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Disclosing your Account Information: Except as noted in Section 2.2, all accounts must be disclosed in

Any employee who maintains an account with a broker that does not submit reportable transactions and holdings information to BlackRock via an electronic feed is required to provide such information to BlackRock as follows:

4 Note that contingent workers are not required to move their accounts to an Approved Broker.

5 Note that the Global Approved Broker List includes a limited number of brokers that do not provide electronic f eeds, f or example, in jurisdictions w here electronic f eeds generally are not available. Any employee w ho maintains an account w ith a broker that does not provide BlackRock w ith an electronic f eed, w hether an Approved Broker or not, is responsible f or the inf ormation delivery requirements in Section 3.1.

Trade confirmations must be submitted to BlackRock within five (5) days of trade execution; and

Quarterly statements must be submitted to BlackRock within thirty (30) days of quarter end.

It is the employee’s obligation to report the information to BlackRock – in instances where the employee arranges for the broker to submit information directly to BlackRock, the employee remains responsible to confirm that documents are submitted and that the information provided is accurate.

If you transact directly with the issuer in a direct stock purchase plan or Dividend Reinvestment Plan (“DRIP”), you must disclose the account information and the name of the transfer agent or bank that executes such transactions to the extent available.

3.2.

BlackRock Open-end Funds Domiciled in the US: Shares of BlackRock Open-end Funds domiciled in the US must be held directly through the Fund, BNY Mellon, Merrill Lynch, Fidelity, Charles Schwab, or UBS. Upon commencing employment, you must transfer any existing holdings of shares or units of BlackRock Funds into an account at one of these named brokers.

Transaction Pre-Clearance Requirement

4.1.

You must submit a pre-clearance request in PTA and receive an approval before undertaking any personal investment transactions permitted under this policy, including purchases, sales, options exercises, and gifts.

4.2.

Pre-clearance approvals, whether for market orders >6

or limit orders 7 , are valid only on the day the approval is received. Your order must be executed by the time the market on which the security is trading closes.

NOTE: Limit pre-clearances are not valid in Japan or Taiwan.

Transactions Not Subject to Pre-Clearance

You are not required to obtain pre-clearance approval to transact in the following:

Open-end Mutual Funds, including Labour-Sponsored Funds and shares or units of BlackRock Funds; Open-End Investment Companies, Unit Trusts, Unit Investment Trusts, SICAVs;

NOTE: BlackRock Japan employees must pre-clear BlackRock Group related funds that are managed, advised, or issued by BlackRock Japan; Taiwan SITE BlackRock funds also must be pre-cleared.

Purchases of common stock under an Employee Stock Purchase Plan (note, however, that sales mus t be pre-cleared);

Direct obligations of national government issuers;

Certificates of deposit and commercial paper;

Foreign exchange;

6 Buy or sell transactions placed at current market price.

7 Buy or sell transactions placed at a pre-determined price (detailed w ithin the pre-clearance request).

529 Plans, Direct Stock Purchase Plans, and any securities purchased pursuant to a dividend reinvestment plan;

Securities issued by an exercise of rights to the holders of a class of securities;

Stock dividend, stock split, or other similar corporate distribution;

Conversion of employee stock options (note, however, that sales must be pre-cleared);

Permissible Futures Transactions; and/or

Managed Accounts (as defined below).

Managed Accounts

6.1.

You are not required to obtain pre-clearance approval with respect to transactions in a Managed Account provided you obtain written confirmation from the manager, investment adviser, or trustee managing your account that the account is managed on a discretionary basis and/or that you (or, if applicable, your spouse, domestic partner, or dependent child) do not exercise investment discretion or otherwise have direct or indirect influence or control over investment decisions. The manager’s written confirmation must be in a form acceptable to Legal & Compliance.

6.2.

Investment Restrictions: The following investments are not permitted in Managed Accounts. It is your responsibility to communicate these investment restrictions to the manager, investment adviser, trustee, or other fiduciary managing your account.

Investments in BlackRock, Inc. (BLK);

BlackRock Closed-end Funds domiciled in the US; and

BlackRock Open-end Funds domiciled in the US (unless held in a managed account at Merrill Lynch, Fidelity, Charles Schwab, UBS, or directly through the transfer agent, BNY Mellon).

6.3.

Permitted Investments: All other securities, including BlackRock iShares ETFs and options, and futures are permitted in Managed Accounts.

Prohibited Investments

You are prohibited from transacting in the following:

Initial Public Offerings except certain offerings directed or sponsored by BlackRock (as may be permitted by Legal & Compliance);

Repurchase Agreements;

Spread betting on financial markets and instruments;

Contracts For Difference (“CFD”) (only prohibited in EMEA and Japan);

Options other than Permissible Options Transactions (as defined in Section 8.1);

Futures other than Permissible Futures Transactions (as defined in Section 8.2); and/or

Limited offerings 8 (e.g., private offerings) unless permitted by Legal & Compliance in accordance with the Global Employ ee Private Inves tment Policy

8 Limited off erings are private of f erings that are exempt from registration under the Securities Act of 1933, as amended, pursuant to Section 4(a)(2), Section 4(a)(5), Rule 504, Rule 505, or Rule 506.

helps execute such employee’s decisions, or directly supervises such employee, each with respect to a client account/fund.

9.3

Blackout Period Exemptions

Blackout period restrictions do not apply to the following transactions:

Transactions not subject to pre-clearance as identified in Section 5; and/or

Securities of a company included in the S&P 200, FTSE 100, S&P/TSX 60 or ASX 100.*

*NOTE: Please see the Annex 3 for additional requirements relating to Japan.

10.

Ban on Short-Term Trading Profits

You may not profit from the purchase and sale, or the sale and purchase, of the same security within a 60 calendar day period. This restriction does not apply to the following transactions at the discretion of Legal

& Compliance:

Transactions not subject to pre-clearance as identified in Section 5;

Securities of a company included in the S&P 200, FTSE 100, S&P/TSX 60, or ASX 100;

Permissible options on securities of a company included in the S&P 200, FTSE 100, S&P/TSX 60, or ASX 100;

ETFs listed on Annex 1 (excludes Japan employees);

Options on ETFs listed on Annex 1 (excludes Japan employees);

Options on Indices consisting of 100 or more components; and/or

Transactions in BlackRock, Inc. (BLK) during open window periods and with prior pre-clearance approval. (Note, day trading is not permitted in BLK).

*NOTE: Please see the Annex 3 for additional requirements relating to Japan.

11.

Private Investment Pre-Approval Process

11.1 Private Investment Questionnaire: Private investments (including hedge funds, private equity funds, or private placements of securities) must be pre-approved by Legal & Compliance. To obtain approval, you must complete and submit a Private Investment Questionnaire to the alias on the questionnaire. You may make the private investment only after obtaining prior written approval from Legal & Compliance. Please consult the Global Employee Private Inves tment Policy for additional details.

12.

Trading in BlackRock, Inc. (BLK)

12.1.

Trading Window: You may only transfer, gift, or trade (purchase, sell, or exercise employee stock options on) BLK during open trading window periods. You will be notified of these window periods by an email notification sent by Legal & Compliance to all employees announcing the opening and closing date of the trading window.

Pre-Clearance of BLK is required: Even during open trading windows, you are required to pre- clear all of your transactions in BlackRock, Inc. (BLK). This includes purchases, sales, option exercises and gifts.

Pre-Clearance and BlackRock’s Employee Stock Purchase Plan (ESPP): You are required to pre-clear sales of BlackRock common stock from BlackRock’s ESPP (purchases in the ESPP do not require pre-clearance).

12.2.

Restrictions on Trading in BlackRock, Inc. (BLK): You may not:

Trade in options or warrants on BLK;

Engage in any day trading (buying and selling the same security during one calendar day);

Engage in any short selling of BLK; and/or

Purchase any single-stock futures contracts on BLK.

13.

Insider Trading

You must comply with BlackRock's Global Ins ider Trading Policy at all times, including when conducting your personal trading. In addition, you must notify Legal & Compliance immediately if you receive or expect to receive material non-public information. Legal & Compliance will determine the restrictions, if any, that will apply to your communications and business activities while in possession of that information.

14. Personal Trading Violations

Employee personal trading is subject to monitoring by BlackRock. BlackRock will determine on a case by case basis what remedial action should be taken in response to any violation. This may include requiring the employee to void or reverse a trade, the cost of which may be borne by the employee or owner of the account, or limiting an employee’s personal trading for some period of time. Violations of this policy, including but not limited to violations relating to trading activity and the obligation to provide information to BlackRock, may result in disciplinary action, up to and including termination.

15. Annual Certification

You must certify annually that the account information (including securities and futures holdings) you have reported to BlackRock is accurate.