor”), its subsidiaries and 
affiliated investment advisers are committed to conducting our investment advisory business with 
the highest legal and ethical standards. We aim to uphold our reputation of integrity and 
professionalism in the furtherance of the interests of our clients and in a manner that is consistent 
with all applicable laws, rules and regulations. This reputation is a vital business asset and has 
generated the trust and confidence of GPIM’s clients. 
Accordingly, the Advisor has adopted this Code of Ethics (the “Code”) to effectuate the purposes 
and objectives of Rule 204A-1 of the Investment Advisers Act of 1940, as amended (the “Advisers 
Act”) and in accordance with industry best practices. All persons associated with the Advisor are 
responsible for knowing and understanding the policies and guidelines contained in the Code. Our 
conduct should reflect GPIM’s values, demonstrate ethical leadership, and promote a work 
environment that upholds our reputation for integrity, ethical conduct and trust. The Code sets forth 
the general principles and standards of conduct expected from you. It cannot and is not intended to 
cover every scenario or circumstances under which you may face business and personal conflicts. 
Technical compliance is not enough and you are expected to comply with the spirit of the Code. 
Compliance monitors, surveils and escalates to the business when appropriate. The GPIM 
Chief Compliance Officer (“CCO”) and GPIM Compliance Department should be contacted 
for advice and recommendations as to compliance with regulatory requirements, this Code 
and together with the GPIM Compliance Manual (“Manual”), the Compliance Program. 
However, the business has primary authority and control over the investment activities and 
operation of GPIM and for managing employees. Access Persons should contact 
Guggenheim Partners’ Central Compliance Department (“Central Compliance”) with any 
questions on employee trading and activities. 
If you have any questions, please speak to a member of the GPIM Compliance Department.  
2. Who is Subject to the Code? 
As a condition of employment, all individual employees, officers, principals, partners and directors 
of GPIM (generally referred to as “Employees”) are required to comply with the Code. In addition, 
the following categories of persons are considered to be Access Persons and are required to 
comply with the Code together with Employees. “Access Person”1 includes any: 
a. Employee, Director, officer, manager, principal and partner of the Advisor (or other persons 
occupying a similar status or performing similar functions), or other person who provides advice 
on behalf of the Advisor or is subject to the Advisor’s supervision and control;  
b. Any person who: 
                                                     
1 This includes any arrangement where the Access Person serves as an agent, executor, trustee or in another capacity.
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i. Has access to nonpublic information regarding any of the Advisor’s client’s purchase or 
sale of securities, or nonpublic information regarding the portfolio holdings of any client 
account the Advisor or their affiliates manage, or any fund which is advised or sub-
 advised by the Advisor (or certain affiliates, where applicable); 
ii. Makes recommendations or investment decisions on behalf of the Advisor; 
iii. Has the power to exercise a controlling influence over the management and policies of 
the Advisor, or over investment decisions, who obtains information concerning 
recommendations made to a client account with regard to the purchase or sale of a 
security;  
iv. The CCO shall determine on a case-by-case basis whether a temporary employee (e.g., 
consultant or intern) should be considered an Access Person. Such determination shall 
be made based upon an application of the criteria provided above, whether an 
appropriate confidentiality agreement is in place, and such other information as may be 
necessary to ensure that proprietary information is protected. As such, temporary 
employees may only be subject to certain sections of the Code, such as certifying to it, or 
may be exempt from certain reporting requirements such as not having to hold their 
reportable accounts at the permitted broker-dealers; or 
v. Any person deemed to be an Access Person by the CCO. 
3. Who Administers the Code? 
3.1. Chief Compliance Officer 
3.1.1. Responsibilities 
The Advisor’s Compliance Department (the “GPIM Compliance Department”) is 
responsible for administering the Code of Ethics under the auspices and 
responsibility of the CCO and the Advisor’s senior management. The CCO will 
delegate appropriate responsibilities to designated members of the GPIM 
Compliance Department. Central Compliance administers certain sections of the 
Code of Ethics pertaining to Employee activities. 
3.1.2. Reporting of Violations 
If an Access Person becomes aware of a violation of this Code, the Access Person 
has an obligation to report the matter promptly to the CCO. Nothing in this policy 
prohibits an Access Person from contacting a securities regulator. 
3.1.3. Review of Violations 
The GPIM Compliance Department will review all violations of the Code and oversee 
any appropriate investigation and subsequent response. As the designee of senior 
management, the CCO shall have the right to make final and binding interpretations
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of the Code and may grant, using his/her discretion, exceptions to certain of the 
Code’s requirements and restrictions.  
 No Employee, who in good faith reports a violation of this Code, shall suffer 
harassment, retaliation or with respect to a report concerning a violation by 
another Employee, adverse employment consequences.  
  An Employee who retaliates against someone who has reported a violation in 
good faith may be subject to disciplinary action. Alternatively, the Advisor will 
treat any malicious or knowingly false report of a violation to be a serious offense 
and may discipline the Employee making such a report.  
3.1.4. Review of CCO Compliance with Code 
A member of senior management of the Advisor or any other person designated 
(e.g., a member of the Legal Department or the Global Head of Compliance or his 
designee), who may or may not be an Employee of the Advisor, is responsible for 
reviewing the CCO’s personal trading reports and Code certifications required under 
the Code. If the CCO is in violation of the Code, senior management will impose the 
appropriate sanction(s). 
3.1.5. Employee Cooperation 
Employees are encouraged to share questions, concerns, suggestions or complaints 
with the GPIM Compliance Department. Reports of violations or suspected violations 
will be kept confidential to the extent possible, but consistent with the need to 
conduct an adequate investigation. 
3.2. Code of Ethics Compliance Platform 
3.2.1. Use of Compliance Platform 
The Advisor utilizes an electronic Compliance Platform, to manage the Code’s 
reporting and certification obligations. Access Persons are required to use the 
Compliance Platform, to the extent practical. 
 Code reporting requirements are to be completed through the Compliance 
Platform (including certifications, personal securities transactions covered by the 
Code, disciplinary disclosures, outside business affiliations, private transactions, 
board memberships, and gifts and entertainment) or through an alternate manner 
approved by the GPIM Compliance Department.  
 At the time of designation as an Access Person, Central Compliance will provide 
all Access Persons with login information and instructions for using the 
Compliance Platform. 
3.2.2. Electronic Reporting  
Quarterly personal securities transaction reporting and annual holdings reporting will 
be completed electronically, to the extent practical. In order for duplicate brokerage
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statements to be sent directly to the Compliance Platform or for electronic feeds to 
be established, Access Persons may need to provide appropriate authorization to 
their brokers. 
3.2.3. Exceptions to Electronic Reporting 
On a case by case basis and at the discretion of Central Compliance, paper reports 
and certifications may be accepted in lieu of electronic reporting on the Compliance 
Platform. 
4. Fiduciary Duty to Clients 
4.1. Managing Conflicts 
Access Persons owe a fiduciary duty to clients and have an obligation to act in their clients’ 
best interests. Access Persons must scrupulously avoid serving personal or conflicted 
interests ahead of the interests of clients. Conflicts and potential conflicts can arise in a 
variety of situations. All Access Persons must also seek to identify and appropriately address 
potential conflicts between and among client accounts as well. One client’s interests may not 
be favored over the interests of another. The Manual, available via OneGuggenheim, 
includes the Private Transactions Conflicts of Interests Review Policy that provides 
additional guidance and procedures for addressing potential conflicts within a business 
transaction context. 
4.2. Confidentiality and Safeguarding Information 
Unless permitted in writing prior to disclosure, information regarding clients or their accounts 
may not be shared with persons outside of the Advisor, such as vendors, family members, or 
market participants. In particular, information regarding the trading intentions of clients or the 
Advisor on behalf of its clients may not be shared. Access Persons may have information 
regarding clients, their investment strategies, strategic plans, assets, holdings, transactions, 
personnel matters and other information. This information must remain confidential and may 
not be shared outside the Advisor. 
4.3. Prohibition on Front Running 
Front-running, or engaging in conduct that may be construed as front-running, is strictly 
prohibited under this Code. Such conduct generally involves an Access Person purchasing 
or selling a Covered Security for his/her own account(s) on the basis of trading plans or 
actual trading positions of the Advisor’s client account(s) over which the Access Person has 
investment control when the Access Person knows that such order is likely to materially 
change a price received by a client or move a market to the benefit of the Access Person 
and detriment of the client. Proprietary, Access Persons’, and discretionary accounts will be 
monitored for front-running. 
4.4. Compliance with the Code of Ethics
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On an annual basis, Access Persons are required to acknowledge that they have reviewed, 
understand and agree to comply with the Code. A current copy of this Code is available via 
OneGuggenheim. 
5. Reporting of Personal Trading 
It is the sole responsibility of the Access Person to ensure that all reporting requirements are 
completed by the timeframes set forth by this Code. This may mean that the Access Person may 
have to enter information manually, provide statements or follow up with his/her broker-dealer or 
bank. 
5.1. Which Investment Accounts Do Access Persons Need to Report? 
Generally, any account which is in the name of the Access Person and members of his/her 
Immediate Family2, which can, even if the account does not currently, hold Covered 
Securities (as defined in Section 5.3.1) will need to be reported.  
5.1.1. Report any of the following Investment Accounts: 
a. The Access Person has Beneficial Ownership3 over an Investment Account. 
b. Any Investment Account with a broker-dealer or bank over which the Access 
Person has investment decision-making authority (including accounts that the 
Access Person is named on, such as being a guardian, executor or trustee, as 
well as accounts that Access Person is not named on such as an account 
owned by another person but for which the Access Person has been granted 
trading authority). 
c. Any Investment Account with a broker-dealer or bank established by 
partnership, corporation, or other entity in which the Access Person has a 
direct or indirect interest through any formal or informal understanding or 
agreement. 
d. Any college savings account in which the Access Person has investment 
discretion and which holds securities issued under Section 529 of the Internal 
Revenue Code and in which the Access Person has a direct or indirect interest. 
e. Any other account that the CCO deems appropriate in light of the Access 
Person’s interest or involvement. 
                                                     
2 Immediate Family includes, but is not limited to, a spouse, child, grandchild, stepchild, parent, grandparent, sibling, mother or 
father-in-law, son or daughter-in-law, or brother or sister-in-law, living in the same household, or otherwise dependent on the Access 
Person. Access Persons may rebut this presumption if they are able to provide the Advisor with satisfactory assurances that they 
have no material interest in the account and exercise no control over investment decisions made regarding the account. Access 
Persons should consult with Central Compliance for guidance regarding this process. 
3A person has Beneficial Ownership if he or she, directly or indirectly through any contract, arrangement, understanding, relationship 
or otherwise, has or shares a direct or indirect pecuniary (financial) interest in a (i) security or (ii) accounts which can hold securities, 
including but not limited to: individual, joint, partnership, custodial, trust, IRA, UGMA and KEOGH accounts. The determination of 
Beneficial Ownership is the responsibility of each Access Person: it is a fact-based decision.
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f. Any account in which the Access Person’s Immediate Family is the owner. 
Access Persons are presumed to have investment decision-making authority 
for, and therefore should report, any Investment Account of a member of their 
Immediate Family if they live in the same household.   
g. Any 401(k) accounts from a previous employer which can, or offer the ability to, 
hold Covered Securities. 
5.1.2. Independently managed third-party account reporting: 
a. Access Persons must disclose managed/third-party discretionary accounts, 
i.e., where the person has “no direct or indirect influence or control”. 
b. Access Persons are required to obtain a signed copy of the Managed 
Account Letter (provided by Central Compliance) from their third-party 
investment advisor confirming that the advisor has authority to effect 
transactions on behalf of the account without obtaining prior consent of the 
Access Person and that the Access Person does not direct trades in the 
account. 
c. Access Persons should immediately notify Central Compliance in writing if 
there are any changes in control over the account or if there are any 
changes to the relationship between the trustee or third-party investment 
advisor and the Access Person (i.e., independent professional or friend or 
relative, unaffiliated versus affiliated firm). Please note that an immediate 
family member with discretion over a covered account is not considered a 
third-party advisor.  
d. Trades in managed/third-party discretionary accounts are not subject to the 
pre-clearance requirements and trading restrictions of the Code. 
e. Account holdings/transactions in such accounts do not need to be reported 
if the Access Person has no influence or control over the account.  
5.2. Required Initial Holdings Reports and Certifications 
Information that is required when you initially become subject to the Advisor’s Code: 
a. Access Persons must report all of their Investment Accounts. (See Section 5.1.1 for 
more information.) 
b. The report must include copies of statements which include the name of the 
broker/dealer or bank, title on the account, security names, and the number of 
shares and principal amount of all holdings. 
i. If the Access Person’s brokerage firm provides automatic feeds to the 
Compliance Platform, the Advisor will obtain account information 
electronically, after the Access Person has completed the appropriate 
authorizations as required by the brokerage firm.
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c. All required account information must be reported within 10 calendar days from the 
date of hire, or the date on which the Access Person becomes an Employee of the 
Advisor and so designated as an Access Person, and the information must be 
current as of a date no more than 45 calendar days prior to the date the person 
becomes an Access Person.  
d. Access Persons must complete a form certifying receipt and acknowledgement of 
this Code.  
e. All Access Persons and any new accounts of current Access Persons must maintain 
their personal brokerage accounts with brokerage firms designated and approved by 
Central Compliance.4 The CCO or his designee may provide exceptions to this 
policy on a limited basis, however the Access Person will be responsible for 
ensuring that the account statements and trade confirmations are received by 
Central Compliance in a timely manner. 
f. Existing accounts by new Access Persons which are not held at the permitted 
broker-dealers must be transferred within 60 calendar days from the date the 
Access Person is so designated; the failure to transfer within this time will be 
considered a violation of this Code. Any request to extend the 60 days transfer 
deadline must be accompanied by a written explanation by the current broker-dealer 
as to the reason for delay. Central Compliance may grant specific exceptions in 
writing. 
5.3. Required Quarterly Transaction Reports 
5.3.1. Information required on a quarterly basis: 
Access Persons must report all their quarterly transactions in Covered Securities in 
which they have a direct or indirect beneficial interest, within at least 30 calendar 
days after quarter end. 
“Covered Securities,” as defined by the Acts, are any financial instrument related to 
a security, including: 
 Stock 
 Note 
 Treasury stock 
 Security future 
 Bond 
 Debenture 
 Evidence of indebtedness 
                                                     
4 The list of designated Broker Dealers is available on OneGuggenheim at: http://oneguggenheim/Compliance/Pages/Designated-
 Broker-Dealers.aspx?type=GPIM?Source=http://oneguggenheim/compliance/Pages/default.aspx
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 Investment contract 
 Voting trust certificate 
 Certificate of deposit for a security 
 Option on any security or on any group or index of securities (e.g., put, call or 
straddle) 
 Exchange traded fund (ETF) 
 Limited partnership 
 Certificate of interest or participation in any profit-sharing agreement 
 Collateral-RIC certificate 
 Fractional undivided interest in oil, gas or other mineral right 
 Pre-organizational certificate or subscription 
 Transferable shares 
 Foreign unit trust (i.e., UCIT) and foreign mutual fund  
 Private Investments (as defined in Section 6.1 below). Please note that a Private 
Investment and Loan Pre-Clearance Form (available through 
OneGuggenheim) must be completed prior to any new investment.  
 Unit investment trusts (UIT)  
 Closed-end mutual funds 
 Any 529 college savings plans  
 Open-end mutual funds managed, advised or sub-advised by the Advisor or an 
affiliate, as applicable  
 Any other instrument that is considered a “security” under the applicable 
securities laws 
The term “Covered Securities” does not include obligations of the U.S. government, 
futures on obligations of the U.S. government, bank loans, bankers acceptances, 
bank certificates of deposit, commercial paper and high quality short term debt 
instruments such as repurchase agreements, shares issued by unit investment 
trusts that are invested exclusively in one or more open-end funds, none of which 
are reportable funds, or open-end mutual funds which the Advisor or its affiliates, as 
applicable, do not manage, advise or sub-advise (Access Persons should be aware 
that investments in Guggenheim Funds through its 401(k) or Employee Investment 
Program are reportable as Covered Securities). 
From time to time, the Compliance Platform may not receive all duplicate statements 
from brokers or may not receive them on a timely basis. In those cases, Access 
Persons will be notified by Central Compliance and must provide copies of the 
statements to Central Compliance who will forward the information to the 
Compliance Platform.
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5.4. Annual Holdings Reports and Certifications 
5.4.1. Information required on an annual basis: 
 Access Persons must provide a list of all Covered Securities in which they or 
their Immediate Family have a direct or indirect interest, including those not held 
in an account at a broker-dealer or bank. The list must include the title, number of 
shares and principal amount of each Covered Security. Access Persons must 
report the account number, account name and financial institution for each 
Investment Account with a broker-dealer or bank for which they are required to 
report. 
 Access Persons must report all accounts and holdings within 30 calendar days 
after year end via the Compliance Platform, or as otherwise permitted by Central 
Compliance, and the information must be current as of a date no more than 45 
calendar days prior to the date the report is submitted. 
 Access Persons must also certify annually that they have complied with the 
requirements and have disclosed all holdings required to be disclosed pursuant 
to the requirements of this Code. In addition, Access Persons will respond to 
personal disciplinary history questions. 
5.5. New Investment Accounts 
Upon opening a reportable account or obtaining an interest in an account that requires 
reporting, the account must be reported within 5 calendar days of funding the Investment 
Account. The account must be reported to Central Compliance via the Compliance Platform 
or as otherwise permitted by Central Compliance, along with the title of the account, the 
name of the financial institution for the account, the date the account was established (or the 
date on which interest or authority that requires the account to be reported was gained) and 
the date reported. 
6. Pre-clearance for Personal Trading 
All Access Persons must pre-clear any trades in their Investment Accounts (except as provided 
below) through the Compliance Platform prior to execution. Prior to participating in any Private 
Investments (as defined below), all Access Persons must pre-clear (i.e., receive approval) for 
proposed transactions through Central Compliance. This is necessary in order to verify that there is 
no conflict between the desired trade and the Advisor’s current activities or the interests of the 
Advisor and its clients.  
Approvals to trade in an Investment Account are generally only good until the close of business on 
the day they are sought. If an Access Person receives approval to trade a security and does not 
execute the trade on the day the approval is received, the trade will need to be pre-cleared again if 
the Access Person still wants to execute the trade.
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If an Access Person is in possession of material non-public information about any security, the 
Access Person must not trade it, in accordance with GPIM’s Insider Trading Policy (see the Manual 
for more information), despite pre-clearing the trade and receiving approval. 
6.1. Trades Requiring Pre-Clearance 
1. Covered Securities: Unless excluded below, Access Persons must pre-clear trades in 
Covered Securities through the Compliance Platform, which checks the trade against 
the Advisor’s Restricted List and any other applicable rules and guidelines. (See 
Section 5.3.1 above for the full list of Covered Securities.)  
2. Initial Public Offerings: Trades in IPO’s must be pre-cleared. Access Persons must 
request pre-approval by submitting the Private Investment and Loan Pre-Clearance 
Form to Central Compliance. The form is available on OneGuggenheim. Note: Any 
Employee who is also registered with a broker-dealer is prohibited from participating in 
an IPO.  
3. Private Investments: Private Investments include, but are not limited to investments in:  
hedge funds, private equity funds, venture capital funds, other private fund vehicles and 
privately-held companies. New Access Persons must disclose any existing Private 
Investments within 10 days of becoming an Access Person. The Central Compliance 
Employee Activities Group sends an email to all new Access Persons with the Private 
Investments Disclosure Form, which they must complete. Existing Access Persons 
are required to seek prior written approval to invest in any new Private Investments and 
must complete the Private Investment and Loan Pre-Clearance Form (available 
through OneGuggenheim), providing information about the investment that will assist 
Central Compliance with the review of the request. The Guggenheim Capital Conflicts 
Review Committee (“CRC”) may also review private investment requests for approval, 
as necessary. Approval by the CRC is required in the event that it is determined that a 
proposed or existing private investment involves one or more potential significant 
conflicts of interest. 
6.2. Trades Not Requiring Pre-Clearance 
1. Government Securities/Certain Other Debt Instruments:  Trades in any direct 
obligations of the U.S. Government, bankers’ acceptances, bank certificates of deposit, 
commercial paper and high quality short-term debt instruments including repurchase 
agreements are not required to be pre-cleared. 
2. Money Market Funds:  Trades in any investment company or fund that is a money 
market fund are not required to be pre-cleared. 
3. Open-End Registered Funds:  Trades in open-end mutual funds that are not advised or 
sub-advised by the Advisor or affiliates are not required to be pre-cleared. 
4. No Knowledge: Securities transactions where no knowledge of the transaction exists 
before it is completed are not required to be pre-cleared. For example, a transaction
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effected by a trustee of a blind trust or discretionary trades involving an investment 
partnership, when the Access Person is neither consulted nor advised of the trade 
before it is executed, are not required to be pre-cleared. If an option is exercised, the 
underlying transaction need not be pre-cleared though the option itself must be pre-
 cleared. 
5. Certain Corporate Actions:  Any acquisition of securities through stock dividends, 
dividend reinvestments, stock splits, reverse stock splits, mergers, consolidations, spin-
 offs, exercise of rights or other similar corporate reorganizations or distributions 
generally applicable to all holders of the same class of securities is not required to be 
pre-cleared. 
6. 529 College Savings Plans Not Advised or Sub-Advised by the Advisor:  Any 
transaction in units of a college savings plan established under Section 529 of the 
Internal Revenue Code, unless the underlying investment includes Open-End 
Registered Funds advised or sub-advised by the Advisor, are not required to be pre-
 cleared. 
7. Miscellaneous:  Any transaction in any other securities as Central Compliance may 
designate. 
6.3. Prohibited Transactions 
1. Investment Clubs: Participation in Investment Clubs is prohibited. Generally, an 
Investment Club is a group of people who pool their money to make investments. 
Usually, Investment Clubs are organized as partnerships and after members study 
different investments, the group decides to buy or sell based on a majority vote of the 
members. If you have any questions regarding whether an arrangement is an 
Investment Club, please contact Central Compliance. 
2. Commodity Interests:  Trading in Commodity Interests and related Futures are 
generally prohibited, except for certain types of futures. See the NFA Compliance 
Manual available on OneGuggenheim, for the list of permissible futures. Access 
Persons should consult with Central Compliance with regard to whether a particular 
instrument is a commodity interest. Senior management, together with the CCO, may 
grant exceptions to this prohibition on a case-by-case basis and approval will be 
conditioned on compliance with certain requirements. 
7. Trading Restrictions 
7.1. For All Trading 
In addition to reporting and pre-clearance obligations, the Code also includes restrictions 
regarding the manner in which Covered Securities may be traded and held in any reportable 
Investment Accounts. (See Section 5.1.1 for more information.)
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Regardless of whether a transaction is specifically prohibited in this Code, no person subject 
to this Code may engage in any personal securities transactions that (i) impact their ability to 
carry out their assigned duties or (ii) increase the possibility of an actual or apparent conflict 
of interest. Access Persons are prohibited from the following under any circumstances: 
7.1.1. Market Manipulation 
Securities transactions may not be executed with the intent to raise, lower, or 
maintain the price of any security or to falsely create the appearance of trading 
activity. 
7.1.2. Trading on Inside Information 
Transactions (e.g., purchases or sales) of any security cannot be made if in 
possession of material non-public information about the security or the issuer of the 
security. (Please also refer to the Manual for the Insider Trading Policy.) 
7.1.3. Front-running 
No Access Person may trade ahead of a client transaction. (See Section 4.3 for 
more information.) 
7.2. Excessive Trading in Reportable Accounts 
Access Persons may not engage in excessive trading in their reportable Investment 
Accounts. Access Persons shall not make more than 60 Covered Securities trades in any 
reporting quarter. Transactions that do not require pre-clearance are not included in the total, 
and buy or sell transactions respectively, executed in the same security on the same day, 
are considered to be one transaction (i.e., an approved transaction executed in lots 
throughout the day is considered one transaction). 
Option Strategies 
Option strategies such as option spreads that are executed on the same security on the 
same day, are considered to be one economic transaction. The multiple transactions that 
make up the option spread will not be counted as individual transactions towards the 
excessive trading limit.  
7.3. Holding Periods  
7.3.1. Registered Funds 
Holding periods apply for any funds advised or sub-advised by the Advisor. A list of 
applicable funds subject to additional personal trading policies is included as 
Supplements 1, 2 and 3. 
 After purchase in an account of a closed-end mutual fund advised or sub-advised 
by the Advisor, Access Persons must hold that security in that account for at 
least 60 calendar days from the date of purchase.
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 Note that this limitation also applies to any purchase or sale in an Access 
Person’s individual retirement account, 401(k), deferred compensation plan, or 
any similar retirement plan or Investment Account for their or their Immediate 
Family. 
8. Annual Review 
The GPIM Compliance Department will review the adequacy of the policies and procedures 
contained in this Code and the effectiveness of its implementation on an annual basis. This review 
will consider any changes in the business activity of the Advisor and any changes to the Advisers 
Act or applicable regulations that might suggest a need to revise the policies and procedures 
contained herein. In addition, the GPIM Compliance Department will consider the need for interim 
reviews in response to significant compliance events, changes in business arrangements or 
regulatory developments. 
9. Retention of Records 
This Code, as updated from time to time, acknowledgements of receipt of a copy of the Code by 
each Access Person, a list of all persons required to make reports hereunder from time to time, a 
copy of each report made by an Access Person and a record of any violation hereof and any action 
taken as a result of such violation, shall be maintained by the Advisor as required under the 
Advisers Act for a period of not less than 5 years. 
Central Compliance will use best efforts to assure that all requests for pre-clearance, all personal 
securities transaction reports and all reports of securities holdings are treated as "Personal and 
Confidential."  However, such documents will be available for inspection by appropriate regulatory 
agencies, and by other parties within the Advisor and its affiliates as are necessary to evaluate 
compliance with, or sanctions under, this Code. 
10. Sanctions 
This Code is designed to facilitate compliance with applicable laws and to reinforce the Advisor’s 
reputation for integrity in the conduct of their businesses. For violations of this Code, sanctions may 
be imposed as deemed appropriate by the GPIM Compliance Department with Central Compliance 
and as applicable in coordination with senior management. Escalation will depend on the severity 
and frequency of the infraction considering the facts and circumstances such as potential or actual 
harm or reputational risk to clients, prospects or the Advisor. A pattern of violations that individually 
do not violate the law, but which taken together demonstrate a pattern of lack of respect for the 
Code, may result in disciplinary action, including termination of employment. 
Specifically, the Access Person shall be subject to remedial actions which may include, but are not 
limited to, any one or more of the following:  (1) verbal warning and/or letter of instruction; (2) 
written memo or letter of caution (including requirement for additional training) or other measures; 
(3) enhanced supervision or management plan; (4) decrease in compensation, performance
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measure or other penalty; (5) termination of employment; or (6) referral to civil or governmental 
authorities for possible civil or criminal prosecution. If the Access Person is normally eligible for a 
discretionary bonus, violations of the Code may also reduce or eliminate the discretionary portion 
of his/her bonus. 
11. Interpretations and Exceptions 
The GPIM Compliance Department shall have the right to make final and binding interpretations of 
the Code and may grant, at its discretion, exceptions to certain of the prohibited transactions as 
described in this Code. Any memorandum created regarding the granting of any such exceptions 
will be retained. Each Access Person must obtain written approval from the GPIM Compliance 
Department before taking any action regarding such an exception.
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12. Supplement 1 – Transactions in Closed End Funds (“CEFs”) Advised or Sub-Advised by the 
Advisor 
With respect to transactions in CEFs advised or sub-advised by the Advisor, the following 
requirements are in addition to, or supplement, the requirements of the Advisor’s Code of Ethics 
(“Code”). Capitalized terms not otherwise defined herein shall have the meaning ascribed to them 
in the Code. 
12.1. Pre-Approval 
Access Persons are required to obtain prior approval through the Compliance Platform 
before undertaking any transaction (e.g., purchase or sale) in CEFs advised or sub-advised 
by the Advisor. Pre-approval is in addition to, not a substitute, for other restrictions discussed 
below. 
12.2. Blackouts – Dividend 
Access Persons are prohibited from trading in CEFs advised or sub-advised by the Advisor 
seven (7) days before and seven (7) days after the initial dividend of such CEF is declared. 
Access Persons are also prohibited from trading in CEFs advised or sub-advised by the 
Advisor seven (7) days before the dividend of such CEF is declared. Dividends that are 
automatically reinvested are not subject to the pre-approval requirement. 
12.3. Blackouts – Fund Securities 
Access Persons with knowledge about or access to information about CEF equity 
transactions (“Equity Access Persons”) may not engage in personal transactions in equity 
securities to be traded in CEFs advised or sub-advised by the Advisor seven (7) days before 
and seven (7) days after such transaction. 
12.4. Holding Period 
Access Persons are required to hold any purchase of CEFs advised or sub-advised by the 
Advisor for sixty (60) calendar days. Additional holding period requirements exist for persons 
deemed to be insiders of a closed-end fund for the purposes of Section 16 of the Securities 
Exchange Act of 1934. Such persons should contact Central Compliance prior to effecting 
trading in the closed end fund(s) for which they are an insider. 
12.5. Requests for Exceptions from Blackouts 
Requests for exceptions from the blackout restriction should be submitted in writing to 
Central Compliance. Central Compliance shall respond to all such requests in writing.  
Central Compliance will maintain records of all exception requests and records of all 
responses.
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12.6. Review of Trading 
Central Compliance will review trading activity of Access Persons and in other client 
accounts, at least quarterly, to ensure compliance with the above procedures. A record of 
such reviews will be maintained by Central Compliance. 
12.7. Reporting of Transactions 
Access Persons must email the CEFs Advisor at:  Section16Filings@guggenheimfunds.com, 
but in no event more than 24 hours, after any transaction in CEFs advised or sub-advised by 
the Advisor. Such reporting is required to make mandatory regulatory filings within the 
required time period.
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13. Supplement 2 – Transactions in Exchange Traded Funds (“ETFs”) Advised or Sub-Advised 
by the Advisor and Securities Traded by Such Funds 
With respect to transactions in an ETF advised or sub-advised by the Advisor and equity securities 
traded by such Funds, the Advisor’s Access Persons are required to comply with the following 
requirements which are in addition to, or supplement, the requirements of the Advisor’s Code of 
Ethics (“Code”). Capitalized terms not otherwise defined herein shall have the meaning ascribed to 
them in the Code. 
13.1. Pre-Approval 
Access Persons are required to obtain prior approval through the Compliance Platform 
before undertaking any transaction (e.g., purchase or sale) in an ETF advised or sub-
 advised by the Advisor and the securities held by such ETFs. Pre-approval is in addition to, 
not a substitute for, other guidelines discussed below. 
13.2. Blackouts – Fund Securities 
With respect to the Advisor role as the advisor or sub-advisor to an ETF, no Access Person 
with knowledge about or access to information about ETF equity transactions (“Equity 
Access Persons”) shall engage in a securities transaction in an equity security 
recommended for inclusion or exclusion for the ETF from the time a final recommendation 
concerning such security is communicated, either to the Advisor’s investment decision-
 maker or to the ETF’s Advisor, until the security is purchased or sold by the ETF. 
13.3. Investment of Dividends 
Dividends that are automatically reinvested are not subject to the pre-approval requirement. 
13.4. Requests for Exceptions from Blackouts 
Requests for exceptions from the blackout restriction should be submitted in writing to 
Central Compliance. Central Compliance shall respond to all such requests in writing. 
Central Compliance will maintain records of all exception requests and records of all 
responses. 
13.5. Review of Trading 
Central Compliance will review trading activity of Access Persons and in other client 
accounts, at least quarterly, to ensure compliance with the above procedures. A record of 
such reviews will be maintained by Central Compliance.
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14. Supplement 3 – Transactions in Unit Investment Trusts (“UITs”) for Which the Advisor 
Assists with the Selection of Securities Traded by Such Trusts 
With respect to transactions in a UIT for which the Advisor assists with the selection of securities 
traded by such Trusts, and with respect to securities selected for inclusion for any such UIT, the 
Advisor’s Access Persons are required to comply with the following requirements which are in 
addition to, or supplement, the requirements of the Advisor’s Code of Ethics (“Code”). Capitalized 
terms not otherwise defined herein shall have the meaning ascribed to them in the Code. 
14.1. Blackouts 
With respect to the Advisor’s role in security selection for UITs, no Access Person with 
knowledge about or access to information about UIT equity transactions (“Equity Access 
Persons”) shall engage in a securities transaction in an equity security recommended for 
inclusion or exclusion for the UIT from the time a final recommendation concerning such 
security is communicated to the UIT Sponsor until the time such security is deposited into 
the UIT. 
14.2. Requests for Exceptions from Blackouts 
Requests for exceptions from the blackout restriction should be submitted in writing to 
Central Compliance. Central Compliance shall respond to all such requests in writing. 
Central Compliance will maintain records of all exception requests and records of all 
responses. 
14.3. Review of Trading 
Central Compliance will review trading activity of Access Persons and in other client 
accounts, at least quarterly, to ensure compliance with the above procedures. A record of 
such reviews will be maintained by Central Compliance.