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Franklin Resources, Inc. Anti-Corruption Policy Overview

Purpose & Objective

This overview of Franklin Resources, Inc. Anti-Corruption Policy outlines the principles that FRI and its affiliates (collectively “FTI” or ”we”) follow to achieve zero-tolerance against bribery and corruption. The objective of our anti-corruption policy is to ensure that appropriate anti-corruption and bribery procedures are in place across the globe to avoid any violations of relevant laws and regulations.

Franklin Templeton GSC Asset Management Sdn. Bhd., being a subsidiary of a U.S. registered entity, is bound by the requirements of the U.S. Foreign Corrupt Practices Act.

This policy applies to all officers, directors, shareholders, employees and appointed third party representatives of FTI (including but not limited to agents, intermediaries, consultants and introducers) in all locations. Violation of this policy will be severely sanctioned, including where appropriate disciplinary procedures, up to and including termination of employment and possible referral to the appropriate criminal or regulatory authorities. FTI intends to review doing business with others who do not commit to the same standard of zero-tolerance of corruption, including joint ventures partners and distributors.

Please contact us if you require more information on this policy.