While the Invesco Whistleblower Hotline website is hosted by third party service, independent from Invesco, if you are concerned with ensuring your submission will be anonymous, we recommend all employees use a non-Invesco computer when submitting their case.

Invesco Whistleblower Hotline

Invesco holds itself and its employees to the highest standards of honest and ethical conduct, and strives to ensure that all activity conducted by, or on behalf of, the firm and its subsidiaries is in compliance with applicable laws, rules and regulations. Employees of Invesco and its subsidiaries are affirmatively required to report possible violations of the Invesco Code of Conduct (“Code”). Such violations can include, but are not limited to:

• Violations of any laws or regulations generally applicable to Invesco
• Questionable accounting matters, internal accounting controls, auditing matters, breaches of fiduciary duty or violations of United States or foreign securities laws or rules (collectively, “Accounting Matters”) including, but not limited to:
• Fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement of Invesco
• Fraud or deliberate error in the recording and maintaining of financial records of Invesco
• Deficiencies in or non-compliance with Invesco’s internal accounting controls
• Misrepresentation or false statements to or by a senior officer or accountant regarding a matter contained in the financial records, financial reports or audit reports of Invesco
• Deviation from full and fair reporting of Invesco’s financial condition; or
• Fraudulent or criminal activities engaged in by officers, directors or employees of Invesco

Invesco’s Board of Directors and senior management fully support this environment and encourage employees to speak up if they encounter concerns. Our firm’s policy for the report of potential wrongdoing either within the organization, or involving a third party that Invesco does business with, is summarized below.

To report a concern where individuals may be in physical danger, call +1 713 214 2221, which is monitored 24 hours a day, 7 days a week by Global Security. To request emergency assistance, call your local emergency services number for Police/Medical/Fire response.

Violation Reporting Process

You are strongly encouraged to review applicable provisions of the Code regarding reporting of potential violations, and are reminded that if you do encounter a possible violation of the Code, laws or regulations, you are required to report it in one of four ways:

1. Contact your supervisor: We encourage you to first contact your immediate supervisor, or another appropriate person in your management chain. You should discuss your concern in detail and work together by following Invesco’s established reporting and escalation processes in order to address the matter. OR
2. Contact the Legal, Compliance, Internal Audit or Human Resources Departments: Where it may not be appropriate to discuss the matter with your supervisor or others in your management chain, you may instead contact one or more of the Legal, Compliance, Internal Audit or Human Resources Departments directly. The individual you report the matter to will ascertain the details of your concern and will work with you to ensure Invesco's reporting and escalation processes are appropriately followed in order to address the matter.
   OR
3. Contact the Invesco Whistleblower Hotline: If you do not wish to raise your concern via one of the first two methods, or if you and/or the individual you have reported your concern to do not feel that Invesco’s established reporting and escalation channels would effectively address or are effectively addressing the matter you have raised, you may anonymously report the suspected violation(s) in two ways
   
   By Telephone: The Whistleblower Hotline website has access to all global, toll-free phone numbers. To ensure confidentiality, this phone line is managed by an independent company, and is available 24 hours a day, 7 days a week. All calls to the Invesco Whistleblower Hotline will be reviewed by Internal Audit and handled in a prompt, fair and discreet manner.
   
   All calls will be answered by a live person. Calls are not recorded and are not able to be traced, and you have the option to remain anonymous. You will be given a Case ID so that you may follow up on your report, and you will be guided through the call and prompted by appropriate questions from the operator. Once the call is completed, a report will be generated and sent to Internal Audit. You are urged to call back for follow up, or to log in through the Invesco Whistleblower Hotline website in the event more information is required.
   Via the Internet: You may visit the Invesco Whistleblower Hotline website and submit your concern electronically through our independent provider www.invesco.ethicspoint.com. This website is managed by the same independent company who manages the telephone hotline, and the website is available 24 hours a day, 7 days a week. All reports submitted through the website will be routed to Internal Audit as noted above. Similar to reporting via the telephone, you will have the option to remain anonymous. A Case ID will be provided at the conclusion of your reporting, allowing you the option to follow the progress of your case through the website and provide additional information, if needed. As an added step to ensure anonymity when reporting in this manner, you should visit the website and submit your concern through a non-Invesco computer.
OR
4. Contact the Invesco Ombuds
   Invesco established the Ombuds to give employees a resource to convey Invesco Funds business-related concerns they believe could implicate matters of questionable ethics or business practices. You can speak directly with Invesco’s Ombuds by calling 713-214-2235 or sending an email to ombuds@invesco.com.
   

If you report a possible violation, regardless of the method that you use to make the report or whether you choose to remain anonymous, it is important that you provide as much detail as possible, including names, dates, times, locations, and the specific conduct in question. Only with sufficient specific information can Invesco adequately investigate the reported concern.

Your submission of information will be treated in a confidential manner to the extent reasonably practicable in the circumstances, and regardless of the reporting method, you can always choose to remain anonymous. Please note, however, that if an investigation by Invesco of the activities you have reported takes place, it may not be possible for Invesco to maintain the confidentiality of the fact of the report or the information reported.

Violations Related to Accounting Matters
Any reported concerns that purport to involve Accounting Matters will be reviewed under Audit Committee direction and oversight by such persons as the Audit Committee determines to be appropriate. All other matters will be reviewed under the direction and oversight of the appropriate departments within Invesco, usually also including the Legal, Compliance and/or Internal Audit Departments. All employees are required to cooperate with any review or investigation. Prompt and appropriate corrective action will be taken when and as warranted in the judgment of the Audit Committee or other reviewing department or governing body.

Nothing in this reporting process shall prohibit an employee from reporting possible violations of law or regulation to any governmental agency (including self-regulatory bodies) or regulator, or from making disclosures that are otherwise protected under the whistleblower provisions of applicable laws or regulations. While employees are encouraged to use Invesco’s internal arrangements prior to contacting an agency or regulator so Invesco may investigate the issues raised, doing so is not a condition to making a disclosure to an agency or regulator.

Invesco takes any reports received via management or the Invesco Whistleblower Hotline/Website very seriously. As a reminder, Invesco will not permit retribution, harassment or intimidation of any employee who in good faith reports a possible violation.