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Global Code of Ethics

Every day we make individual choices which reflect on the collective reputation of the Manulife and John Hancock brands. Our global standards for business ethics and our well-regarded reputation for integrity differentiate our brands in the marketplace and have been critical factors in our past as well as our future success. We are proud of Manulife Asset Management’s culture of doing business the right way and we want to underscore the need to continue to conduct our business in this manner.

To this end, Manulife Asset Management has adopted this Global Code of Ethics to promote compliance with applicable law as well as to address certain potential and actual conflicts of interests which can arise between our personal investment decisions and the interests of our clients. This Global Code of Ethics has been designed to reflect our values as a global organization and demonstrate the importance of the trust our clients have placed in Manulife Asset Management and the duties we owe to our clients.

Code Version: September 1, 2015

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PART 1:	Purpose & Applicability
1.1	Purpose
1.2	Code Applicability—MAM Associates & Access Persons
1.3	Report Changes to Access Person Status
1.4	Code Certification
1.5	Reporting Violations of the Code as well as Manulife and MAM Policies
1.6	Supervisory Oversight & Personal Liability
PART 2:	Principles of Business Conduct
2.1	General Principles of Business Conduct
2.2	Personal Trading & Conflicts of Interests
2.3	Confidential Investment Information
2.4	False Rumors
2.5	Outside Business Activities
2.6	Other MAM & Manulife Compliance Requirements
PART 3:	Personal Investing Restrictions & Limitations
3.1	What Securities are Subject to the Code’s Personal Trading Restrictions & Requirements?
3.2	Restrictions on Securities under Active Consideration
3.3	Restrictions on Manulife Securities
3.4	Preclearance Approval Requirement
3.5	SpecialPre-Clearance Approval Requirement for Level 3 Access Persons Only
3.6	15 Day Blackout Period Rule
3.7	Affiliated Mutual Fund Profit Ban—30 Day Rule
3.8	Short-Term Profit Ban—60 Day Rule
3.9	Limit Orders and Special Orders
3.10	Investment Clubs
3.11	Discouraging Excessive Trading
3.12	Additional Restrictions—Hong Kong-Based Access Persons Only

PART 4:	Level 1 Access Persons Additional Personal Investing Restrictions
4.1	Initial Public Offering Ban
4.2	Investment Team Hold Until Sold Rule
4.3	Investment Team Enhanced Trade Blackout Rule for Certain Level 1 Access Persons
4.4	Preclearance of Significant Personal Securities Positions
4.5	Disclosure of Personal Investment Conflicts & Limited Offering Independent Review
4.6	1% & 5% Security Ownership Disclosure & Prohibitions
PART 5:	Initial & Periodic Reporting
5.1	Requirement to Report All Securities Accounts
5.2	Duplicate Transaction Confirmations & Statements
5.3	USA-Based Access Person Preferred Brokerage Account Requirement
5.4	Initial Holdings Report & Certification
5.5	Quarterly Transaction Report & Certification
5.6	Reporting of Gifts, Donations & Inheritances
5.7	Annual Holdings Report & Certification
5.8	Method of Reporting & Certifications
PART 6:	Code Administration
6.1	No Liability for Loses
6.2	Penalties for Code Violations
6.3	Exemptions & Appeals
6.4	Code Amendments
6.5	Code Interpretation & Administration
6.6	Recordkeeping

Appendix A:	Code Definitions
Appendix B:	Code Adoption Dates
Appendix C:	Chart: Reportable Securities &Pre-Clearable Securities

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  PART 1 PURPOSE & APPLICABILITY  

1.1 Purpose

Manulife Asset Management¹ (MAM) has adopted this Code of Ethics (Code) to promote compliance with applicable law byMAMandMAM Associates and to prevent those abuses in the investment management business that can arise when certain conflicts of interest exist between personnel of an investment advisor and its clients. By adopting and enforcing thisCode, we strengthen the trust and confidence entrusted in us by demonstrating that atMAM, client interests come first.

1.2 Code Applicability—MAM Associates & Access Persons

ThisCode applies toMAM Associates.MAM Associates are: (i) any partner, officer, director (or other person occupying a similar status or performing similar functions) ofMAM; (ii) an employee ofMAM; (iii) any person who provides investment advice on behalf ofMAM and is subject to the supervision and control ofMAM; (iv) any person meeting the definition ofAccess Person; and (v) any other person who theCode Administrator deems aMAM Associate.²

Additionally,MAM Associates who have access to certain investment information and the investment decision-making process are further classified by theCode Administrator into one of following threeAccess Person levels and as a result are responsible for complying with the personal trading restrictions and obligations of their access designation level.

¹ Refer to APPENDIX B for a list ofMAM entities who have adopted this Code of Ethics.

² TheCode Administrator orChief Compliance Officer may modify the requirements of thisCode for thoseMAM Associates whose tenure atMAM is expected not to exceed 90 days (for instance contractors,co-ops and interns) or in instances where a person is subject to another code of ethics or fiduciary duty and where the modification is not otherwise specifically prohibited by law.

Access Person Level 1

AnyMAM Associate who, in connection with his/her regular functions or duties, makes or participates in making recommendations regarding the purchase or sale of securities forMAM-advisedClient accounts or provide direct administrative support to aMAM Associate who makes or participates in the recommendations.

Examples: Portfolio Managers, Analysts, Traders and Certain Administrative Staff

Access Person Level 2

AnyMAM Associate who, in connection with his/her regular functions or duties: (i) hasregular access to nonpublic information regarding anyClients’ purchase or sale of securities ornon-public information regarding the portfolio holdings of anyMAM-advisedClient account (ii) is involved in making client securities recommendations, or (iii) has regular access to such recommendations that are nonpublic.

Examples: Certain Compliance, Legal, Investment Operations, Administration, Client Services & Products, Private Client Group, Sales/Marketing, Technology Resources, and MMF Personnel as well as Administrative Staff Supporting Level 2 Access Persons

Access Person Level 3

AMAM Associate who, in connection with his/her regular functions or duties, hasperiodic access tonon-public information regarding any clients’ purchase or sale of securities, ornon-public information regarding the portfolio holdings of any account advised byMAM

Examples: Certain Business Financial Analysts, Technical Associates, Technical Resource Associates, Legal Staff, Client Services and Products Staff as well as Administrative Staff Supporting Level 3 Access Persons

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 4

1.3 Report Changes to Access Person Status

TheCode Administrator is responsible for classifyingMAM Associates asAccess Persons based on theCode Administrator’s understanding of theMAM Associates current role. If aMAM Associate has a level of investment access different than their assigned category, or theMAM Associate is promoted or changes duties and as a result should more appropriately be included in a different category, it is theMAM Associates responsibility to immediately notify theCode Administrator.

1.4 Code Certification

EachMAM Associatemust provide a written (or electronic) acknowledgement of their initial receipt of theCodeand any amendments to theCode, copies of which are to be provided by theCode Administrator, and a certification that they have read and understood theCodeand will comply with the applicable provisions of theCode(including any amendments to theCode).

Additionally, annually eachMAM Associate is required to certify that he or she has read and understands theCode, acknowledges the applicableCode provisions, and represents that he or she has complied with (or has disclosed any failure to comply with) the applicableCode requirements during the past year.

1.5 Reporting Violations of the Code as well as Manulife & MAM Policies

AnyMAM Associatewho knows or has reason to believe that theCodeor a ManulifeorMAMpolicyhas been or may be violated must bring such actual or potential violation to the immediate attention of theChief Compliance Officer.

AMAM Associate must speak with their manager, a member of the Human Resources Department, Law Department or theChief Compliance Officer if he or she has:

● a doubt about a particular compliance situation;

● a question or concern about a business practice; or

● a question about potential conflicts of interest.

It is a violation of theCodefor aMAM Associateto deliberately fail to report a violation or deliberately withhold relevant or material information concerning a violation of theCodeor a Manulife or MAMpolicy.

No person will be subject to penalty or reprisal for reporting in good faith suspected violations of theCodeor aManulifeorMAM policyby others.

Additionally, unethical, unprofessional, illegal, fraudulent or other questionable behavior may also be anonymously reported by calling the confidential toll freeManulife Ethics Hotline at1-866-294-9534 or by visiting the website: www.ManulifeEthics.com.

1.6 Supervisory Oversight & Personal Liability

AllMAM Associates with managerial responsibility are responsible for the reasonable supervision of their staff to prevent and detect violations of theCodeand applicable rules and regulations. Failure to perform adequate oversight can result in the manager being held personally liable by regulators for violations of theSecurities Laws and theCode.

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Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 5

  PART 2 PRINCIPLES OF BUSINESS CONDUCT   

2.1 General Principles of Business Conduct

EachMAM Associate is expected to adhere to a high standard of professional and ethical conduct and should be sensitive to situations that may give rise to an actual conflict or the appearance of a conflict with ourClients’ interests, or have the potential to cause damage toMAM or aMAM Affiliates’ reputation. To this end, eachMAM Associate must act with integrity, honesty and in an ethical manner. The following General Principles of Business Conduct govern the activities ofMAM and everyMAM Associate as well as the interpretation and administration of thisCode:

● We have a fiduciary duty at all times to place the interests of ourClientsfirst.

● All personal securities transactions must be conducted consistent with the provisions of theCode that apply and in such a manner as to avoid any actual or potential conflict of interest and any other abuse of trust or responsibility.

● We should not take inappropriate advantage of our position or engage in any fraudulent or manipulative practice (such as front-running or manipulative market timing) with respect toClient accounts.

● We must treat as confidential anynon-public or confidential information concerning the identity of security holdings and financial circumstances ofClients.

● We must comply with all applicable laws including applicable domestic and foreignSecurities Laws.

Adherence to the General Principles of Business Conduct and other provisions of thisCode is a condition of employment atMAM. Additionally, while theCode contains specific restrictions and limitations designed to prevent certain defined types of conflicts,MAM recognizes that not every potential conflict of interest can be anticipated by theCode. Therefore, it is critical that theCode’sGeneral Principles of Business Conduct be followed in the absence of a specificCoderequirement or limitation.

Additionally as described in Section 6.2 “Penalties for Code Violations”, failure to comply with the General Principles of Business Conduct (above) or any provision of theCodemay result in disciplinary action, including termination of employment.

Compliance Tip - Ask First, Act Second

It is critical that any MAM Associatewho is in doubt about the applicability of the Codein a given situation seek a determination fromthe Code Administratoror the Chief Compliance Officerabout the propriety of the conduct in advance.

2.2 Personal Trading & Conflicts of Interests

TheCode represents a balancing of important interests. On the one hand, as an investment adviser,MAM owes a duty of undivided loyalty to itsClients, and must avoid even the appearance of a conflict that might be perceived as abusing the trustClientshave placed in MAM. On the other hand,MAMdoes not want to prevent conscientious professionals from investing for their own accounts where conflicts do not exist or are immaterial to investment decisions affecting theClients.

When conflicting interests cannot be reconciled, theCodemakes clear that, first and foremost,MAMAssociates owe a fiduciary duty toMAM’sClients. In most cases, this means that the affectedMAM Associates will be required to forego conflicting securities transactions. In some cases, personal investments will be permitted, but only in a manner, which, because of the circumstances and applicable controls, cannot reasonably be perceived as adversely affectingClientportfolios or taking unfair advantage of the client relationship.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 6

2.3 Confidential Investment Information

Information acquired by aMAM Associate in connection with their duties forMAM, including information regarding actual or contemplated investment decisions,non-public portfolio composition, research, research recommendations, firm activities, orClientinterests, is confidential and may not be used in any way that might be contrary to, or in conflict with the interests ofClients orMAM. Additionally,MAM Associates are reminded that certainClientshave specifically required their relationship withMAM to be treated confidentially.

2.4 False Rumors

TheSecurities Laws prohibit the deliberate or reckless use of manipulative devices or activities with an intention to affect the securities markets, including the intentional creation or spreading of false or unfounded rumors or other information. Accordingly, aMAM Associate may not communicate information regarding companies,Securities, or markets that he or she knows to be false.

2.5 Outside Business Activities

In addition to other Manulife policies with respect to outside business activities,MAM Associatesmay only serve on outside investment committees or beemployed by, serve as an officer of, or serveon boards of trustees and directors of business andnon-business entities (including charitable boards) with the approval of theMAM Associate’s manager and theChief Compliance OfficerorMAM General Counsel.³

2.6 Other MAM & Manulife Compliance Requirements

In addition to theCode,MAM Associatesmust comply with all compliance-oriented requirements applicable to them, including business unit policies as well as theMAMandManulife policies listed in the column to the right.

³ Unless serving at the direction ofMAM,MAM Associates who engage in outside business and charitable activities are not acting in their capacity as aMAM Associateand may not useMAM’s name in connection with those activities.

ManulifeCode of Business Conduct & Ethics

The Code of Business Conduct and Ethics provides standards for ethical behavior when representingManulife and conductingManulife’s business.

Insider Trading & Market Abuse Policies

TheMAMandManulifeinsider trading and market abuse policies address important topics, such as: the identification and reporting of materialnon-public information, the Investment Division’s information barrier,MAM’s “restricted list”, and the various prohibitions on sharing and misusingmaterial-non-public information.The policies specifically prohibit the unlawful use and sharing of materialnon-public information.

Portfolio Holdings Disclosure & Confidentiality Policies

Non-public information aboutMAM client portfolio holdings as well as other client information cannot be shared or disclosed except in accordance with these policies.

ManulifeAnti-Fraud Policy

This policy requires the prompt reporting of any suspicion or allegation of fraud, fraudulent activity, or dishonest activity in relation toManulife.

ManulifeElectronic Communications Guidelines

This policy contains various limitations and restrictions on the use of email, and other forms of electronic communications.

ManulifeConflict of Interest & MAM Gift Policies

These policies address standards and disclosure requirements related to the giving and receiving of gifts and entertainment.For the protection of theMAM Associate andMAM, the appearance of a possible conflict of interest must be avoided.

MAM Anti-Bribery and Pay–to–Play Policies

These policies are designed to prevent bribery, kickbacks and similar unlawful schemes. Specifically, these policies limit or prohibit certain types of gift, entertainment and political donation practices in order forMAM to comply with certain government regulations. For instance, thePay-to Play Policy restricts certain types of personal political donations in the U.S. A. and also requires the reporting of certain U.S.A. donations by certainMAM Associates.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 7

  PART 3   PERSONAL INVESTING RESTRICTIONS & LIMITATIONS  

The following personal investing restrictions and limitations are designed to prevent certain defined types of conflict of interests.MAMrecognizes that not every potential conflict of interest can be anticipated by theCode. Therefore, it is critical that theCode’sGeneral Principles of Business Conduct be followed in the absence of a specific requirement or limitation. It is critical that any MAM Associatewho is in doubt about the applicability of the Codein a given situation seek a determination from the Code Administratoror the Chief Compliance Officerabout the propriety of the conduct in advance.

3.1 What Securitiesare Subject to the Code’s Personal Trading Restrictions & Requirements?

Securitiesin which theAccess Person has aBeneficial Interest are subject to theCode’s personal trading restrictions and requirements. An Access Personis deemed to have aBeneficial Interestin anySecurity where theAccess Person controls or has the opportunity to directly or indirectly profit or share in the profit derived from a transaction in the Security.An Access Personis presumed to have aBeneficial Interest inthe following Securities:

● Securitiesowned by an Access Person in his or her name.

● Securitiesowned by Household Family Members.

● Securitiesowned by an Access Personindirectly through an account or investment vehicle for his or her benefit, such as an IRA/RRSP/RESP/ ISA/SIPP, family trust or family partnership.

● Securitiesin which the Access Personhas a joint ownership interest, such asSecurities owned in a joint brokerage account.

● Securitiesover which theAccess Person has discretion or gives advice (other thanMAM Client accounts). This includes Securitiesowned by trusts, private foundations or other charitable accounts for which the Access Personhas investment discretion.

3.2 Restriction on Securities under Active Consideration

AllMAM Associates (including allAccess Persons) may not purchase, sell, or otherwise dispose of anySecurityin which theMAM Associatehas (or as a result of such transaction will establish)Beneficial Interestif the MAM Associateat the time of the transaction has actual knowledge that (i) theSecurity(if it is aPre-Clearable Security)is underActive Consideration for Purchase or Saleby or on behalf ofMAMor anyClientor (ii) theSecurityis on the MAMRestricted Trading List.

Beneficial Interest & Household Family Member Reminder

Please note that if a specificCodeprovision (including a personal investing restriction or limitation,pre-clearance obligation or reporting obligation) applies to theAccess Person, it also applies to allSecuritiesandSecuritiesaccounts over which theAccess Person has aBeneficial Interest.

Access Persons are presumed to have aBeneficial Interest in the personalSecuritiesholdings andaccounts ofHousehold Family Members.The definition of Household Family Memberincludes an Access Person’s spouse, significant other, minor children or other family members who also share the same household with theAccess Person.

3.3 Restrictions on Manulife Securities

Manulife’s Insider Trading & Reporting Policy prohibitsManulifeemployees from speculating inMFC Securities. Speculation includes the purchase or sale ofManulife Securities with the intention of reselling or buying back in a relatively short period of time in the expectation of a rise or fall in the market price of such securities, buying or selling options, or short selling. Please refer to the Manulife Insider Trading and Reporting Policy for additional restrictions and requirements onManulife Securities transactions.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 8

3.4 Pre-Clearance Approval Requirement

Level 1 and Level 2 Access Persons may not purchase, sell or otherwise acquire or dispose of anySecurityin which he or she has (or as a result of such transaction will establish) aBeneficial Interestwithout obtaining advance written (or electronic)pre-clearance approval for such transaction from theCode Administrator, Chief Compliance Officer,or thePersonal Trading & Reporting Systemunless theSecuritytransaction is exempt from thisCode’spre-clearance requirement. Refer toAPPENDIX C of theCodefor a list ofSecuritiesand Securitiestransactionsexempt from thepre-clearance requirement.

A preclearance approval is valid only for the day it is granted unless an exception is granted by theChief Compliance Officer orCode Administrator.

Additionally, successfully obtainingpre-clearance approval for a transaction does not mean anAccess Person cannot be found to be in violation of a specific applicable personal investing restriction or limitation of theCode or the Code’sGeneral Principles of Business Conduct.

3.5 SpecialPre-Clearance Approval Requirement for Level 3 Access Persons

Level 3Access Persons are exempt from thepre-clearance requirements of Section 3.4. However, Level 3Access Person’s may not acquire aBeneficial Ownership in anySecurityin anInitial Public Offering or aLimited Offering or acquire or dispose of aBeneficial Interest in aClosed-End Investment Companyadvised by aManulife Affiliate without obtaining advance written (or electronic) approval from theChief Compliance Officer.

Pre-Clearance Reminder:

Household Family Members

Access Persons (Level 1 and 2) are required to obtainpre-clearance approval for allSecurities transaction of persons who qualify as aHousehold Family Member of theAccess Person (unless the transaction is exempt from thepre-clearance requirement. Refer toCodeAPPENDIX C forpre-clearance exemptions).

3.6 15 Day Blackout Period Rule

Level 1 and Level 2 Access Persons may not purchase, sell or otherwise acquire or dispose of anyPre-ClearableSecurityin which he or she has (or as a result of such transaction will establish) aBeneficial Interestif thatSamePre-Clearable Securitytraded in aClient account 15 calendar days before such transaction (or will trade in aClient account 15 days following such transaction)unless (1) theAccess Person has no actual knowledge that theSamePre-Clearable Security is under Active Consideration for Purchase or Saleby aClient and (2) the transaction can satisfy one of the following exceptions:

● De Minimis Trading Exception:MAMmay permit the transaction if all of theAccess Person’s aggregate totalsame-daypre-clearance requests for theSamePre-Clearable Security have a transaction market value of less than $25,000 USDand (in the case of equities) the same day transactions in thePre-Clearable Security total no more than 500 equity shares.

● Market Cap Securities Exception:MAMmay permit the transaction if the individual preclearance request is in theSecurities of an issuer whose market capitalization is at least $5 billion USD or more.

Level 1Access Persons should refer to Part 4 of the Code (Level 1Access Persons Additional Restrictions) to determine if a Level 1Access Person may rely on the exceptions (above) to the 15 Day Blackout Period Rule.

If aMAM Clientaccount trades in aPre-Clearable Securitywithin 15 calendar days before or after anAccess Person obtainspre-clearance approval of a trade, theAccess Person may be required to demonstrate that he or she did not know that the sameSecuritywas under Active Consideration for Purchase or Salefor aClientaccount.

TheChief Compliance Officer,in his or her sole discretion, may exempt or exclude an individual or class ofAccess Person transactions and/orClientaccounts from the 15 Day Blackout Period Rule so long as theChief Compliance Officer documents the rationale for granting the exemption or exclusion.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 9

3.7 Affiliated Mutual Fund Profit Ban—30 Day Rule

All Access Persons(includingHousehold Family Members)are prohibited from directly or indirectly profiting from a discretionary purchase and sale of anAffiliated Mutual Fund actively managed by theAccess Person’s MAM entity within 30 calendar days.

3.8 Short-Term Profit Ban—60 Day Rule

Level 1 and 2 Access Persons (includingHousehold Family Members), cannot directly or indirectly profit from a discretionary purchase and sale of the samePre-Clearable Security within 60 calendar days. However,Pre-ClearableSecuritieswhose issuer’s market capitalization is $5 Billion USD or more at the time of the transaction are exempt from this 60 Day Rule. Note: a voluntary transaction related to a derivativeSecurity (including options) which results in a profit is permitted so long as the voluntary transaction occurs more than 60 calendar days after the initial related transaction event.

3.9 Limit Orders and Special Orders

Due to the1-daypre-clearance trade window outlined in Section 3.4,multi-day special orders, such as “good until canceled orders” or “limit orders,” are prohibited for Level 1 and 2Access Persons.⁴ However,Access Persons (and Household Family Members) may place day orders, (i.e., orders that automatically expire at the end of the trading day session). Be sure to check the status of all orders at the end of the trading day and cancel any orders that have not been executed. Please note that if a trade order is left open beyond thepre-clearance window and it is executed outside of the window, the transaction will constitute aCode violation.

3.10 Investment Clubs

Access Persons(including Household Family Members)are prohibited from participating or holding an interest in anyInvestment Club.

⁴ TheCode Administrator orChief Compliance Officer may provide anAccess Person with a transaction-specific exemption in special limited circumstances (e.g., subscription offerings with an uncertain trade execution date, special employment transaction with limited exercise trade windows).

Securities Transactions Exempted from the Affiliated Mutual Fund30-Day Profit Ban and60-Day Short Term Profit Ban

The followingSecuritiesactivities are exempted from both the60-Day Short Term Profit &Affiliated Mutual Fund30-Day Profit Ban:

●     All money market fund transactions

●     Automatic Investment Plan transactions (including payroll deduction purchases)

●     Dividend reinvestment purchase transactions

●     IssuerPro Rata Discretionary Transactions

●     Involuntary issuer transactions (e.g., stock dividends, stock splits/ reverse splits or other similar reorganizations or distributions, call of a debt security, and spin-offs of shares to existing holders)

●     Automatic purchases into a default investment option by a retirement plan

●     Other involuntary purchase or sales activity not at the direction of theAccess Person or theAccess Person’s Household Family Member

Gifts and Donations

Please note that giving gifts and donations of Securities are considered “sales” and are not exempt from 30/60 day profit bans.

Exemptions

TheChief Compliance Officer, in his or her sole discretion, may grant a hardship exemption from 30/60 day profit ban (such as profitable sales motivated by the need to pay for unexpected medical expenses).

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 10

3.11 Discouraging Excessive Trading

While active personal trading may not in and of itself raise issues under theSecuritiesLaws,MAMbelieves that a very high volume of personal trading by anAccess Person can be time consuming and can increase the possibility of actual or apparent conflicts with portfolio transactions. Accordingly, an unusually high level of discretionary personal trading activity by anAccess Person is strongly discouraged and may be subjected to enhanced scrutiny byMAM.TheChief Compliance Officer may impose limitationson the number ofPre-Clearable Securitiestrades permitted during a given period for certainAccess Persons.

3.12 Additional Restrictions—Hong Kong-Based Access Persons Only

Hong Kong-basedAccess Persons (andHousehold Family Members) are prohibited from the following additional activities: (i) short selling anySecurity, (ii) delay of personal transaction settlement beyond the normal settlement time for the relevant market and (iii) cross trades betweenAccess Persons andClient accounts.

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  PART 4   LEVEL 1 ACCESS PERSONS ADDITIONAL PERSONAL INVESTING RESTRICTIONS  

In addition to the personal investing restrictions and requirements forAccess Persons in Part 3 of thisCode, Level 1Access Persons (including theirHousehold Family Members) are subject to the following additional restrictions and requirements.⁵

4.1 Initial Public Offering Ban

Level 1 Access Personsmay not directly or indirectly acquire aBeneficial Interestin aSecurity through anInitial Public Offering(IPO). Consequently, Level 1Access Persons (includingHousehold Family Members) must wait to purchase newly-issued IPOSecurities until the next business (trading) day following the offering date of the IPO.

4.2 Investment Team Hold Until Sold Rule

A Level 1 Access Personassociated with anInvestment Team (including Household Family Members)is not permitted to sell aPre-Clearable Securityholding in which they have aBeneficial Interest if (i) theSamePre-Clearable Security is held in aClient account managed by theAccess Person’s Investment Teamand (ii) the Access Person (orHousehold Family Member) purchased thePre-Clearable Security after the date of the Code’s initial adoption (Refer to APPENDIX B for initial adoption dates)or the date the person was named to the relevantInvestment Team (which ever date is later).

⁵ TheChief Compliance Officer may grant individual exceptions to Sections 4.1, 4.2, and/or 4.3 under limited hardship circumstances where theChief Compliance Officer concludes that no material conflict of interest is present. For instance in the case of anIPO, a Level 1Access Person may request and exemption from theIPOprohibition for certain investments that do not create a potential conflict of interest, such as: (1) Securities of a mutual bank or mutual insurance company received as compensation in a demutualization and other similarnon-voluntary stock acquisitions; (2) fixed rights offerings; or (3) a family member’s participation as a form of employment compensation in their employer’sIPO. TheChief Compliance Officermay also exclude an individual or class ofClientaccounts from the application of Sections 4.2 and 4.3 so long as theChief Compliance Officer documents the rationale for the exemption or exclusion.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 11

4.3 Investment Team Enhanced Trade Blackout Rule for Certain Level 1 Access Persons

Level 1 Access Personswho are members of anInvestment Team (includingHousehold Family Members) may not purchase, sell or otherwise acquire or dispose of anyPre-ClearableSecurityin which he or she has (or as a result of such transaction will establish) aBeneficial Interestif thatSamePre-Clearable Securitytraded 15 calendar days before such transaction or will trade 15 days following such transaction in aClient account managed by the Level 1Access Person’s Investment Team. Note:the De Minimis and Market Cap exceptions outlined in Section 3.6 are not available for the types of transactions described above in this Section 4.3.

All Level 1Access Personswho are members of anInvestment Team must affirmatively assert as part of thepre-clearance trade approval process, thattheSamePre-Clearable Security is not underActive Consideration for Purchase or Sale for a Clientaccount managed by the Level 1 Access Person’s Investment Team.

4.4 Pre-Clearance of a Significant Personal Securities Position

In addition to thepre-clearance requirements of Section 3.4, a Level 1Access Person (including Household Family Members) must obtain advance written trade approval from theMAM Chief Investment Officer—Fixed Income or the Chief Investment Officer—Equity (or their designee) for any discretionary transaction (or series of transactions) which establishes a Beneficial Interest inaPre-Clearable Security valued at $100,000 USD or more (“Significant Positions”). Additionally, any discretionary transaction which increases or decreases an established Significant Position must be approved in the same manner.

4.5 Disclosure of Personal Investment Conflicts & Limited Offering Independent Review

A Level 1Access Person cannot recommend or participate in the investment decision-making process involving a particularSecurity for aClient account if theAccess Person also maintains aBeneficial Interest in the same issuer’sSecuritiesunless theAccess Person has disclosed theBeneficial Interest to theprimary portfolio manager for the relevantClient account or relevantMAM Chief Investment Officer. Following any initial oral disclosure, theAccess Person is required to make the same disclosure in writing to the primary portfolio manager and either (i) theChief Compliance Officeror (ii) the relevantMAM Chief Investment Officer.

In addition to the disclosure requirements (above), anAccess Personwith aBeneficial Interestin aLimited Offering (a.k.a., a private placement) is required to ensure that any final investment decision (for aClient account) involving the same issuer as theLimited Offering is subjected to an independent review by otherMAM investment personnel that do not hold aBeneficial Interestinthesame issuer’sSecurities.

4.6 1% and 5% Security Ownership Disclosure & Prohibitions

Any Level 1Access Person with aBeneficial Interestof 1% of more of an issuer or a class or series of an issuer’sSecurities must disclose such a fact in writing to theChief Compliance Officer.

If a Level 1Access Person holds aBeneficial Interest of 1% or more of an issuer or a class or series of an issuer’sSecurities then the sameAccess Person is prohibited from recommending or participating in the investment decision to purchase or sell the same issuer’s securities for aClient account.

If a Level 1Access Person serving as a portfolio manager or analyst holds aBeneficial Interest of 5% or more of an issuer or a class or series of the issuer’sSecuritiesthen theMAM entity theAccess Person is associated with is prohibited from purchasing the same issuer’sSecurities for aClient account.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 12

  PART 5   INITIAL AND PERIODIC REPORTING

The following requirements allowMAMto monitor and verifyAccess Person compliance with requirements theCode. AllAccess Personsmust initially and periodically thereafter make disclosures and compliance certifications regardingSecuritiesholdings,Securitiesaccounts andSecurities transactions in which theAccess Person has aBeneficial Interestin(this includes disclosures, holdings and transaction information forHousehold Family Members).

5.1 Requirement to Report SecuritiesAccounts

AllAccess Persons are required to report the name of broker, dealer, bank, or other entity with which theAccess Person maintains an account in which anySecuritiesare or can be held for theAccess Person’s Beneficial Interest(including accounts of Household Family Members).

Access Personsare required to report allSecurities accounts within 10 days of initially being designated anAccess Person. After this initial report ofSecurities accounts, anySecurities accounts opened in the future time must be reported no later than 10 calendar days following the opening of the account or prior to the first discretionary transaction in the account.To comply with theMAM Insider Trading Policy you are also required to inform any broker/dealer when you open a newSecurities account that you are employed by a financial institution and also whether you are registered with a broker-dealer.⁶

Hong Kong-basedAccess Persons (and theirHousehold Family Members) must obtain approval from theCode Administrator prior to opening any brokerage account.

⁶ Brokers and dealers are subject to certain rules designed to prevent favoritism toward anAccess Person’s accounts.Access Personsmay not accept negotiated commission rates that you believe may be more favorable than the broker grants to accounts with similar characteristics.

5.2 Duplicate Transaction Confirmations & Statements

EachAccess Personmust arrange for theCode Administratorto receive duplicate copies of trade confirmations ofReportable Securitiestransactions and, if requested⁷ by theCode Administrator, periodic account statements for anyReportable Securitiesaccounts in which theAccess Personhas aBeneficial Interestinif the account holds, or has the ability to hold,Reportable Securities (this requirement also applies to theSecuritiesconfirmations and statements ofHousehold Family Members).

Compliance Tip - What Securities Accounts Do I Need to Report?

Any account (including aHousehold Family Member’s account) that holds or can hold aSecurity. For instance here is anon-exclusive list of commonly reportedSecuritiesaccounts:

    ●    Brokerage Accounts

    ●    Mutual Fund Only Accounts

    ●    Custodial Securities Accounts

    ●    Manulife GSOP Plan Accounts

    ●    Certain 529 Plans (plans affiliated with or plans with investment options managed by Manulife or Manulife affiliated entity)

    ●    IRA Accounts

    ●    Stock Purchase Plans

    ●    Transfer Agent Accounts

    ●    Variable Life or Annuity Insurance Policies with underlyingAffiliated Mutual Fund investment options

    ●    Manulife Loan Program Mutual Fund Account

    ●    John Hancock Unified 401k Plan/Manulife RPS

    ●    Registered Retirement Savings Plan (RRSP)/RESP/TFSA

    ●    Uncertificated Book EntrySecurities

    ●    Physical possession of certificatedSecurities

    ●    Employee Stock Option Accounts

    ●    UK Individual Savings Accounts (ISA)

    ●    UK Self Invested Pension Plans (SIPP)

⁷ TheCode Administrator may rely on the operating groups ofManulife/John Hancock for administration of trading activity limitations and monitoring of market timing policies forManulife Affiliated Funds. To the extent theCode Administrator has ready access toSecurities transaction and holdings through aManulife Affiliate, theCode Administrator is not required to obtain duplicate confirmations or statements for such accounts.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 13

5.3 USA-Based Access Person Preferred Brokerage Account Requirement

AllUSA-basedAccess Persons who became employees ofMAMor a MAM Affiliateafter March 1, 2008 are required to maintain allReportable Securitiesaccounts established after March 1, 2008 (including theSecurities accounts ofHousehold Family Members) at one ofMAM’s Preferred Brokers unless theSecuritiesaccount has been qualified by theCode Administrator as anExempt Securities Account.A current list ofMAM’sPreferred Brokerscan be found on thePersonal Trading & Reporting Systemwebsite or by contacting theCode Administrator. Upon designation as anAccess Person, a person has 45 calendar days to (i) qualify anynon-compliantSecuritiesaccount as anExempt Securities Account or (ii) transfer all assets to aMAM Preferred Brokerand close thenon-compliant account.

5.4 Initial Holdings Report & Certification

After reporting all Securities accounts (Refer to Section 5.1), newAccess Personsmust file an Initial Holdings Report.⁸ This Initial Holdings Report is due within 10 calendar days after the person became anAccess Personand the submitted information must be current as of a date no more than 45 calendar days prior to the date the person became anAccess Person.

AnAccess Personmust submit with his or her Initial Holdings Report a certification that he or she: (i) has read and understands theCode;(ii) recognizes that he or she is subject to theCode; (iii) agrees to comply with theCoderequirements applicable to their designated access level; and (iv) has disclosed or reported all requiredReportable Securitiesholdings and allSecuritiesaccounts in which they have aBeneficial Interest (includingHousehold Family Member accounts).

⁸ The Initial Holdings Report will contain: (i) the title and type of eachReportable Securityin which the Access Person has anyBeneficial Interest; (ii) the exchange ticker symbol or CUSIP number and the number of shares or principal amount of eachReportable Security(each as applicable); (iii) the name of any broker, dealer, bank, or other entity with which theAccess Person maintains an account in which anySecuritiesare or can be held for theAccess Person’s direct or indirectBeneficial Interest; and (v) the date the report is submitted by theAccess Person.

5.5 Quarterly Transaction Report & Certification

AllAccess Personsmust file a Quarterly Transaction Report that discloses certain information about eachReportable Securitytransaction in which they have (or as a result of the transaction acquired) aBeneficial Interest (including transactions forHousehold Family Members) during the quarter covered by the Quarterly Transaction Report.⁹

EachAccess Person’s Quarterly Transaction Report is duewithin 30 calendar days after the end of each calendar quarter. EachAccess Person’sQuarterly Transaction Report must also include a certification that the submitted Quarterly Transaction Report includes all information required to be reported. In connection with the Quarterly Transaction Report Certification, allAccess Personsare alsorequired to certify to the accuracy of the listing ofSecurities accounts displayed inPersonal Trading & Reporting Systemor by alternative method as permitted bySection 5.8 of theCode.

Compliance Reminder: AutomaticPre-Population of Transaction and Holdings Data in the Personal Trading & Reporting System

As a convenience to certainAccess Persons,Code Administration works with certain brokers to obtainSecurities transaction and holding data topre-populate Quarterly Transaction and Annual Holdings Reports in the Personal Trading & Reporting System. Thepre-populated data may contain omissions or inaccuracies.It is eachAccess Person’s responsibility to contact theCode Administrator to correct any inaccurate transaction or holdings data prior to submitting a report or certification.

⁹ The Quarterly Transaction Report will include the following information: (i) the date of the transaction (“trade date”); (ii) the title of theReportable Security; (iii) the exchange ticker symbol or CUSIP number, the interest rate and maturity date, the number of shares or principal amount of eachReportable Security, the type of transaction or acquisition, the price at which the transaction was effected (each as applicable); (iv) the name of any broker, dealer, bank, or other entity with or through which the transaction was effected; and (v) the date the report is submitted by theAccess Person.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 14

5.6 Reporting of Gifts, Donations & Inheritances

AnAccess Person’s gift or donation of aPre-Clearable Security is considered a “sale” event for Level 1 and 2Access Persons (this includes gifts or donations byHousehold Family Members) and therefore requirespre-clearance approval prior to making the gift or donation. Additionally, any approved gift or donation event of aReportable Security must be accurately reflected in the next Quarterly Transaction Report (Refer to Section 5.5).

The receipt of a gift or an inheritance ofReportableSecuritiesshould be promptly reported to theCode Administrator to ensure the new holding is accurately accounted for. Note: the receipt of a gift or inheritance does not requirepre-clearance approval from Compliance.

5.7 Annual Holdings Report & Certification

AllAccess Personsmust file an Annual Holdings Report.¹⁰ TheAnnual Holdings Report is due within 45 calendar days of December 31st and must be current as of a date no more than 45 calendar days prior to the date this information is filed. EachAccess Personmust submit each Annual Holdings Report with a certification that he or she: (i) has read and understands theCode; (ii) recognizes that he or she is subject to theCode; (iii) has complied with (or has disclosed any failure to comply with) theCode’srequirements applicable to their designated access level; and (iv) has reported all violations of theCodeand all requiredReportableSecuritiesholdings andSecuritiesaccounts for which theAccess Person holds aBeneficial Interest(including the applicable holdings and accounts ofHousehold Family Members).

¹⁰ The Annual Holdings Report will include: (i) the title and type of eachReportable Securityin which they haveBeneficial Interest; (ii) the exchange ticker symbol or CUSIP number (as applicable) and the number of shares or principal amount of eachReportable Security(as applicable); (iii) the name of any broker, dealer, bank, or other entity with which theAccess Personmaintains an account in which anySecuritiesare or can be held for theAccess Person’sdirect or indirect benefit; and (iv) the date the report is submitted by theAccess Person.

5.8 Method of Reporting & Certifications

Access Personsare expected to use the intranet-basedPersonal Trading & Reporting System,to make their requiredSecurities account disclosures, Initial and Annual Holdings Reports,Quarterly Transaction reports and related certifications.¹¹ AnAccess Person that fails to make a required report or certification by the specified deadline will, at a minimum, be prohibited from engaging in discretionary personal trading until the reporting/certification requirement is satisfied and may give rise to other sanctions (this prohibition also applies to anySecuritiesaccount orSecuritiesof which theAccess Person has aBeneficial Interest,including theSecurities accounts andSecurities of Household Family Members). The timing of the deadlines for each reporting obligations are set by various regulations adopted under theSecurities Laws.Compliance may establish earlier deadlines than specified in this Part 5 to ensure compliance with the Securities Laws.

***

¹¹Access Person’s without access to thePersonal Trading & Reporting System will use other methods for reporting and certification as directed by theCode Administrator orChief Compliance Officer.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 15

  PART 6   CODE ADMINISTRATION

6.1 No Liability for Losses

MAM andManulife Affiliates and/or anyMAM Clients will not be liable for any losses incurred or profits avoided by anyAccess Persons orHousehold Family Member resulting from the implementation or enforcement of theCode.Access Persons must understand that their ability (as well as the ability of theHousehold Family Members) to buy and sellSecurities may be limited by theCode and that trading activity byMAM,MAM Clients, and/or otherManulife Affiliates may affect the timing of when anAccess Person (as well asHousehold Family Members) can buy or sell a particularSecurity.

6.2 Penalties for Code Violations

Penalties for violating theSecurities Lawscan be severe, both for the individuals involved and their employers. A person can be subject to penalties even if he or she does not personally benefit from the violation. Penalties may include civil injunctions, payment of profits made or losses avoided (“disgorgement”), jail sentences, fines for the person committing the violation, and fines for the employer or other controlling person.

In addition, any violation of theCodeis subject to the imposition of sanctions byMAM as may be deemed appropriate under the circumstances by MAM.These sanctions could include,without limitation, bans on personal trading, disgorgement of trading profits, and personnelaction, including termination of employment, where appropriate.Refer to MAM’sFine and Sanction Guidelines for further information.

6.3 Exemptions & Appeals

Exemptions fromCode provisions may be granted by the Chief Compliance Officer where warranted by applicable facts and circumstances, if permitted by law, and if theCCO determines and exemption would be in accord with the spirit of the General Principles of theCode and theSecurities Laws.Access Persons may direct their request for an exemption to theCode Administrator orChief Compliance Officer. TheChief Compliance Officer is also authorized to modify the personal trading provisions of thisCode as it applies to a specificMAM Associate where local law would prohibit the application of a specific provision.

IfAccess Person believes that aCode-related request has been incorrectly denied by theChief Compliance Officer, or that aCode-related action is not warranted, anAccess Person may make a written appeal of the decision or action within30-days of the decision or action to theEthics Oversight Committee.Code Administration will arrange an appropriate forum or communication for the consideration of appeals.

6.4 Code Amendments

TheChief Compliance Officer is permitted to approvenon-material amendments to the Code and theEthics Oversight Committee (orMAMBoard, if applicable) is responsible for approving any material amendments. For certainMAM Affiliated Mutual Fundclients,the respective Board of Trustees of theAffiliated Mutual Fund must approve any material changes to the code ofMAM within six (6) months of the adoption of the material change in accordance with the requirements of Rule17j-1 under the Investment Company Act of 1940.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 16

6.5 Code Interpretation & Administration

TheChief Compliance Officer has general administrative responsibility for theCode and is responsible for establishing policies and procedures for the administration of theCode; monitoring and testing forCode compliance; ensuringCode training is provided toAccess Persons; granting exceptions or exemptions to any provision of theCode,on an individual or a class basis; appointing one or moreCode Administratorsand defining the scope of his or her authority andday-today responsibilities (in addition to those specified in theCode); oversight of theCode Administrator’sCodeactivities; considering and recommending material amendments to theCodeto the Ethics Oversight Committee(orMAMBoard, if applicable); and reviewing and considering any decisions made by theCode Administratorat the request of aMAM Associateor involving ordinary sanctions imposed related toCodeviolations.

Ethics Oversight Committee (orMAMBoard, if applicable) retains the ultimate discretion as to the interpretation theCode’s provisions in any given situation, rendering material sanctions for violations of theCode, and rendering final judgments on anyAccess Person’s appeal of any decision or ordinary sanction imposed by theChief Compliance Officer.

6.6 Recordkeeping

TheChief Compliance OfficerorCode Administratormaintains or causes to be maintained, the following records: (1) a copy of theCodeor any predecessorMAM code of ethicswhich has been in effect during the most recent5-year period; (2) a record of any violation of theCode, or any predecessorMAM code of ethics, and of any action taken as a result of such violation in the5-year period following the end of the fiscal year in which the violation took place; (3) a list of all persons currently or within the most recent5-year period who were required to make reports pursuant to theCode (or any predecessorCode) and the person(s) who were responsible for reviewing these reports; (4) copies of all acknowledgements of each person’s receipt of theCode,Initial and Annual Holdings Reports, Quarterly Transaction Reports, and duplicate brokerage confirmations andSecuritiesaccount statements (as applicable) filed during the most recent5-year period; and (5) a record of the approval of, and rationale supporting, the acquisition ofSecuritiesbyAccessPersonsin anInitial Public Offering orLimited Offeringfor at least 5 years after the end of the fiscal year in which the approval is granted.¹²

Code records will be maintained for the first 2 years in an office ofMAM (in paper or accessible electronically) and in an easily accessible place for the time period as required by any applicable regulations thereafter.¹³

***

¹²  In reviewing apre-clearance request for aLimited Offeringor IPOtheChief Compliance Officermay consider the following factors: (1) whether the investment opportunity should be or can be reserved forMAMclients; (2) is it being offered because of a relationship toMAMor position withinMAM; and (3) any other relevant factors in the sole discretion of theChief Compliance Officer. TheChief Compliance Officer orCode Administrator will document the rationale for any approval decision.

¹³  Code records forMAM Hong Kong will be maintained for at least 7 years and maintained in an easily accessible place.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 17

Appendix A	Definitions ofItalicizedCode of EthicsTerms
Access Person	Refer to definition in Section 1.2 of thisCode.
Active Consideration for Purchase or Sale	ASecurity is underActive Consideration for Purchase or Sale once aMAM portfolio manager forms a specific intent to purchase or sell aSecurity for aMAM Client account.
Affiliated Mutual Fund	AnyMutual Fund for whichManulifeserves as an investment adviser (orsub-adviser) or whose investment adviser (orsub-adviser) controls, is controlled by, or is under common control withManulife. (e.g., Manulife orJohn HancockMutual Funds).
Automatic Investment Plan	A program in which regular periodic purchases (or withdrawals) are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation. Examples include automatic dividend reinvestment plans and payroll deduction purchase plans.
Beneficial Interest	An Access Personis deemed to have aBeneficial Interestin any transaction in which theAccess Person controls or has the opportunity to directly or indirectly profit or share in the profit derived from theSecurities transacted.An Access Personis presumed to have aBeneficial Interestin the following Securities and related transaction activities: (1) Securities owned by anAccess Person in his or her name; (ii) Securities(andSecuritiesaccounts) owned by Household Family Members; (iii) Securitiesowned by an Access Personindirectly through an account or investment vehicle for his or her benefit, such as an IRA/RRSP/RESP/ISA/SIPP, family trust or family partnership; (iv) Securitiesowned in which the Access Personhas a joint ownership interest, such asSecurities owned in a joint brokerage account; and (v) Securitiesover which theAccess Person has discretion or gives advice (other thanMAMClientaccounts) and includesSecuritiesowned by trusts, private foundations or other charitable accounts for which the Access Personhas investment discretion. Beneficial Interest is interpreted in the same manner under theCode as it would be under Rule16a-1(a)(2) under the U.S. Securities Exchange Act of 1934.
Chief Compliance Officer	The termChief Compliance Officerrefers each Chief Compliance Officer of the applicableMAM entity adopting thisCode.
Client	For purposes of thisCode, the term “Client” means the specific person or entity that has an investment advisory or investmentsub-advisory services agreement (or supervised investment delegation affiliate arrangement) with the specificMAMentity adopting this Code.
Closed-End Investment Company	AClosed-End Investment Companyis a registered investment company that issues a fixed number of shares and is usually traded on a major stock exchange. In contrast, anopen-end investment company(i.e., mutual fund) continuously offers new shares to the public and repurchases shares at net asset value. Note: Many REITs areClosed-End Investment Companies.
Code Administrator	Code Administratorrefers to the person (or persons) designated by the relevantMAM Chief Compliance Officerto be primarily responsible for theday-to-day administration of theCode.
Direct Obligations of the Government of the US or UK	Any security directly issued or guaranteed as to principal or interest by the United States. Examples of direct obligations include Cash Management Bills, Treasury Bills, Notes and Bonds, and STRIPS. It is important to note that Federal National Mortgage Association (Fannie Mae), and Federal Home Loan Mortgage Corporation (Freddie Mac)Securities are notDirect Obligations of the Government of the United States. Directed Obligations of the UK refers to the following list ofSecuritiesissued and guaranteed by the United Kingdom Treasury: Premium Savings Bonds, Index Linked Savings Certificates, Fixed Interest Savings Certificates, Guaranteed Equity Bonds, Capital Bonds, Children’s Bonus Bonds, Fixed Rate Savings Bonds, Income Bonds, and Pensioners Guaranteed Income Bonds.Refer to M&G Investment Management Ltd. SECNo-Action Letter (Sept. 10, 2002)

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 18

Appendix A	Definitions ofItalicizedCode of EthicsTerms(Continued)
Ethics Oversight Committee	The Ethics Oversight Committee is an ad hoc or standing compliance committee composed of relevantMAM Chief Compliance Officer and certainMAMsenior management.
Exempt ETF	AnExempt ETFis an exchange-traded fund that has as its underlying tracking instrument the S&P 100, S&P Midcap 400, S&P 500, Hang Seng Index, Hang Seng China Enterprises Index, TSX 60, EAFE, FTSE 100, and Nikkei 225.Exempt ETFs also include options and futures contracts on the S&P 100, S&P Midcap 400, S&P 500, TSX 60, EAFE, FTSE 100, and Nikkei 225.Exempt ETF transactions do not require advancepre-clearance approval. Refer to APPENDIX C for further information on reportingExempt ETF transactions and holdings.
Exempt Securities Accounts	Withwritten approval fromCode Administrator, aUS-basedAccess Persons (andHousehold Family Members) subject to the Preferred Broker Requirement of Section 5.3 are permitted to maintain aSecurities account with an entity other than with aPreferred Broker, if theSecurities account can meet one of the following exemptions: (i) it contains onlySecurities that can’t be transferred; (ii) it exists solely for products or services that one of thePreferred Brokers cannot provide; (iii) it exists solely because your spouse’s or significant other’s employer prohibits external covered accounts; (iv) it is managed by a third-party registered investment adviser; (v) it is restricted to trading interests in 529 College Savings Plans; (vi) it is associated with an ESOP (employee stock option plan) or an ESPP (employee stock purchase plan); (vii) it is required by a direct purchase plan, a dividend reinvestment plan, or anAutomatic Investment Plan with a public company in which regularly scheduled investments are made or planned; (viii) it is aMutual Fund only account; (ix) it is required by a trust agreement; (x) it is associated with an estate of which theAccess Person is the executor, but not a beneficiary, and involvement with the account is temporary; (xi) transferring the account would be inconsistent with other applicable rules; or (xii) other exception approved by theCode Administrator.
High Quality Short Term Debt Instrument	Any instrument that has a maturityat issuance of less than 366 days and that is rated in one of the two highest rating categories by a nationally recognized rating organization(e.g., S&P, Moody’s, Fitch, A.M. Best).
Household Family Member	AnAccess Person’s spouse, “significant other,” minor children, or other family member whoalso shares the same household with theAccess Person. AnAccess Person’s “significant other” is defined as a personwho (i) shares the same household with theAccess Person; (ii) shares living expenses with theAccess Person; and (iii) is in a committed personal relationship with theAccess Person and there is an intention to remain in the relationship indefinitely. TheCCOorCode Administrator, after reviewing all the pertinent facts and circumstances, may determine, if not prohibited by applicable law, that an indirectBeneficial InterestoverSecuritiesheld by members of theAccess Person’s Household Family Membersdoes not exist or is too remote for purposes of theCode’s requirements.
Initial Public Offering	An offering ofSecuritiesregistered under the U.S. Securities Act of 1933 (or comparablenon-U.S. registration statute or regime), the issuer of which, immediately before the registration, was not subject to the reporting requirements of Sections 13 or 15(d) of the U.S. Securities Exchange Act of 1934 (or comparablenon-U.S. compulsory reporting requirements).
Investment Club	A group of people who pool their assets in order to make joint decisions (typically a vote) on whichSecuritiesto buy, hold or sell.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 19

Appendix A	Definitions ofItalicizedCode of EthicsTerms (Continued)
Investment Team	An individualInvestment Team describes the grouping ofMAManalysts and portfolio managers who make or participate in making recommendations regarding the purchase or sale of securities for designatedMAM-advisedClient accounts. TheCode Administrator orCCO may also assign certain traders to specificInvestment Teams if the trader regularly participates in theSecurity recommendation process with the analysts or portfolio managers.
Limited Offering	ASecuritiesoffering that is exempt from registration under the U.S. Securities Act of 1933, pursuant to Section 4(2) or Section 4(6) or pursuant to Rule 504, Rule 505, or Rule 506 under the Securities Act of 1933, or equivalent foreign statute or regulation. Also known as a private placementSecurity (e.g., private investment funds, “hedge funds,” limited partnerships,etc.)
MAM Associate	MAM Associates are: (i) any partner, officer, director (or other person occupying a similar status or performing similar functions) ofMAM; (ii) an employee ofMAM (including contractors,co-ops and interns); (iii) any person who provides investment advice on behalf ofMAM and is subject to the supervision and control ofMAM; (iv) any person meeting the definition ofAccess Person; and (v) any other person who theCode Administrator deems aMAM Associate.14
Manulife	Manulife Financial Corporation
Manulife Affiliate	All persons or entitiescontrolled byManulife.
Mutual Fund	(a) Any U.S. registeredopen-end investment management company (i.e., mutual fund); or (b) a Canadian or foreign regulated mutual fund (UCITs etc.) which meets the following 4 requirements: (i) redemption on demand at the net asset value of fund shares, (ii) forward pricing reflecting the net asset value of fund shares, (iii) daily calculation of the fund’s net asset value in a manner consistent with principles and rules adopted under the Investment Company Act of 1940, and (iv) absence of a secondary market.Refer to SECNo-Action Letter, Manufacturers Adviser Corp., Sept. 10, 2002.
No Direct or Indirect Control Over Account	Purchases, sales or dispositions ofSecuritiesover which a person has no direct or indirect influence or control (e.g., a “blind trust” or certain managed accounts which theAccess Person has obtained from theCode Administrator a written exemption).
Personal Trading & Reporting System	Theweb-based reporting and certification system used byMAMto facilitate compliance with certain periodic reporting andpre-clearance obligations imposed under theCode (a.k.a.,PTCC).Access Persons not provided with access to the PTCC will make reports, disclosures, and certifications in an alternate method as directed by theCode Administrator.
Pre-Clearable Security	AllSecuritiesexcept thoseSecuritieslisted on APPENDIX C of theCode as exempt from thepre-clearance requirements of theCode.
Preferred Brokers	A current list ofMAM’sPreferred Brokerscan be found on thePersonal Trading & Reporting Systemwebsite or by contacting theCode Administrator. Refer to Section 5.3 for further information regarding thePreferred Broker requirements.

¹⁴ In reliance on the PrudentialSECno-action letter, certainMAM SEC-registered investment advisers may include in the definition of “MAM Associate” any person of aMAM Affiliate who is involved, directly, or indirectly, inMAM’s investment advisory activities.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 20

Appendix A	Definitions ofItalicizedCode of EthicsTerms (Continued)
Pro Rata Discretionary Transactions	Purchases or other acquisitions or dispositions ofSecuritiesresulting from the discretionary exercise of rights acquiredfrom an issuer as part of a pro rata distribution to all holders of a class ofSecuritiesof the issuer. (e.g., discretionary participation in takeovers, rights & tender/exchange offerings)
Reportable Security	AllSecuritiesexcept thoseSecuritieslisted as exempt from the Initial and Annual Holdings Reportand Quarterly Transaction Report requirements on APPENDIX C of theCode.
SamePre-Clearable Security	For an equitySecurity, theSamePre-Clearable Security would include all other equity securities of the same issuer or, other instrument whose value is derived from the value of the issuer’s equitySecurities. For a debtSecurity, theSamePre-Clearable Security would include all other debt instruments of the same issuer as well as any instrument whose value is derived from the credit, value or reference to the issuer’s debt.
Security (Securities)	A “security” as defined by Section 1(1) of the Ontario Securities Act, the Hong Kong Securities and Futures Ordinance, Section 3(a)(10) or the Investment Advisers Act of 1940.Examples include but are not limited to: any note, stock, treasury stock, security future, bond, debenture, evidence of indebtedness, mutual funds,closed-end funds, unit investment trusts, REITS, ETFs, commodity funds, broker cds, certificate of interest or participation in any profit-sharing agreement, collateral-trust certificate,pre-organization certificate or subscription, transferable share, investment contract, security-based swap, voting-trust certificate, certificate of deposit for a security, fractional undivided interest in oil, gas, or other mineral rights, any put, call, straddle, option, or privilege on any “security” (including a certificate of deposit) or on any group or index of securities (including any interest therein or based on the value thereof), or any put, call, straddle, option, or privileged entered into on a national securities exchange related to foreign currency, or, in general, any interest or instrument commonly known as a “security”, or any certificate of interest or participation in, temporary or interim certificate for, receipt for, guarantee of, or warrant or right to subscribe to or purchase any of the foregoing. References to aSecurity also includes any warrant for, option in, or “security” or other instrument immediately convertible into or whose value is derived from that “security” and any instrument or right which is equivalent to that “security.” The definition ofSecurityapplies regardless of the registration status or domicile of registration of theSecurity(i.e., the termSecurityincludes both private placements/limited partnership interests and publicly-traded securities as well as domestic and foreignSecurities). For purposes of thisCode, the definition ofSecurities also includes other instruments and interests labeled as reportable on APPENDIX C of this Code.
Securities Laws	TheSecurities Laws include various domestic and foreign securities-related laws, statutes and rules/regulations that govern MAM’s investment management activities and includes: Ontario Securities Act, UK Financial Services Authority regulations, the Securities and Futures Ordinance of Hong Kong, Securities and Futures Act (Singapore), the Securities Act of 1933 (US), the Securities Exchange Act of 1934 (US), the Sarbanes-Oxley Act of 2002 (US), the Investment Company Act of 1940 (US), the Investment Advisers Act of 1940 (US),Title V of the Gramm-Leach-Bliley Act (US), and the Bank Secrecy Act (US) (as it applies to funds and investment advisers).

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 21

Appendix B	Code of Ethics InitialAdoption and Amendment Dates
Manulife Asset Management (US) LLC	Initially Adopted January 12, 2012, Amended Effective Date September 1, 2013
Manulife Asset Management (North America) Limited	Initially Adopted February 22, 2012, Amended Effective Date November 1, 2013
Manulife Asset Management Limited	Initially Adopted February 22, 2012, Amended Effective Date November 1, 2013
Manulife Asset Management (Europe) Limited	Initially Adopted September 1, 2013

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 22

APPENDIX C Securities Reporting &Pre-Clearance Manulife Asset Management Code of Ethics	Reportable Security: Initial and Annual Holdings Reports	Reportable Security: Quarterly Transaction Reports	Pre-Clearable Security?
Unless otherwise indicated on this chart, (i) all Securities positions must be reported initially and annually thereafter, (ii) allSecurities transactions must receive advancepre-clearance approval, and (iii) allSecuritiestransactions must be reported quarterly. (italicized terms are defined in the Code)	Does the Access Personneed to report the following types ofSecuritiesholdings?	Does the Access Person need to report transactions in the following types ofSecurities?	Does theAccess Person need to obtainpre-clearance approval prior to transacting in the following types ofSecurities? Note: Level 3 Access Persons are only required to obtainpre-clearance approval for transactions involving IPOs, Limited Offerings, andClosed-End Investment Companies advised by a Manulife Affiliate
GovernmentSecurities
Direct Obligations of the Government of the US or UK	No	No	No
State, Province or Municipal Bonds	Yes	Yes	Yes
Direct Obligations of the Governments of Canada, Japan, Germany, France or Italy	Yes	Yes	No
Money Market Instruments/Commodities/Currency
Bankers Acceptances	No	No	No
Bank Certificates of Deposit	No	No	No
Brokerage Certificates of Deposit	Yes	Yes	No
Commercial Paper	No	No	No
High Quality Short-Term Debt Instruments	No	No	No
Repurchase Agreements	No	No	No
Money Market Funds (including Money MarketAffiliated Mutual Funds)	No	No	No
Physical Commodities and Options and Futures on Commodities (not commodity ETFs orclosed-end funds)	No	No	No
Foreign and Domestic Currency Holdings/ Transactions (including currency options and futures)	No	No	No

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 23

APPENDIX C Securities Reporting &Pre-Clearance(Continued) Manulife Asset Management Code of Ethics	Reportable Security: Initial and Annual Holdings Reports	Reportable Security: Quarterly Transaction Reports	Pre-Clearable Security?
Unless otherwise indicated on this chart, (i) allSecurities positions must be reported initially and annually thereafter, (ii) allSecurities transactions must receive advancepre-clearance approval, and (iii) allSecuritiestransactions must be reported quarterly. (italicized terms are defined in the Code)	Does theAccess Person need to report the following types ofSecuritiesholdings?	Does theAccess Person need to report transactions in the following types ofSecurities?	Does theAccess Person need to obtainpre-clearance approval prior to transacting in the following types ofSecurities? Note: Level 3 Access Persons are only required to obtainpre-clearance approval for transactions involving IPOs, Limited Offerings, andClosed-End Investment Companies advised by a Manulife Affiliate
IPOs / Private Placements / Limited Offerings
IPOs(Note: Prohibited for Access Person Level 1)	Yes	Yes	Yes
Private Placements/Private Funds/Limited Offerings	Yes	Yes	Yes
Issuer Event Transactions / Automatic Investment Plans
Involuntary Issuer Transactions and Holdings (stock dividends, stock splits/reverse splits, or other similar reorganizations or distributions, call of a debt security, and spin-offs of shares to existing holders)	Yes	Yes	No
IssuerPro Rata Discretionary Transactions/Elections (purchases or other acquisitions or dispositions resulting from the discretionary exercise of rights acquiredfrom an issuer as part of a pro rata distribution to all holders of a class ofSecuritiesof such issuer) (e.g., discretionary participation in takeovers, rights & tender/exchange offerings)	Yes	Yes	Yes.Pre-clearance approval for discretionary elections should be sought bymanually phoning or emailing the Code Administratordirectly.
Automatic Investment Plans (a program in which regular periodic purchases or withdrawals are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation) (for Mutual Funds AIPs Refer to below)	Yes. You must add up all of the Plan transactions for the year and reflect the activity on the Annual Holdings Report	No. You do not need to report automatic(non-discretionary) Plan transactions on the Quarterly Transaction Report	No, however, transactions that override the automatic preset schedule (discretionary purchases /sales, discretionary changes in individual security selection) must bepre-cleared.Note: You do not need topre-clear a change to your money contribution level into a Plan.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 24

APPENDIX C Securities Reporting &Pre-Clearance(Continued) Manulife Asset Management Code of Ethics	Reportable Security: Initial and Annual Holdings Reports	Reportable Security: Quarterly Transaction Reports	Pre-Clearable Security?
Unless otherwise indicated on this chart, (i) allSecurities positions must be reported initially and annually thereafter, (ii) allSecurities transactions must receive advancepre-clearance approval, and (iii) allSecuritiestransactions must be reported quarterly. (italicized terms are defined in the Code)	Does theAccess Person need to report the following types ofSecurities holdings?	Does theAccess Personneed to report transactions in the following types ofSecurities?	Does theAccess Person need to obtainpre-clearance approval prior to transacting in the following types ofSecurities? Note: Level 3 Access Persons are only required to obtainpre-clearance approval for transactions involving IPOs, Limited Offerings, andClosed-End Investment Companies advised by a Manulife Affiliate
Issuer Event Transactions / Automatic Investment Plans
Dividend Reinvestment Plan Automatic Transactions	Yes	No	No
Issuer Direct Stock Plan Automatic Transactions	Yes	No	No
Issuer Direct Stock PlanNon-Automatic Transactions (discretionary transactions)	Yes	Yes	Yes. Apre-cleared transaction instruction is valid until executed by the Plan.
Investment CompanySecurities
Closed-End Investment Companies	Yes	Yes	Yes
Exchange Traded Funds (ETFs) and Exchange Traded Notes	Yes	Yes	Yes, however,Exempt ETFsdo not need to bepre-cleared (Refer to definition in Code)
Money Market Funds (including Money MarketAffiliated Mutual Funds)	No	No	No
Mutual Funds*(non-affiliated)	No	No	No
* Affiliated Mutual Funds	Yes	Yes	No
*Affiliated Mutual Funds interests held by or through the Manulife Registered Pension Plan (RPS), Manulife Registered Retirement Savings Plan (RRSP), John Hancock Unified 401k Plan, other employer-sponsored retirement plan, 529/RESP plan, or any other account.	Yes	Yes, however do not report automatic transactions/rebalances (in accordance with a predetermined schedule/ allocation) on the Quarterly Transaction Report	No
* Affiliated Mutual Funds held through a variable (annuity or life) insurance product separate account/unit investment trust	Yes (reportAffiliated Mutual Fund unit values)	Yes, however do not report automatic transactions/rebalances (in accordance with a predetermined schedule/ allocation) on the Quarterly Transaction Report	No

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 25

APPENDIX C SecuritiesReporting &Pre-Clearance (Continued) Manulife Asset Management Code of Ethics	Reportable Security: Initial and Annual Holdings Reports	Reportable Security: Quarterly Transaction Reports	Pre-Clearable Security?
Unless otherwise indicated on this chart, (i) allSecurities positions must be reported initially and annually thereafter, (ii) allSecurities transactions must receive advancepre-clearance approval, and (iii) allSecurities transactions must be reported quarterly. (italicized terms are defined in the Code)	Does theAccess Person need to report the following types ofSecurities holdings?	Does theAccess Person need to report transactions in the following types ofSecurities?	Does theAccess Person need to obtainpre-clearance approval prior to transacting in the following types of Securities? Note: Level 3 Access Persons are only required to obtainpre-clearance approval for transactions involving IPOs, Limited Offerings, andClosed-End Investment Companies advised by a Manulife Affiliate
Employee Compensation Instruments
MFC Shares in the MFC Global Share Ownership Plan (GSOP)	Yes	Purchases—No Sales—Yes	No
MFC Restricted Share Units (RSU), Deferred Share Units (DSU), or Performance Share Units (PSU)	No	No	No
Options Acquired from MFC or Other Public Company Employer as Part of Employee Compensation (MFC Solium Account options)	Yes	Yes	Grants -No. You do not need topre-clear a MFC option grant but do need to report the grant in your quarterly transaction report. Exercising Options - Yes. You do need topre-clear a sale or exercise of these employment-related options.
Employer Phantom Stock/Phantom Option Interest (granted as compensation to employee, only employer can redeem interest and interest isnon-transferrable)	No	No	No
Gifts / Blind Trusts / Managed Accounts
Gifts, Inheritances, or Donations ofReportable Securities(received or given)	Yes	Yes	Securities Gifts & Inheritances Received-No Securities Given or Donated - Yes
No Direct or Indirect Control Over Account (Securitiesheld in, purchased/sold for an account where a person does not have direct or indirect influence or investment/ proxy voting control, e.g., Blind Trusts,Certain Managed Accounts)	No*	No*	No* *However, you must report initial and annual holdings in (as well aspre-clear and report quarterly transactions for) aManaged Account unless the Access Person has obtained a specific writtenpre-clearance or reporting exemption from theCode Administrator.

Complete definitions foritalicizedterms may be found in APPENDIX A of theCode. 26