EIM is a wholly-owned subsidiary of Equitable Financial Life Insurance Company

Statement of General Principles.

The interests of the Funds’ shareholders are paramount, and all of the Funds’ personnel must conduct themselves and their operations to give maximum effect to this tenet by assiduously placing the interests of the shareholders before their own.

All personal transactions in securities by the Funds’ personnel must be accomplished so as to avoid even the appearance of a conflict of interest on the part of such personnel with the interests of the Funds and their shareholders.

All of the Funds’ personnel must avoid actions or activities that allow (or appear to allow) a person to profit or benefit from his or her position with respect to the Funds, or that otherwise bring into question the person’s independence or judgment.

For the purpose of the Funds, the term “shareholder” shall be deemed also to include owners of variable annuity contracts and variable life insurance policies funded through separate accounts investing in a Fund and participants in The Equitable 401(k) Plan.

Definitions.

“Access Person” means:

any Advisory Person of a Fund or of the Fund’s Investment Adviser;

any director, officer, or general partner or employee of Equitable Distributors who, in the ordinary course of business makes, participates in or obtains information regarding, the purchase or sale of Covered Securities by a Fund for which the principal underwriter acts, or whose functions or duties in the ordinary course of business relate to the making of any recommendation to a Fund regarding the purchase or sale of Covered Securities.

EIM Compliance will maintain a list of Access Persons under this Code, which will be updated from time to time as necessary or appropriate.

“Advisory Person” of the Funds or of the Investment Adviser means:

any director, officer, general partner or employee (including temporary employees, interns or consultants whose assignments exceed 90 days) of a Fund or the Investment Adviser (or of any company in a control relationship to a Fund or the Investment Adviser) who, in connection with his or her regular functions or duties, makes, participates in, or obtains information regarding the purchase or sale of Covered Securities by the Fund, or whose functions relate to the making of any recommendations with respect to the purchases or sales; and

any natural person in a control relationship to a Fund or the Investment Adviser who obtains information concerning the recommendations made to the Fund with regard to the purchase or sale of Covered Securities by the Fund.

“Sub-Adviser” means any entity who pursuant to a contract with a Fund or EIM, regularly furnishes advice to a Fund with respect to the desirability of investing in, purchasing or selling securities or other property, or is empowered to determine what securities or other property shall be purchased or sold by the Fund.

A security is “being considered for purchase or sale” when a recommendation to purchase or sell a Covered Security for the Fund has been made and communicated and, with respect to the person making the recommendation, when such person seriously considers making such a recommendation.

“Beneficial Ownership” shall be interpreted in the same manner as it would be under Section 16 of the Securities Exchange Act of 1934, as amended, (“Exchange Act”) and Rule 16a-1(a)(2) thereunder. A person is a “beneficial owner” of a security for purposes of the Code if he or she, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, has or shares a direct or indirect pecuniary interest in the securities. A pecuniary interest means the opportunity, directly or indirectly, to profit or share in any profit derived from a transaction in the subject securities. An indirect pecuniary interest includes, but is not limited to: (1) securities held by members of a person’s immediate family sharing the same household (for example, spouse or equivalent domestic partner, minor children, a relative, such as an adult child, stepchild or parent, who shares the home and to whom a person provides financial support); (2) a general partner’s proportionate interest in the portfolio securities held by a general or limited partnership; (3) a person’s right to dividends that is separated or separable from the underlying securities; (4) a person’s interest in securities held by a trust (for example, where the person or immediate family member is a beneficiary of the trust); and (5) a person’s right to acquire securities through the exercise or conversion of any derivative security, whether or not presently exercisable. A person will be deemed to have beneficial ownership of securities in his/her individual retirement account and securities in his/her 401(k) account or similar retirement plan, and spousal retirement plan accounts, even if the person has chosen to give someone else investment discretion over the account. A person who has and exercises power of attorney over an account, or who has investment discretion over an account that could hold Covered Securities, is deemed to be a beneficial owner of the account.

“Board” or “Board of Trustees” means the Boards of Trustees of the Funds.

“Control” shall have the same meaning as that set forth in Section 2(a)(9) of the 1940 Act, which states that “control” means “the power to exercise a controlling influence over the management or policies of a company, unless such power is solely the result of an official position with such company.” Ownership of 25% or more of a company’s outstanding voting securities is presumed to give the holder thereof control over the company. Such presumption may be countered by the facts and circumstances of a given situation but shall continue until the SEC makes a determination to the contrary. This definition is subject to any amendments in text or interpretation of Section 2(a)(9) of the 1940 Act.

“Compliance Officer” refers to each Fund’s Compliance Officer or any person designated by the Fund to perform certain compliance functions.

“Covered Account” means:

All accounts in the name of the person;

All accounts of the person’s spouse³;

All accounts of any minor children or other relatives (by marriage or otherwise) living in the person’s home⁴;

All accounts in which any of the foregoing persons had any beneficial ownership interest or over which he or she exercises control or investment influence; and

All accounts of non-immediate relative or non-relative (i.e., roommate, nanny) sharing the household are not covered unless you have the opportunity either to share profits from such securities or exert investment influence or control.

“Covered Security” means any security as defined in Section 2(a)(36) of the 1940 Act including any stock, bond, future, investment contract or any other instrument that may be considered a “security.” The term “Covered Security” is very broad and includes:

Options on securities, on indexes and on currencies;

All kinds of limited partnerships (e.g., LP, LLP, etc.);

Foreign unit investment trusts and foreign mutual funds;

Private investment funds, hedge funds, and investment clubs;

Closed-end mutual funds and unit investment trusts;

Shares of exchange-traded funds (“ETFs”); and

Shares of open-end mutual funds registered under the 1940 Act that are managed by the Investment Adviser or affiliates of the Investment Adviser.

Direct obligations of the Government of the United States or any agency thereof;

Banker’s acceptances, bank certificates of deposit, commercial paper and high-quality short-term debt instruments, including repurchase agreements; and

Shares issued by money market funds registered under the 1940 Act; and

As used herein, the term “spouse” includes any domestic partner and common law spouse.

This includes any adult child, grandchild, parent, step-parent, grandparent, siblings and in-laws.

Shares of open-end mutual funds registered under the 1940 Act that are not managed by the Investment Adviser or affiliates of the Investment Adviser.

“Disinterested Trustee” means a Trustee of a Fund who is not an “interested person” of the Fund within the meaning of Section 2(a)(19) of the 1940 Act.

“Fund” means the 1290 Funds, EQAT, or VIP Trust or each of their separate series (each a “Portfolio”).

“Initial Public Offering” means an offering of securities registered under the Securities Act of 1933, as amended, (“1933 Act”), the issuer of which, immediately before the registration, was not subject to the reporting requirements of Sections 13 or 15(d) of the Exchange Act.

“Investment Adviser” or “EIM” means Equitable Investment Management Group, LLC (also doing business as 1290 Asset Managers).

“Investment Personnel” means:

all Access Persons who occupy the position of portfolio manager (or who serves on an investment committee that carries out the portfolio management function) with respect to a Fund (or any Portfolio);

all Access Persons who, in connection with their regular functions or duties, make or participate in making any recommendations regarding the purchase or sale of any security by a Fund (or any Portfolio);

any natural person who controls a Fund or the Investment Adviser and who obtains information concerning recommendations made to or by the Fund with respect to the purchase or sale of a security by the Fund.

“Purchase or sale of a Covered Security” includes, among other things, the writing of an option to purchase or sell a Covered Security.

The “Restricted Period” is the number of days before or after a Security is being purchased or sold by a Fund or Portfolio during which, subject to an exception under the particular circumstances made by the Compliance Officer in his or her discretion, no Advisory Person may purchase or sell, directly or indirectly, any security in which he or she had or by reason of such transaction acquires any Beneficial Ownership.

“Review Officer” shall mean the person charged with the responsibility, at any given time, to pre-clear trades, grant exceptions to prohibitions under the Code, receive reports and notices required by this Code to be generated, and to accomplish any other requirement of this Code related to the oversight of activities, the exercise of discretion or the making of decisions relating to the activities of persons covered by this Code. Generally, this person will be the CCO; however, the CCO may designate other members of the EIM Compliance Department as a Review Officers.

A person may be designated by the Board or the CCO to act as the Review Officer for purposes of this Code without otherwise formally carrying that title or the responsibility for functions otherwise generally associated with the responsibilities of a Review Officer.

The Review Officer may delegate certain functions as appropriate.

The Companies may have separately designated Review Officers.

A “Covered Security held or to be acquired” by the Fund means (1) any Covered Security which, within the most recent fifteen (15) days, (a) is or has been held by any Portfolio of the Fund, or (b) is being or has been considered for purchase by any Portfolio of a Fund; and (2) any option to purchase or sell and any security convertible into or exchangeable for a Covered Security described in (1) of the definition.

A Covered Security is “being purchased or sold” by any Portfolio of a Fund from the time when a purchase or sale program has been communicated to the person who places the buy and sell orders for any Portfolio of the Fund until the time when such program has been fully completed or terminated.

Limitations on Personal Securities Transactions.

Access Persons. The following limitations apply to all Access Persons:

In connection with the purchase or sale, directly or indirectly, of a Covered Security held or to be acquired by any Portfolio of a Fund, or the purchase or sale, directly or indirectly, of shares of any Portfolio of a Fund, no Access Person shall:

employ any device, scheme or artifice to defraud the Fund or any Portfolio of the Fund;

make to the Fund any untrue statement of a material fact or omit to state to the Fund a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading;

engage in any act, practice or course of business that would operate as a fraud or deceit upon any Portfolio of the Fund;

engage in any manipulative practice with respect to the Fund or any Portfolio of the Fund. Such acts shall include, but not be limited to, the following:

intentionally inducing or causing the Fund to take action or to fail to take action for the purpose of achieving a personal benefit rather than to benefit the Fund. Examples of this violation include:

causing any Portfolio of the Fund to purchase a Covered Security owned by the individual for the purpose of supporting or driving up the price of the Security; and

causing any Portfolio of the Fund to refrain from selling a Covered Security in an attempt to protect the value of the individual’s investment, such as an outstanding option.

use actual knowledge of transactions for any Portfolio of the Fund to profit by the market effect of such transactions;

transact in shares of an ETF listed on the Restricted List maintained by the CCO or designee;

engage in short-term, or rapid, trading in shares of any Portfolio of a Fund.⁵ For purposes of this Code, a short-term trade is a purchase (or sale) of shares of any Portfolio and a subsequent sale (or purchase) of shares of the same Portfolio within a five-business day period; or

sell short a Covered Security.

Pre-clearance. All Access Persons must pre-clear in writing all proposed personal transactions in futures and ETFs that are held by a Fund with the appropriate Review Officer prior to proceeding with the securities transaction; provided, however, that de minimis trades (generally defined as involving 100 shares or fewer) are not required to be precleared.

Clearance authorizations are effective only until the close of trading on the date the approval is received, unless otherwise indicated in writing.

Upon request, the Review Officer will promptly provide notifications of each Personal Trading Request and Authorizations to the Funds’ CCO.

Blackout Periods.

No Access Person may transact in a particular ETF held by a Fund on the same day that the Fund transacts in that ETF; provided, however, that de minimis trades (generally defined as involving 100 shares or fewer) are not restricted.

As a reminder, the prohibition on short-term trading in this paragraph is applicable to The Equitable 401(k) Plan and other products that offer the Funds such as variable annuities and variable life policies.

No Access Person may transact in any Covered Securities that have been discussed at a meeting where the Access Person has attended for a period of 10 business days following the meeting.

No temporary employee, intern, and guest or visitor of the Companies may transact in any Covered Securities that have been discussed at a meeting where the temporary employee, intern, and guest or visitor of the Companies has attended for a period of 10 business days following the meeting.

Investment Personnel. In addition to the limitations set forth in Paragraph A. of this Section III, the following limitations apply to all Investment Personnel:

No Investment Personnel shall purchase or sell, directly or indirectly, any Covered Security (i) over which any Investment Personnel exercised direct investment and trading authority (e.g., ETF trades, beta adjustments) and (ii) that the Investment Personnel had or by reason of such transaction acquires any Beneficial Ownership, within the Restricted Period. The Restricted Period is currently designated as seven (7) days before or after the time that the same (or a related) Security is being purchased or sold by a Fund or any of its Portfolios;

No Investment Personnel may acquire a Covered Security as part of an initial public or limited offering by an issuer;

No Investment Personnel may directly or indirectly sell any Covered Security over which any Investment Personnel exercised direct investment and trading authority (e.g., ETF trades, beta adjustments) within sixty (60) days of acquiring Beneficial Ownership of that Covered Security;

Exemptions from the Trading Restriction Requirements. Unless otherwise noted below the trading restrictions listed above for Access Persons and Investment Personnel shall not apply to the following transactions:

Transactions effected for, and Covered Securities held in, any account over which the Access Person had no direct or indirect influence or control (“Non-Discretionary Account”);

Securities issued by the parent company of EIM

Purchases or sales pursuant to an Automatic Investment Plan, a program in which regular periodic purchases or withdrawals are made automatically in

Transactions executed in a prior employer’s automated profit sharing or retirement plan, except that discretionary transactions in such plans are still subject to the trading restrictions;

Purchases effected upon the exercise of rights issued by an issuer pro rata to all holders of a class of its securities, to the extent such rights were acquired from such issuer;

Acquisitions of securities through stock dividends, dividend reinvestments, stock splits, reverse stock splits, mergers, consolidations, spin-offs, and other similar corporate reorganizations or distributions generally applicable to all holders of the same class of securities;

Transactions in municipal bonds;

Other non-volitional events; and

Transactions that appear, pursuant to reasonable inquiry and investigation and approval, in writing, by the appropriate Review Officer, to present no reasonable likelihood of harm to a Fund and that are otherwise in accordance with Rule 17j-1.

Additional Restrictions and Requirements.

Gifts and Entertainment. Except as set forth below, no Access Person may accept or receive on their own behalf or on behalf of the Companies any gift or other accommodations from any person or entity that does business with, or may do business with, or on behalf of any of the Funds or the Companies (a “business contact”) that might create a conflict of interest or interfere with the impartial discharge of such Access Person’s responsibilities to the Funds or the Companies or their clients or place the recipient or the Funds or the Companies in a difficult or embarrassing position. This prohibition applies equally to gifts to members of the immediate family or household of the Access Person.

No Access Person shall accept any gift or other accommodation (other than a regular salary or wages), including entertainment, for the purchase or sale of any property to or for the Funds, except in the course of such person’s business as an underwriter or broker, if applicable.

No Access Person shall accept or receive any gift of more than de minimis value (e.g., $100) from any person or entity that does business with or on behalf of any of the Funds or the Companies. Any gift exceeding $100.00 in value should be refused or returned. If it is not practical to return the gift, the

an occasional breakfast, luncheon, dinner or reception, ticket to a sporting event or the theater, or comparable entertainment, that is not so frequent, so costly (i.e., less than $300.00 per event), nor so extensive as to raise any question of impropriety and that is attended with the business contact;

breakfast, luncheon, dinner, reception or cocktail party in conjunction with a bona fide business meeting or industry conference; and

a gift approved in writing by the Review Officer prior to accepting the gift.

Access Persons may not give gifts with an aggregate value in excess of $100 per year to persons associated with securities or financial organizations, including exchanges, broker/dealer firms or news media.

Members of EIM’s Trade Practices Oversight Committee may not receive any gift or entertainment from any broker-dealer or transition manager with which EIM currently transacts.

Access Persons may not accept or give cash or cash equivalent gifts (e.g., American Express gift cheques), without the prior approval of the Review Officer. Gift certificates to retail stores and restaurants may be accepted without prior approval, as long as it is below the de minimis standard but must be reported pursuant to Section 7 below. This activity is related to business relationships of EIM or the Funds.

Access Persons should be mindful of the frequency of gifts and entertainment as that may be looked upon as excessive. Access Persons are generally prohibited from accepting business entertainment that exceeds $1,200.00 in value per person in one calendar year (including, e.g., sporting events, concerts, theater or comparable entertainment). Business relationship sponsored events such as charitable events or awards dinners will not count toward the $300.00 per business event limit and the $1,200.00 business entertainment per calendar year limit.

Gifts under the de minimis standard must be reported, except as provided in Section 9 below. Any gifts and entertainment that exceed the de minimis standard must be pre-approved by the CCO or the Review Officer, if practicable, prior to accepting the gift. In circumstances in which the Access Person may not be able to obtain pre-approval for the receipt of a gift or entertainment, the Access Person should notify Compliance as soon as possible for a determination whether reimbursement is appropriate.

Access Persons may not provide business entertainment without accompanying the guest and may not receive business entertainment

The following items do not need to be reported:

Promotional items containing a company logo (e.g., pens, key chains, note pads, mugs, desk items) of less than $50.00 in value;

Gifts given by the Company or Access Person in recognition of a special occasion or life event (e.g., birthday gift or baby gift);

Gifts that are directed to the Company or a group within the Company or are otherwise shared by employees (e.g., holiday gift baskets, holiday group lunches); and

Gifts received by an Access Person from a raffle by EIM Legal or EIM Compliance (e.g., tickets that are raffled off to employees).

Gifts and entertainment should be valued at cost or face value. All reportable gifts and entertainment shall be reported during the quarterly Code of Ethics reporting cycle. In certain situations, an employee may not be able to ascertain the cost of an event after its conclusion (e.g., business dinners). Compliance should be consulted when reporting such items to determine the course of action.

Employees who support the wholesale distribution function may use other applications to report gifts and entertainment as approved by the compliance department of Equitable Distributors, LLC.

Service on the Board or as an Officer of Another Company. To avoid conflicts of interest, sharing of inside information and other compliance and business issues, Access Persons generally are prohibited from serving as officers or members of the board of any other entity. Exceptions to this provision must be obtained through the CCO and the Fund’s Board of Trustees. Exceptions must be provided in writing and granted only based on the best interests of a Fund and Company and their shareholders/clients. The CCO can deny the exception request for any reason.

Other Outside Business Activity. Access Persons must obtain preapproval from Compliance prior to engaging in any outside business activity as this may interfere with their duties with the firm. Preapprovals must be submitted to the CCO and will be reviewed by Compliance. Outside business activities include, but are not limited to:

Employment with another firm;

Consulting engagements;

Public/Charitable positions;

Fiduciary appointments other than with respect to family members; and

Political Contributions. EIM has adopted policies and procedures (“Pay-to-Play Policy”) in accordance with Rule 206(4)-5 under the Advisers Act. Pursuant to EIM’s Pay-to-Play Policy Covered Associates (as defined in the Pay-to-Play Policy) are prohibited from, among other things, making any direct or indirect political contribution, either personally or on behalf of EIM, to any political party, elected official or candidate with the intention of soliciting or maintaining investment advisory business for EIM. Violations of EIM’s Pay-to-Play Policy are viewed as violations of this Code and may result in disciplinary action or sanctions as listed in Section IX below.

Approval and Adoption of Code of Ethics.

Prior to initially approving any proposed new or additional investment adviser, sub-adviser or affiliated principal underwriter for a Portfolio, the Board of Trustees, including a majority of the Disinterested Trustees, must approve the new or additional investment advisers, sub-adviser’s or affiliated principal underwriter’s Code. The Board must base its approval on a determination that the relevant Code contains provisions reasonably necessary to prevent Access Persons from engaging in conduct prohibited by Rule 17j-1 under the 1940 Act.

Within six months of the adoption of any material changes to its Code, a Company and any Sub-Adviser must provide the material changes to the applicable Board of Trustees for approval and the Board of Trustees must consider the material changes to the relevant Code.

Reporting Obligations.

The Funds. Each Company shall provide the following to the Board of Trustees:

periodic reports on issues raised under the Code or any related procedures; and

on an annual basis, (i) a written report that describes issues that arose during the previous year under the Code, or any other related procedures, including but not limited to, information about material violations of the Code or procedures and any sanctions imposed in response to the material violations or its procedures, and (ii), a written certification that it has adopted procedures reasonably necessary to prevent Access Persons from violating the Code.

Access Persons. Each Access Person (other than the Fund’s Disinterested Trustees) shall file the following reports with the appropriate Review Officers:

Initial Holdings Report.    Each Access Person must provide to the Review Officer an initial complete listing of all Covered Securities in Covered Accounts and shares of any Portfolio of a Fund directly or indirectly owned by such person as of the date the person first becomes an “Access Person.” The initial listing must be submitted no later than ten (10) days after the

the title of the Covered Security or Portfolio of a Fund;

the number of shares held;

the principal amount of the Covered Security or Portfolio of a Fund;

the name of any broker, dealer or bank with whom the Access Person maintained an account in which the named Covered Securities or Portfolio of a Fund were held; and

the date that the report is submitted by the Access Person.

Quarterly Reports. Each Access Person must provide to the Review Officer, on a quarterly basis, a report indicating all transactions in Covered Securities in Covered Accounts and any Portfolio of a Fund in which the person has, or by reason of such transaction acquires, any direct or indirect beneficial ownership.

Every report shall be made not later than thirty (30) days after the end of the calendar quarter in which the transaction to which the report relates was affected, and shall contain the following information:

The date of the transaction, the title, the interest rate and maturity date (if applicable) and the number of shares or the principal amount of each Covered Security or Portfolio of a Fund involved;

The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition);

The price at which the transaction was affected;

The name of the broker, dealer or bank with or through whom the transaction was affected; and

The date the report was submitted by the Access Person.

In the event no reportable transactions occurred during the quarter, the report should be so noted and returned signed and dated to the Review Officer.

Typically, the transactions in Covered Securities in Covered Accounts are obtained by the Review Officer through automated data feeds or scanned duplicate statements for all Access Persons.

Newly Opened Accounts. If an Access Person opens an account while employed at the Companies or Funds, you must notify Compliance. On a

Annual Holdings Report. Each Access Person must provide to the Review Officer a complete listing of all Covered Securities in Covered Accounts and shares of any Portfolio of a Fund owned by the Access Person, which covers the prior calendar year, no later than January 30 of each year and current as of a date no more than 45 days before the report is submitted. You are required to report all Covered Accounts in which you or your family/household members hold any securities that could benefit you or your family/household members directly or indirectly. The listing must contain the following information:

the title of the Covered Security or Portfolio of a Fund;

the number of shares held;

the principal amount of the Covered Security or Portfolio of a Fund;

the name of any broker, dealer or bank with whom the Access Person maintained an account in which the Covered Securities or Portfolio of a Fund are held; and

the date that the report is submitted by the Access Person.

Annual Certification. All Access Persons shall be required to certify annually that they have read and understand the Code. Further, all Access Persons are required to certify annually that they have complied with the requirements of the Code and that they have disclosed or reported all personal securities transactions required to be disclosed or reported pursuant to the Code.

Annual Certification for Non-Discretionary Accounts. Access Persons who maintain beneficial ownership of Covered Securities in one or more Non-Discretionary Accounts will be required to certify annually that they have no direct or indirect influence or control over the Non-Discretionary Accounts and have not directed the fiduciary of such Non-Discretionary Accounts to buy or sell securities in the account.

Review Officer. Each Review Officer shall submit the reports, as described in Paragraph B. above, with respect to his or her own personal securities transactions to an Alternate Review Officer, such as the CCO. In the case of the

Disinterested Trustees.

A Disinterested Trustee shall report transactions in Covered Securities only if the Trustee knew, or in the ordinary course of fulfilling his or her official duties as a trustee, should have known, that during the 15-day period immediately preceding or following the date of the transaction (or such period prescribed by applicable law), the Covered Security was purchased or sold, or was being considered for purchase or sale, by any Portfolio of the Fund.

The “should have known standard” implies no duty of inquiry, does not presume there should have been any deduction or extrapolation from discussions or memoranda dealing with tactics to be employed meeting any of Portfolio’s investment objectives, or that any knowledge is to be imputed because of prior knowledge of any Portfolio’s portfolio holdings, market considerations, or any Portfolio’s investment policies, objectives and restrictions.

Every Disinterested Trustee shall report the name of any publicly-owned company (or any company anticipating a public offering of its equity Securities) and the total number of its shares beneficially owned by the Disinterested Trustees if such total ownership is more than ¹⁄₂ of 1% of the outstanding shares of the company.

No Disinterested Trustee may transact in any Covered Securities that have been discussed at a meeting where the Disinterested Trustee has attended for a period of 10 business days following the meeting.

Sub-Advisers. Each Sub-Adviser shall:

Adopt a code of ethics that satisfies the requirements of Rule 204A-1 under the Advisers Act and Rule 17j-1 under the 1940 Act;

Submit a copy of such code to the Board of the Fund for its consideration and approval

No less frequently than quarterly, report to the Fund, in writing, any material amendments to such code;

No less frequently than quarterly, furnish to the Fund a quarterly certification regarding reasonable procedures to prevent violations of their Code and required documentation to be retained

No less frequently than quarterly, request information regarding violation(s) of such code by any person who is an Access Person to the Fund; and

Provide, on an annual basis, (i) a written report that describes material issues that arose during the previous year under such code, , including but not limited to, information about material violations of such code or procedures and any sanctions imposed in response to the material violations or its procedures, and (ii), a written certification that it has adopted procedures reasonably necessary to prevent the sub-adviser’s Access Persons from violating such code.

Temporary Employees, Interns, Consultants and Guests. Temporary employees, interns or consultants of the Funds whose assignments exceed 90 days, or who have otherwise been designated by EIM Compliance as temporary Access Persons under this Code, are required to certify for the period during which the designation as an Access Person is in effect, that they have complied with the requirements of the Code and that they have disclosed or reported all personal securities transactions required to be disclosed or reported pursuant to the Code. Guests, visitors or other persons who may have temporary access to information regarding Covered Securities (i.e., less than 90 days) and who are not designated Access Persons may receive relevant training from the Compliance Department and may be requested by EIM Compliance to provide certifications related to this activity.

Confidentiality. All reports of securities transactions and any other information filed with the Fund pursuant to this Code shall be treated as confidential. In this regard, no Access Person shall reveal to any other person (except in the normal course of his or her duties on behalf of any of the Companies) any information regarding Securities transactions made or being considered by or on behalf of any Portfolio of the Fund.

The Code requires that if at any time you become aware that you, any members of your family/household or any other Access Person, have violated the Code, it is your fiduciary obligation to report such violation(s) to the CCO, or the Review Officer in the CCO’s absence, immediately. All Access Persons are required to report actual or suspected violations of the Code promptly to the CCO or his designee. Any retaliation against an employee who reports a violation is prohibited and constitutes a further violation of the Code.

The Review Officer for the Fund shall compare all reported personal securities transactions with completed portfolio transactions of each Portfolio of a Fund and a list of the securities within the EIM trading universe to determine whether a violation of this Code may have occurred. One test that may be applied in determining whether a violation of the Code has occurred will be to review the securities transactions of Access Persons for patterns of transactions. For example:

Any pattern involving parallel transactions (for any Portfolio of the Fund and the individual both buying or both selling the same Security) or opposite transactions (buy/sell or sell/buy) within the Restricted Period may be analyzed to determine whether the individual’s transaction may have violated the Code.

Among the other factors that may be considered in the analysis are:

the number and dollar amount of the transactions;

the trading volume of the Covered Security in question;

the length of time the Covered Security has been held by the individual; and

the individual’s involvement in the investment process.

If the Review Officer determines that a violation of this Code may have occurred, the Review Officer shall submit his or her written determination, together with a confidential report and any additional explanatory material provided by the individual, to the Chief Compliance Officer of the Fund.

If the Review Officer and the Chief Compliance Officer find that a violation has occurred, the Chief Compliance Officer shall impose upon the individual such sanctions as he or she deems appropriate and shall report the violation and the sanction imposed to the Board of Trustees of the Fund.

No person shall participate in a determination of (1) whether he or she personally has committed a violation of the Code, or (2) the imposition of any sanction in the event he or she has committed a violation of the Code.

The CCO, in consultation with EIM Legal, may from time to time grant exceptions, other than or in addition to those described in this Code, if it is determined that the case involves no opportunity for abuses and does not conflict with the interests of clients or the Funds. Requests for exceptions must be in writing to the CCO or the Review Officer. The CCO, in consultation with EIM Legal, may from time to time adopt interpretations of this Code as deemed appropriate.

Exemptions from Certain Reporting Requirements. The following are exempt from certain reporting requirements of this Code:

Non-Discretionary Accounts – Personal Securities Transactions. Transactions in Covered Securities held in an approved Non-Discretionary

Automatic Investment Plans – Personal Securities Transactions. Access Persons are not required to disclose on their quarterly transaction reports any securities that were purchased or sold through an Automatic Investment Plan, including dividend reinvestment plans, 401(k) rebalance programs or automatic investments in variable deferred compensation plans (e.g., Karr Barth). You are required to disclose these holdings on your initial and annual holdings reports.

Educational Savings Plans – Personal Securities Transactions. Access Persons are not required to report accounts that are held through educational savings plans (i.e., 529 Plans) that only allow unaffiliated mutual funds.

Retirement Savings Plans – Personal Securities Transactions. Access Persons are not required to report accounts that are held through retirement savings plans (e.g., 401(k), 403(b), pension plans) that only allow unaffiliated mutual funds.

Other Exemptions –

Transactions effected for, and Covered Securities held in, any account over which the Access Person had no direct or indirect influence or control.

Securities issued by the parent company of EIM, including securities issued through Stock Plan Accounts (e.g., Stock Purchase, Restricted Stock, Stock Option), are not considered Covered Accounts under this Code. Trading in shares of securities issued by EIM’s parent company are subject to restrictions under the parent company’s relevant policies and procedures.

Transactions executed in a prior employer’s automated profit sharing or retirement plan, except that discretionary transactions in such plans are still subject to the reporting requirements to the extent that such plans are not otherwise exempted from the reporting requirements under this Code.

Purchases effected upon the exercise of rights issued by an issuer pro rata to all holders of a class of its securities, to the extent such rights were acquired from such issuer.

Acquisitions of securities through stock dividends, dividend reinvestments, stock splits, reverse stock splits, mergers, consolidations, spin-offs, and other similar corporate reorganizations or distributions generally applicable to all holders of the same class of securities.

Transactions in municipal bonds.

Records. The Companies shall maintain records in the manner and to the extent set forth below, which may be maintained on microfilm or by such other means permissible under the conditions described in Rule 31a-2 under the 1940 Act, or under no-action letters or interpretations under that rule, and shall be available for examination by representatives of the Securities and Exchange Commission.

A copy of this Code shall be preserved in an easily accessible place (including for five (5) years after this Code is no longer in effect).

A record of any violation of this Code and of any action taken as a result of such violation shall be preserved in an easily accessible place for a period of not less than five (5) years following the end of the fiscal year in which the violation occurs.

A copy of each report, including any information provided in lieu of the report, made by an Access Person pursuant to this Code shall be preserved for a period of not less than five (5) years from the end of the fiscal year in which it is made, the first two years in an easily accessible place.

A list of all Access Persons who are, or within the past five (5) years have been, required to make reports pursuant to this Code shall be maintained in an easily accessible place.

Sanctions

The Funds and the Companies each treat violations of this Code (including violations of the spirit of the Code) very seriously. If you violate either the letter or the spirit of this Code, a Fund or a Company may impose one, several or all of the following: formal warnings or fines as outlined in this Code; a disgorgement

The table below describes the sanctions that may be imposed for certain violations. The Review Officer has full discretion to impose sanctions that are more or less than those outlined in the table. Sanctions also may be imposed for any violation not discussed below.

Approval, Amendment and Interpretation of Provisions.

This Code may be amended as necessary or appropriate with the approval of the Board of Trustees.

This Code is subject to interpretation by the Board of Trustees in its discretion.

Updated effective May 1, 2020 to reflect EQ Premier VIP name change

Updated effective June 15, 2020 to reflect corporate name changes