Exhibit 99(r)(i)

CODE OF ETHICS AND PERSONAL TRADING POLICY

August 2025

This Code of Ethics and Personal Trading Policy (the “Code”) sets forth the standards of business conduct expected of all (i) partners and employees of Lord Abbett and their Family Members (as defined in Section V); (ii) officers, directors and employees of the Lord Abbett Funds; and (iii) contractors, consultants, and any other personnel who are determined to be Access Persons and have been notified by Global Compliance that they are subject to this Code (collectively referred to as “Employees”) in connection with their personal trading transactions.

This Code is designed to:

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

CODE OF ETHICS AND PERSONAL TRADING POLICY

All Employees subject to this Code are designated as “Access Persons” as that term is defined under Rule 17j-1. The Independent Directors/Trustees of the Lord Abbett Funds are subject only to the requirements of the Policy set forth in Exhibit A.

Lord Abbett, the Lord Abbett Advisers, Lord Abbett Distributor LLC and the Lord Abbett Funds have each adopted this Code to ensure that the personal trading activities of Employees are conducted in compliance with the applicable provisions of law and regulation and in a manner consistent with the firm’s responsibilities to its clients.

Certain terms used in this Code are defined in Section V.

Lord Abbett has established a Code of Business Principles that sets standards expected of all Employees and provides the framework for conducting business in a fair and ethical manner. Consistent with the Code of Business Principles, Lord Abbett and each Employee have a fiduciary duty to always act in the best interests of clients. Employees must comply with applicable legal requirements, securities laws, the Code of Business Principles, this Code and related policies and procedures.

Addressing conflicts of interest

Conflicts of interest may arise between clients, between clients and Lord Abbett, and between clients and Employees. Lord Abbett takes reasonable steps to identify and manage conflicts. It is the responsibility of each Employee to disclose to Global Compliance all material conflicts of which they are aware and to act in a manner consistent with the letter and the spirit of this Code. Conflicts or potential conflicts of interest involving an Employee’s behavior may arise through, among other activities, an Employee’s personal trading transactions, outside business activities, political contributions and activities and the exchange of gifts and business entertainment.

Outside business activities

Employees may wish to engage in business activities outside of Lord Abbett. Outside business activities are permissible, as long as the activity has been approved by the Employee’s manager and Global Compliance and does not conflict with, or appear to conflict with, their duties on behalf of Lord Abbett. Refer to the Outside Business Activities Policy for more information.

Gifts and business entertainment

Gifts and business entertainment are key components to establishing and maintaining business relationships with clients and business partners. Employees may offer, give, provide, or accept gifts or business entertainment as long as such gift or entertainment:

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

Refer to the Gifts and Entertainment Policy for more information.

Political contributions and activities

Employees wishing to participate in the political process must obtain pre-clearance for their political contributions and activities in support of candidates for political office in the U.S. Political contributions and political activities undertaken by Employees must always be lawful and consistent with Lord Abbett policies.

Employees may not:

Refer to the U.S. Political Contributions and Activities Policy for more information.

Personal trading transactions

An Employee’s personal trading transactions may present an actual, potential or apparent conflict or other risk that could harm Lord Abbett, its clients or the shareholders in the Lord Abbett Funds. In order for Lord Abbett to identify and manage the conflicts and risks associated with Employee personal trading, Employees must disclose their personal brokerage accounts and holdings, and conduct approved personal trading transactions in accordance with the requirements of this Code.

Employees may not:

Employees must contact Global Compliance for guidance if they believe that a perceived or actual conflict may arise under any of the activities described above or otherwise.

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

A personal trading account subject to this Code (a “Personal Account”) is generally defined as an account that satisfies one of the following conditions:

AND

the account invests in or has the ability to invest in or hold Securities (as defined in Section V).

Initial Disclosure of Existing Accounts

Employees must disclose all their Personal Accounts and the accounts of their Family Members (including Managed Accounts) maintained with any broker, dealer, investment adviser, bank or other financial institution via the Code of Ethics app. Such disclosure must take place within ten calendar days after becoming subject to the Code.

Disclosure of New Accounts

Employees may open a new Personal Account as long as the financial institution is on the Approved List and should disclose the account via the Code of Ethics app as soon as they have the account number. Employees wishing to open an account with a firm that is not on the Approved List must contact personaltrading@lordabbett.com before they open the account. Employees outside the U.S. may be permitted to maintain accounts with financial institutions that are not on the Approved List. Such Employees should contact personaltrading@lordabbett.com before they disclose their accounts in the Code of Ethics app. The current Approved List shall be posted in the Code of Ethics app.

Employees who are asked to close Personal Accounts maintained with firms that are not on the Approved List will generally have 60 days to do so.

For the avoidance of doubt, Employees are not permitted to open or maintain margin accounts.

Exceptions to the Account Reporting Requirement

The following accounts are not subject to reporting to Global Compliance and are not subject to the provisions of the Code:

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

Initial Disclosure of Holdings

All Employees must disclose and certify, via Code of Ethics app, all holdings in Securities in which they have a Beneficial Interest or Control (the “Initial Holdings Report”) no later than ten calendar days after they become subject to the Code. The term “Securities” includes, but is not limited to:

The Initial Holdings Report must be current as of a date no more than 45 calendar days prior to the date the Employee becomes subject to the Code, and include, among other things:

The following Securities and instruments are not subject to reporting:

As long as a Personal Account is maintained with a firm on the Approved List, no additional transaction reporting is required. If transactions are not feeding electronically, the Employee shall be required to upload transaction data or account statements via the Code of Ethics app on a quarterly basis.

Exceptions to the Transaction Reporting Requirements

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

Except as noted below, Employees shall pre-clear all transactions involving Securities held in their Personal Accounts via the Code of Ethics app and must refrain from executing the transaction until they are notified that it has been approved. Approval shall be denied if an Employee is requesting to trade in a Security that is on the Restricted List.

The following transactions are exempt from the pre-clearance requirement:

Pre-clearance for Private Placements

Employees must obtain pre-clearance via the Code of Ethics app when investing in a Private Placement, including purchasing limited partnership interests. When requesting pre-clearance for a new Private Placement, the Employee must provide the Private Placement offering document and complete the information requested in the Private Placement Approval Request.

An Employee who has invested in a Private Placement and who later anticipates participating in

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

an investment decision regarding the purchase or sale of securities or a financing of the issuer of that Private Placement or its affiliates on behalf of any Lord Abbett Adviser client, must immediately notify Global Compliance for further review.

Duration of Pre-clearance Approval

Pre-clearance approval is valid until the end of the second business day after the date of approval, (e.g., if approval is communicated on Monday, the Employee has until close of business on Wednesday to act on executing the trade). Pre-clearance approval for Private Placements may take additional time to review and will generally be valid for 90 calendar days. Any trades not executed within the prescribed timeframe after approval is granted must be re-submitted for approval.

Refer to Exhibit B for additional pre-clearance requirements.

Investment Professionals may not:

If an Investment Professional obtained approval for a purchase or sale of a Security for their Personal Account, and a purchase or sale of the same Security for a client account, is effected within seven calendar days following the Investment Professional’s personal transaction, the personal transaction may be subject to a price adjustment and/or disgorgement of profits.

Employees are prohibited from selling ETFs, closed end funds, and any Security the purchase of which was subject to pre-clearance from their Personal Account within 30 calendar days following the purchase of such Security or ETF. Lord Abbett Funds are also subject to a holding period as specified below. Refer to Exhibit B for additional information regarding the holding period.

The holding period restriction does not apply to:

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

Holding Period for the Lord Abbett Family of Funds

Employees must comply with the provisions of the holding restrictions set forth in the prospectus for the applicable Lord Abbett Fund or Sub-Advised Fund, typically 30 calendar days. The holding restriction does not apply to shares of a Lord Abbett money market fund or the Lord Abbett Ultra Short Bond Fund.

Please note that there are two exceptions to this holding period requirement.

The holding period requirements are calculated on a “first in, first out” basis. Profits realized from a violation of these restrictions will generally be disgorged to charity and violations shall nevertheless be subject to the Violations and Sanction section below.

Refer to Exhibit B for additional holding period requirements.

Employees are prohibited from:

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

Limit Orders

Limit orders are discouraged in light of the fact that pre-clearance approval is valid for two business days after the day it was granted. Employees are encouraged to use “day” limit orders.

Stock Options

The following rules apply to stock options received or exercised by an Employee’s spouse or domestic partner who is a director or employee of, or a consultant to, a company providing such options:

Employees must attest to receipt and understanding of the Code:

Quarterly Certification Requirements

Within 30 days after the end of each calendar quarter, Employees shall certify that all transactions effected in Securities during the quarter in their accounts have been recorded accurately in the Code of Ethics app.

Annual Certification Requirements

Employees must certify annually, that, among other things, their securities accounts, holdings and transactions are accurately disclosed. This requirement does not apply to Managed Accounts. Employees with Managed Accounts shall provide a separate certification.

In General

Global Compliance shall be responsible for administering and monitoring Employee adherence to the Code, including reviewing disclosures, providing training and identifying violations. From time to time, situations may arise with respect to certain provisions of this Code that require interpretation. Employees may contact personaltrading@lordabbett.com for clarification regarding the applicability, meaning or administration of this Code, in advance of any contemplated transaction and should not proceed until they receive a response.

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

Material Changes

Material changes to the Code shall be approved by the Standards & Practices Committee, which shall also serve as a point of escalation for matters relating to the Code. Material changes to the Code shall also be approved by the board of trustees/directors of each Lord Abbett Fund, including a majority of the Independent Trustees/Directors. Approval of any material change to the Code by the board of trustees/directors of the Lord Abbett Funds shall be obtained within six months after the change is implemented.

CCO Reporting

At least annually, the Chief Compliance Officer of the Lord Abbett Funds shall provide:

Recordkeeping

Records shall be retained in accordance with the requirements of Rule 17j-1(f) under the Investment Company Act.

Violations are taken seriously and may result in sanctions or other consequences, including one or more of the following:

Employees are required to self-report to Global Compliance if they believe they have violated the Code.

Global Compliance applies a rolling two-year look-back period when tracking violations of the Code. All violations of the Code shall be reported to the boards of trustees/directors of the Lord Abbett Funds and any other applicable board or client, upon request.

Exceptions to the Code may be granted in the discretion of the Global Chief Compliance Officer. All exceptions will be considered on a case-by-case basis once it is determined that the proposed conduct involves no opportunity for abuse and does not conflict with the interests of clients.

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

Access Persons means:

Approved List means a financial institution that agrees to provide Global Compliance with an automated data feed of the transactions effected in an Employee’s personal securities account. The Approved List will be available to Employees in the Code of Ethics app.

Beneficial Owner means an individual with the opportunity, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, to share at any time in any economic interest or profit derived from ownership of or a transaction in a security. An Employee may be deemed to be the Beneficial Owner of securities belonging to others and not registered in their name. The SEC will presume that a person Beneficially Owns securities held by a Family Member who shares their household or securities held by a trust of which the individual is a beneficiary or a trustee with investment Control. An Employee is not considered to be the Beneficial Owner of a 401(k) account, individual retirement account or a transfer upon death account of a Family Member for which they are solely a named beneficiary, assuming the Employee does not reside with the Family Member and does not have the ability to Control and/or direct transactions in such account.

Broad-based ETF means an exchange traded fund that is not a Narrow ETF (see definition below).

Control means the power to exercise a controlling influence over the management or policies of a company. Ownership of more than 25% of a company’s outstanding voting securities is presumed to give the holder thereof Control over the company.

Employee means any person who is a partner or employee (or Family Member of a partner or employee) of Lord Abbett; or an officer, director or employee of the Lord Abbett Funds; or a contractor, consultant, or any other person who has been deemed to be an Access Person and been notified by Global Compliance that they are subject to this Code. For the avoidance of doubt, the term “Employee” also includes those interns who are determined to be Access Persons.

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

ETF means an exchange-traded fund.

ETN means an exchange-traded note.

Family Member means the Employee’s spouse, domestic partner, parent, stepparent, child, stepchild, sibling, grandparent, grandchild, or in-law (including mother, father, sister, brother, daughter or son) as well as adoptive relationships sharing the same household as the Employee. For the avoidance of doubt, this definition includes children who reside in the Employee’s home while not attending college but does not include an Employee’s adult children who no longer share the Employee’s home.

Independent Directors/Trustees means those directors/trustees of the Lord Abbett Funds who are not deemed to be “interested persons” (as defined in Section 2(a)(19) of the Investment Company Act) of Lord, Abbett & Co. LLC or the Lord Abbett Funds.

Investment Advisers Act means the U.S. Investment Advisers Act of 1940, as amended.

Investment Company Act means the U.S. Investment Company Act of 1940, as amended.

Investment Professional means an Employee who is also:

Lord Abbett means Lord, Abbett & Co. LLC, an investment adviser registered with the SEC, and its affiliates, including the Lord Abbett Advisers and Lord Abbett Distributor LLC.

Lord Abbett Advisers means Lord, Abbett & Co. LLC and its advisory affiliates.

Lord Abbett Funds means collectively, (i) the family of open end mutual funds registered with the SEC and advised by a Lord Abbett Adviser and (ii) the family of funds consisting of: (a) closed-end investment companies that have elected to be regulated as business development companies under the Investment Company Act and advised by a Lord Abbett Adviser, and (b) the closed-end interval funds registered under the Investment Company Act and advised by a Lord Abbett Adviser.

Managed Account means a Personal Account that meets the following requirements:

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

Managed Account Certification means the document executed by the adviser to a Managed Account that generally states that:

Narrow ETF means an exchange traded fund that: (i) has 20 or fewer holdings; or (ii) is concentrated in a specific sector or industry (e.g., energy, healthcare, financial services).

Private Placement means an offering of securities (e.g., hedge fund, private equity fund, venture capital fund) that is exempt from registration by a regulatory authority and sold through a private offering. For the avoidance of doubt, investments made: (i) in a small business sourced through family, friends or any referral source; and (ii) through a crowdfunding site that matches entrepreneurs with investors through which investors receive an equity stake in the business, are considered Private Placements.

Restricted List means the list of issuers maintained by Global Compliance for which Lord Abbett or an Employee may be in possession of material, non-public information.

SEC means the U.S. Securities and Exchange Commission.

Security means, except as noted below:

The term Security does not include:

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

Sub-Advised Fund means a mutual fund sponsored by a third party and advised or sub-advised by a Lord Abbett Adviser.

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

EXHIBIT A

CODE OF ETHICS AND PERSONAL TRADING POLICY

Provisions Applicable to Independent Directors/Trustees of the Lord Abbett Funds

The Independent Directors/Trustees of the Lord Abbett Funds (the “Independent Board Members”) are not subject to the Code except to the extent set forth below.

In General

The Lord Abbett Advisers make every effort to ensure that the Independent Board Members do not receive information that will subject their personal securities transactions to the requirements of the Code; therefore, Independent Board Members generally are not required to obtain pre-clearance to purchase or sell Securities, or to submit holdings and transaction reports.

However, no Independent Board Member shall in connection with the purchase or sale, directly or indirectly, of a Security held or to be acquired by one of the Lord Abbett Funds:

Quarterly Transaction Reporting Requirement

Independent Board Members are required to submit a quarterly transaction report to Global Compliance (personaltrading@lordabbett.com) when they know or reasonably should have known at the time of a transaction in a particular Security that a Lord Abbett Fund was transacting or considering a transaction in that Security during the 15-day period immediately before or after the date of the transaction by the Lord Abbett Fund. If the Independent Board Member enters into that transaction, they must report all securities transactions effected during the quarter for their Personal Account or for any account that would be in scope under the Code in the manner required by Rule 17j-1(d)(ii).

Other Board Positions

Prior to becoming a director of any public company, Independent Board Members must inform the Legal Department to discuss whether accepting such appointment will create any conflict of interest or other issues.

Annual Certifications

Independent Board Members are required to annually certify to their compliance with Exhibit A to the Code.

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

EXHIBIT B

PRE-CLEARANCE/REPORTING/30-DAY HOLD MATRIX

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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CODE OF ETHICS AND PERSONAL TRADING POLICY

This policy is proprietary and may not be distributed to, or shared with, any third-parties, unless required by applicable law or approved by Lord Abbett Global Compliance.

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