Exhibit (r)(2)

Personal Account Dealing and
Private Investments Policy

Owner: Employee Compliance
Next Review Date: April 2024
Effective from: April 2023

Contents

Most Recent Changes

This Personal Account Dealing and Private Investments Policy (the “Policy”) establishes the minimum standards to be followed by all Employees of RBC BlueBay UK in connection with their personal account transactions and Private Investments.

This Policy has been adopted to ensure adequate arrangements are in place to manage any actual or potential Conflicts of Interest that may arise from an Employee’s personal account dealing and private investment activity.

This Policy applies to all Employees, subject to section 16 – Exempt Individuals, as well as their Related Persons and certain other persons by virtue of their relationship with the Employee or RBC BlueBay UK. Employees are therefore responsible for notifying these individuals of their responsibilities under this Policy. Full definitions can be found in section 20.

Any questions concerning the scope of this Policy should be directed to Employee Compliance and/or RBC BlueBay Compliance.

Employees who are BlueBay Technology Users are required to use FIS Protegent Personal Trading Assistant (PTA), an online application, for all personal account dealing activity. The system is referred to internally as the “Code of Ethics System” and can be accessed on BlueBay’s technology platform via the Intranet. All pre-clearance requests, disclosures, reporting, and certifications required in accordance with this Policy must be submitted in the Code of Ethics System by BlueBay Technology Users. Specific guidance has been provided in this Policy for requesting pre-clearance for Securities Transactions and Private Investments. For further guidance please contact RBC BlueBay Compliance.

RBC BlueBay Compliance will provide Employee Compliance with all relevant information as required for complying with this Policy and applicable regulatory requirements.

This Policy should be read in conjunction with the following RBC BlueBay UK and RBC enterprise policies:

Upon joining RBC BlueBay UK, Employees are required to disclose the existence of all Employee and Related Accounts within thirty (30) calendar days of their start date in MyComplianceOffice (MCO). Thereafter, Employees must promptly disclose any new Employee and Related Accounts in MCO and advise Employee Compliance of any account closures.

Digital Wallets used to facilitate transactions between users and merchants including Bitcoin and/or other Crypto- Currency payment systems do not need to be disclosed provided an RBC email address is not used to register the account.

Employee Accounts must be held at a Permitted Firm. The list of Permitted Firms can be found in section 20 – Definitions.

From 1 April 2023 Employees (including contract Employees who will be with the firm for twelve (12) months or more) who have Employee Accounts maintained at a non-Permitted Firm are required to close or transfer such accounts to a Permitted Firm within 90 calendar days of commencing employment. From 1 July 2023, this period will revert to 30 calendar days of commencing employment. (Employees must comply with the pre-clearance requirements in this Policy if the transfer of a holding is executed on the market.)

Exceptions:

Exceptions to this requirement should be requested only in the most unusual and compelling circumstances and may be granted only with the consent of the Employee’s line manager and Compliance.

Employees should note that existing managed SIPPs and Child Trust Funds and Employee Share Schemes in place prior to becoming an Employee do not need to be transferred to a Permitted Firm, however they remain subject to the rules set out in this Policy. For the avoidance of doubt, all new Employee Accounts should be opened with a Permitted Firm.

Related Accounts do not need to be held at a Permitted Firm but must be disclosed to Employee Compliance via MCO, and quarterly statements must be provided in accordance with this Policy.

Discretionary Accounts do not need to be held at a Permitted Firm and quarterly statements are not required for these accounts. However, they must be disclosed in MCO and a letter of confirmation provided from the financial institution managing the account must be sent to Employee Compliance at the point of disclosure or soon after, confirming the Employee does not have authority to trade on the account and the portfolio/investment manager will not accept or act upon instructions from the Employee when trading on behalf of the account.

Permitted Firms offer RBC a “live feed” service which provides Employee Compliance with oversight of all holdings and transaction activity occurring within those accounts. Employees (and Related Persons if applicable) must provide consent directly to the Permitted Firm for their accounts to be added to the live feed. Instructions for this are available from Employee Compliance and will be provided when Employee and/or Related Accounts are disclosed.

Upon joining RBC BlueBay UK, Employees must provide Employee Compliance with a holdings statement for any Employee and/or Related Accounts that are not held at a Permitted Firm. The holdings must be current as of the date of joining RBC BlueBay UK but, in any event, must be current as of a date not more than forty-five (45) calendar days prior to disclosure.

For Employee and/or Related Accounts not held with a Permitted Firm, Employees must provide detailed quarterly statements to Employee Compliance within thirty (30) calendar days of the quarterly reporting date. The statements must include a transaction history covering the quarter, and a holdings statement which is current as of the end of the quarter.

Subject to certain exceptions set out in section 7.5 – Exceptions to Pre-Clearance Requirements, any Securities Transaction made in an Employee Account (including a Related Account over which the Employee has influence, trading authorisation or control) is subject to a pre-clearance process.

Pre-clearance is also required for all transfers in kind between tax sheltered retirement accounts and non-retirement accounts. However, securities may be transferred between like accounts at any time as long as the total number of securities owned (directly or beneficially) or controlled does not change and the transfer is not executed on the market. Pre-clearance is required for all other transfers of securities including all donations of securities.

Pre-clearance will remain in force for the trading day it was granted. Orders must be placed, instructed and executed on the same trading day that pre-clearance was granted.

Where pre-clearance review is performed by a team based in a different jurisdiction to the Employee submitting the request, and pre-clearance is received outside of local market hours, pre-clearance will remain in force for the next trading day. In such cases, orders must be placed, instructed and executed no later than the next trading day.

Employees who are RBC GAM Technology Users are required to submit pre-clearance requests to their Line Manager, the Investment Policy team, and Employee Compliance via MCO. Investment Policy will check pre-clearance requests against the Restricted List and open orders.

Employees must only execute their trade request once pre-clearance has been approved by Employee Compliance via MCO.

Members of the GAM Canada Global Fixed Income and Currency Team based in London are subject to dual pre- clearance from both Employee Compliance and GAM Canada Compliance. Employee Compliance will forward any pre-clearance request received from these Employees to GAM Canada Compliance for review before confirming pre- clearance. As such, pre-clearance requests should be made in good time to allow the full approval process to complete.

Furthermore, members of the GAM Canada Global Fixed Income and Currency Team based in London who are subject to the GAM Canada and RBC BlueBay UK Personal Account Dealing Policies are prohibited from trading individual securities. For more information, please refer to Canadian RBC GAM Personal Trading Policy.

Employees who are BlueBay Technology Users are required to:

Investment Policy will check pre-clearance requests against the Restricted List and open orders. Employees will receive an automated email notification from the Code of Ethics System once their pre-clearance has been approved or denied. Employees must only execute their trade request once they have received approval.

Pre-clearance is not required for the following Security types:

Please note: it is prohibited for any third party, including a relative or close family member to undertake a transaction as a means of enabling an Employee to circumvent any of the requirements of the RBC Enterprise Control Standard for Personal Trading, this Policy, or in contravention of any considerations of a possible Conflict of Interest.

Employees are expected, during normal working hours, to devote their full time and attention to their responsibilities at RBC BlueBay UK. Excessive trading in an Employee Account suggests this expectation is not being met and will be addressed by the applicable Line Manager.

With this objective in mind, a thirty (30) calendar day holding period has been established for all Securities held in Employee Accounts. This holding period requirement applies to all Employee Accounts, whether they are maintained at a Permitted Firm or elsewhere. The holding period also applies to Securities that do not require pre-clearance.

The thirty (30) calendar day period begins from the date a trade is executed until the thirty (30) first day when the Employee is permitted to sell the Security. When an Employee adds to an existing position in a Security in an account, the holding period for subsequent sales of that Security will be measured on a “FIFO” (first in – first out) basis.

Exceptions may be granted to the holding period in cases of:

BlueBay Technology Users (Tokyo Office): Employees based in RBC BlueBay’s Tokyo office cannot sell a security within six (6) months of purchase of that security or buy a security within six (6) months of sale of that security. This six (6) month holding period will be monitored in the BlueBay Code of Ethics System.

Employee Accounts are permitted to buy and sell commodities futures, and futures or options on futures, provided that all transactions are pre-cleared. Such transactions are subject to the thirty (30) day holding period. The significant unrealised (10% or more) market loss exception from the thirty (30) day holding period is with respect to change in initial margin posted, not the value of the contract or underlying instrument.

All Employees are prohibited from buying or selling options or other derivatives in respect of RBC Securities.

Employee Accounts are permitted to buy and sell call and put options, except that such accounts may not engage in naked option writing. Options transactions are subject to the same pre-approval and thirty (30) day holding period as other securities. The significant unrealised (10% or more) market loss exception from the thirty (30) day holding period requirement is measured by the percent change in the underlying Security, not the option premium. Employees are prohibited from opening a short-term options position, i.e., an option with less than thirty (30) calendar days until expiration date.

Short selling and other investment activities that include a high degree of financial risk are strongly discouraged by RBC BlueBay UK and may be subject to future review in the event of a regulatory inquiry.

Apart from the restriction on RBC Securities, Employee Accounts are permitted to engage in the short sales of securities. Such transactions are subject to the thirty (30) calendar day holding period requirements set forth in this Policy. Please note that short selling does not entitle an Employee to any holding period exemptions based on a significant loss in the value of the underlying Security. Employees are also reminded that short selling may be considered a Speculative Activity and to exercise caution when engaging in such transactions.

Employees are not permitted to place orders directly with market makers, floor brokers or institutional sales and trading personnel. All Securities Transactions must be executed through a broker, investment advisor or customary electronic channel (e.g., telephone or on-line access) used by ordinary retail investors.

Pre-clearance requests (including limit orders) should be limited to securities where the terms of the Securities Transaction are such that it is reasonable to assume the Securities Transaction will be executable within the pre- clearance timeframe (i.e. close of trading same day).

Membership of Investment Clubs is generally permissible however certain requirements, such as treating the Investment Club account as an Employee Account for the purposes of this Policy, will apply where you have beneficial ownership or decision-making authority within such a Club. Should you wish to join an Investment Club, or if you are a new joiner with an existing Investment Club membership, please speak to Employee Compliance.

Buying and selling digital assets, converting government-run currencies into digital assets or sending or securing digital assets in a wallet does not require pre-clearance. Trading in Securities that derive returns based on the price of digital assets (e.g., Bitcoin trusts and ETFs) must be executed in an approved brokerage account and are subject to the other requirements set out in this Policy, including holding periods and pre-clearance where required. Please note the prohibition for Initial Coin Offerings (ICOs) below.

Employees are subject to the following rules when trading RBC Securities in Employee Accounts or RBC shares acquired via the Compensation plans:

Outside of bonus deferral arrangements, Employees are generally not permitted to make any personal investment in fee-free share classes of RBC BlueBay UK funds. Such an investment would be deemed a benefit in kind which would have adverse tax consequences for both the Employee and RBC BlueBay UK (including additional social security costs, complex tax valuations, and increased tax reporting).

Employees (including former BlueBay Partners) may only invest in fee-free share classes at the point of a fund launch, provided there are no fee-paying investors.

Once an RBC BlueBay UK fund has fee-paying investors, Employees are only permitted to invest in fee-paying share classes that are offered on the same terms to external investors. Employees may be able to access lower fee-paying share classes if their investment meets the AUM levels required for a fee discount, similar to those offered to external investors in accordance with RBC BlueBay GAM UK’s internal fee schedule.

If you have any queries about personal investment in the RBC BlueBay UK funds please reach out to the Client Data team for further guidance.

Pre-clearance is required if an Employee intends to make any direct personal investment in an open ended pooled fund organised and offered by RBC BlueBay UK in either a Cayman or Delaware open-ended vehicle (a “Covered Fund”). This must be requested via email to RBC BlueBay Compliance prior to initiating any such investment.

The preclearance requirement is to enable RBC BlueBay UK and RBC to comply with applicable requirements of section 13 of the US Bank Holding Company Act, more commonly known as the Volcker Rule. For specific funds sponsored by RBC BlueBay UK, including Covered Funds, the firm is required to ensure that only Employees directly providing services or certain ancillary services may invest in the fund.

If RBC BlueBay Compliance gives permission to invest in a Covered Fund hereunder, it is valid for thirty (30) business days after permission is given. After the thirty (30) business days has passed you should resubmit the application if you have not invested and still wish to do so.

Pre-clearance will not be required for:

If you have any queries about the pre-clearance requirements, or which of the RBC BlueBay UK funds are defined as Covered Funds, please contact RBC BlueBay Compliance.

The very essence of the financial services industry demands that we consistently maintain the highest possible standards of honest and ethical behaviour. Numerous laws, rules and regulations have been established to govern the operations of financial institutions. RBC companies and Employees are subject to, and are expected to comply with, the laws, rules and regulations of all countries in which they operate, as well as the expectations and requirements of our various regulators. These laws include, but are not limited to, banking laws, securities laws and regulations, laws prohibiting the corruption of foreign officials, laws designed to combat money laundering and terrorist financing, as well as lobbying and employment legislation.

In keeping with these expectations, all Employees are prohibited from engaging in Speculative Activities in their Employee Accounts and should not engage in any investment activities that involve a high degree of financial risk and / or that may materially impact their financial soundness.

All financial spread betting and CFD trading is prohibited; all existing accounts must be closed prior to or immediately upon becoming an Employee.

Employees are not permitted to subscribe for new issues or IPOs (including within Related Accounts over which the Employee has influence, trading authorisation or control). Exceptions may be permitted by Employee Compliance and the CCO of RBC BlueBay UK in limited situations, for instance:

Any investment is subject to pre-clearance in accordance with section 7 – Pre-Clearance of Securities Transactions. In addition pre-clearance will also consider whether the investment could be construed as:

Employees are prohibited from participating in Initial Coin Offerings (ICOs) as ICOs can be interpreted as representing offerings of securities.

No Employee or Related Person may buy or sell a Security of any issuer (or any related Security) when in possession of Inside Information relating to the issuer or the Security (or any related Security). These restrictions apply whether the Securities Transaction is for an Employee or a Related Account. It is an offence for an Employee to disclose Inside Information to another person, other than in the proper performance of their employment or duties

Any Employee who is unsure whether they are in possession of information that would preclude trading in a particular Security should contact RBC BlueBay Compliance for clarification. Employees are reminded that Insider Dealing is a criminal offence under Insider Dealing legislation in the UK which carries a penalty of imprisonment upon conviction.

Employees in possession of information which is or might be perceived to be Inside Information must not undertake themselves, or arrange, advise or encourage others to undertake, transactions in the securities of the relevant entities.

Should an Employee or RBC business unit acquire Inside Information about a Reporting Issuer then this will trigger certain reporting obligations to RBC BlueBay Compliance. Should this situation arise you should contact RBC BlueBay Compliance who will facilitate the appropriate disclosure of the relevant information and add the issuer to the Restricted List. Once the Employee becomes aware that the non-public information or event is in the public domain, RBC BlueBay Compliance should be notified so they may update the Restricted List accordingly.

Where a Conflict of Interest, real or perceived, may arise as a result of a trade in a Reporting Issuer, the name of the Reporting Issuer should be made known to RBC BlueBay Compliance, in accordance with the procedure set out above. At all times Employees of RBC BlueBay UK must comply with RBC BlueBay UK’s Inside Information Policy.

Employees may not transact in securities/issuers that are on the Restricted List or RBC’s Global Restricted List. Further information regarding confidential, proprietary and/or Inside Information and information on the RBC Global Restricted List, please refer to the RBC Enterprise-Wide Policy on Inside Information and Information Barriers.

Information regarding client orders must be kept confidential. Confidential Information obtained directly or indirectly from a client (e.g., orders from a customer account), or any other internal or external source, may be used only for the specific business purpose or transaction for which it was given. Any other use without the permission of the client which originally entrusted RBC with the information is a misuse and may result in disciplinary action.

An Employee who has prior or concurrent knowledge of an order for either an RBC proprietary account or client of the RBC or RBC BlueBay UK, must not enter an order for their Employee or Related Account that would precede or compete with such order. Likewise, such information must not be passed along to others.

Where RBC BlueBay UK has made a decision to deal for a Client, then an Employee must not deal the same way until the Client order or decision has been executed or cancelled.

Having observed a pattern of successful trading by an RBC proprietary trading account or client of RBC or RBC BlueBay UK, an Employee must not “piggyback” by patterning trading in their Employee or Related Accounts after the RBC trading account or client account. Likewise, such information must not be passed along to others. Employees should not discuss their personal trading with clients.

The approval process described in this section must be adhered to by all Employees looking to make a new Private Investment, as well as by new Employees seeking approval for Private Investments made prior to joining RBC BlueBay UK. New Employees must disclose and obtain approval for pre-existing Private Investments within thirty (30) days of commencing employment with RBC BlueBay UK. The requirements in this section do not apply to Related Persons.

When submitting approval requests for new Private Investments and/or existing Private Investments (together “Requests”), Employees must include copies of all relevant supporting documentation (e.g. Subscription Agreement, Offering Memorandum, Limited Partnership Agreement etc.) with their Request.

Requests must be accurate, complete, and contain full details of the Private Investment. Incomplete Requests will be returned for completion prior to review. Employees should submit their Requests using MCO and allow sufficient time for the Request to be reviewed.

Approval will be granted on a case-by-case basis and only after consideration of all relevant factors, including, but not limited, to:

Employees who are RBC GAM Technology Users must submit Private Investment Requests to their Line Manager and Employee Compliance via MCO.

Employees will be notified via MCO once a final determination on their Request has been made. Employees must not make or instruct the requested Private Investment until they have received approval from Employee Compliance via MCO. Employee and RBC BlueBay Compliance will discuss options for divestment with new Employees if a pre-existing Private Investment is not approved.

Employees must submit a new Request and receive approval via MCO prior to making any additional investment.

Members of the GAM Canada Global Fixed Income and Currency Team based in London are subject to dual pre- clearance from both Employee Compliance and GAM Canada Compliance. As such, Employee Compliance will forward any Private Investment Request received from these Employees to GAM Canada Compliance for final review before communicating the outcome. Requests should be made well in advance of the closure date.

Employees who are BlueBay Technology Users are required to:

Employees will receive an automated email notification from the Code of Ethics System once their Request has been approved or denied. Employees must not make or instruct the requested Private Investment until they have received approval. Employee and RBC BlueBay Compliance will discuss options for divestment with new Employees if a pre- existing Private Investment is not approved.

Employees must submit a new Request and receive approval prior to making any additional investment.

If the Private Investment is approved, the Employee is responsible for:

Line Managers have an ongoing obligation to supervise approved Private Investments and any related conditions imposed on the approval of such Private Investments.

It is strictly prohibited for Employees to engage in any of the following with respect to a Private Investment:

Employees are required to complete the Annual Compliance Declaration (via Workday) and the Annual Disclosure Attestation (via MCO) within specified timeframes.

Employees are required to complete the Annual Compliance Declaration (via Workday), and quarterly personal account dealing certifications in the Code of Ethics System within specified timeframes.

All Employees who retire or leave RBC, as well as Employees who transfer to another role within RBC that does not require monitoring under the RBC Compliance policies, remain subject to the restrictions in law regarding insider trading and tipping off as well as those regarding confidentiality of information.

Employees on garden leave or income protection will continue to be monitored until their last day of employment. However, if the Employee does not have access to any RBC or RBC BlueBay UK systems, they are not required to pre- clear trades, adhere to the thirty (30) day holding period, and are not subject to the Restricted List.

Employees on short term leave (for example, sick leave or parental leave) must continue to adhere to this Policy where appropriate, unless in limited circumstances as determined by the Employee Compliance, RBC BlueBay Compliance and HR. Situations involving Employees on long term leave will be assessed by Employee Compliance and the RBC BlueBay UK CCO on a case-by-case basis.

Any breach of this Policy must be promptly reported to the Employee’s Line Manager and Compliance,

Violations of this Policy may result in penalties ranging from cancellation of a trade and suspension of trading privileges to termination of employment. RBC and RBC BlueBay UK reserve the right to instruct the Employee to cancel (at their expense) a trade executed in a Securities Dealing Account maintained away from RBC or compel the repurchase at market prices of Securities improperly sold. Any loss from an impermissible trade will be charged to the Employee and any profits will be forfeited.

Generally, Employees can expect to receive instruction to reverse trades as soon as practicable, or ordinarily within one (1) trading day. However, there may be cases where for reasons beyond RBC and RBC BlueBay UK’s control, the Employee may be exposed to the market for longer periods. Accordingly, the financial consequences of violating this policy may be severe. In the event that RBC or RBC BlueBay UK determines that a Securities Transaction was executed based upon confidential, proprietary or material non-public information, appropriate disciplinary action will be taken against the Employee and, if appropriate, legal or regulatory authorities will be notified.

RBC Compliance has established a Regulatory Compliance Management (RCM) program which enables a risk based monitoring and testing approach. The RCM program requires that monitoring and testing programs must be adequately documented and include both the roles and responsibilities related to monitoring and testing program and the results of monitoring and testing. For more details on the RCM program related to this Policy, refer to the RCM Control Standards for Regulatory Compliance.

1st Line of Defence – Front Office Management Branch and Divisional Managers, Department and Division Heads and their designated supervisory persons are responsible for implementing, maintaining and enforcing this Policy and procedures in their respective branches, divisions and departments.

2nd Line of Defence – Employee Compliance and RBC BlueBay Compliance are responsible for maintaining and updating this Policy, and for working with management to coordinate education and training with respect to items contained in the Policy.

Certain RBC BlueBay UK officers and/or directors (“RBC Executives”) may not be RBC BlueBay UK Employees and serve in such roles solely at the request of RBC or its affiliates. If all of the following conditions apply, such RBC Executives shall be exempt from this Policy and will be asked to provide an annual certification of the facts giving rise to their exempt status.

Exempt individuals must be individuals who:

Policy exceptions related to Employee and Related Accounts at Permitted Firms, and the Holding Period restriction are detailed in the corresponding sections of the Policy.

Exceptions to any of other components of this Policy should be requested only in the most unusual and compelling circumstances and may be granted only with the consent of the Employee’s Line Manager and Compliance.

Records are required to be maintained by the RBC Compliance function for seven (7) years:

Any material change to this Policy must be disclosed in full to any Client who is an Investment Company under the US Investment Company Act of 1940 promptly, so that Client is able to approve the change in accordance with US regulations.

On a quarterly and annual basis RBC BlueBay UK provides required reports to the Board of Trustees of any registered investment company for which it serves as investment adviser or sub-adviser.

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