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Message Classification: Internal Use

Classification: Internal Use2Business participation in social media is permitted solely for pre-approved program participants. As a program participant, you may engage in social media only via authorized channels and tools and through approved accounts.The Social Sales Enablement Program, which provides for active monitoring of enrolled social media accounts, requires program participants to:• complete training on social media for business use,• use only an approved account,• adhere to adviser-specified profile standards,• read and agree to the Program terms and conditions, and• authorize Principal to actively monitor your profile and posts/social activity on a pre and/or post review basis.1Currently, LinkedIn is the only permitted social media platform approved for business use. Subject to compliance pre-approval, however, the advisers’ marketing department may be permitted to maintain a social media presence on other platforms.Information on specific requirements for program participants and non-program users can be found in Exhibit A and Exhibit B, respectively, to this Social media policy.Use of social media for business(program participants only)1Employees who do not opt in to the Program are still subject to periodic review and spot checking of public social media content at the discretion of the advisers and are subject to disciplinary action for violations of these policies.DEFINITIONSAdvisers: For purposes of this policy the “Advisers” include Principal Global Investors, LLC (PGI) and Principal Real Estate Investors, LLC (PrinREI).Note: PGI (including certain adviser affiliates) began using Principal Asset Management ("Principal AM") as a DBA (doing business as) name, and the Advisers will be referenced throughout this document as Principal AM (or "the Firm"). While Principal AM may include other entities, this Policy only applies specifically to the Advisers named above.Clients: Clients refers to the Advisers’ separately managed accounts, Mutual Funds, Interval Funds and Private Funds.Employees: Employees refers to the Advisers’ officers, principals, directors and employees.Social media is defined as any digital technology or practice that enables people to use, create, and share content, opinions, and insights in conversations over the internet. This includes many of the platforms traditionally identified as social media such as Facebook, Twitter, Instagram, and LinkedIn. However, it also includes other communication channels such as YouTube, blogs, and comments included on websites that provide product reviews and services. This policy is meant to be an extension of the electronic communication and marketing policies of Principal Asset Management (Principal AM) governing business communications and is in addition to any other applicable policies of the advisers, Principal Financial Group (Principal, or Corporate) and, if a registered rep, Principal Funds Distributor (PFD) and Principal Securities, Inc. (if applicable).

Use of social media for personal use(all non-programsocial media accounts)(see Exhibit B)The advisers respect an employee’s right to use social media forpersonal, non-business purposes. Employee personal social media profiles on sites such as Facebook, Twitter, or LinkedIn can includeidentification as an employee of the advisers; however, the profile mustbe limited to the employee’s personal biographical informationand may not include any information about the advisers’ advisory activities (including photos or videos) funds, products, services, securities information, or any other investment-related content or communication.Any business-related information displayed must be static, truthful, and presented in a concise manner. Further, an employee may not engagein personal social media activity that could be construed as providinginvestment advice, market commentary, or promoting advisory services; and may not provide links to third party websites or share content from the advisers, affiliates, Principal, or its competitors. In addition, withrespect to business- related financial services content, the use ofinteractive features, such as commenting, chatting, messaging, liking, orparticipating in groups is also prohibited.Promotion of the advisers and electronic communication related to the advisers’ business must only be conducted using approved accounts through approved channels and methods as later defined herein.Non-program users must also be familiar with the Principal AM Compliance Manual and, if applicable, the Principal Funds Distributor, Inc. (PFD) Compliance Manual and understand the rules governing the use of social media (including LinkedIn) for non-program users.See Exhibit B, Principal AM LinkedIn guidelines for non-program users. Also, a summary chart for guidance purposes appears in Exhibit C of the Social media policy.Leaders who wish to post about employment opportunities are not required to be a program participant, provided that the social mediaactivity is limited to posting the HR-provided job link and directs interested applicants to the hiring manager’s approved (principal.com) email address.For guidance concerning social media marketing on behalf of the advisers, contact the email distribution list, PGI Social.Use of social media for recruitingClassification: Internal Use3

Press inquiriesGeneral prohibitions for allUnless specifically authorized to do so, Employees may not respond to mediaor press inquiries received via social media regarding the advisers, itsbusiness, or products. Employees must send all such social media inquiries to Principal’s Corporate Relations team for appropriate review and response.Further, if an employee receives a comment, via social media or otherwise,that could be a potential complaint, the employee must follow the advisers’complaint and escalation policy.All users must refrain from the following activities:• Discussing, mentioning, or otherwise communicating any informationrelating to:- the business of Principal,- an existing, former, or prospective client or investor,- any other officer or employee of Principal,- any actual or potential service providers, counterparties,or competitors,- portfolio information or potential investment opportunities (includingissuers or potential issuers),- a recommendation or guidance with respect to a specific securityor other investment, and- information which might either give rise to the other party gaininginsight into a trading position in a particular underlying instrument,strategy in respect of a particular market or client, or informationwhich may encourage the other party to adopt an investment stancein relation to the same.• Making any forward-looking or predictive statement about theperformance or specific future results of Principal, its member companies, or any of its clients including Principal Funds.• Hosting, maintaining, or participating in a blog, website, or otherunapproved/unmonitored social media forum that covers, in whole or inpart, the financial industry, financial advice or topics related thereto, oris likely to mention Principal, the business of Principal, or a competitor of Principal.• Posting photographs of persons employed by or affiliated withPrincipal, whether inside or outside of the office, or at work eventswithout first obtaining their specific consent to do so in each instance.• Providing a link to the Principal.com or PrincipalAM.com websites (or website of a Principal affiliate) on any blog, social networkingsite, or other website, except as otherwise expressly permitted by this policy.• Posting on social media an identifiable work email address (e.g.,[name]@principal.com) or other identifying business contactinformation, except as otherwise expressly permitted by this policy.• Communicating through social media on behalf of Principal or indicatingthat the views or comments being expressed by staff through socialmedia are a reflection or representation of the views of Principal, its personnel, its clients, or investors.Classification: Internal Use4

Classification: Internal Use 4EXHIBIT APrincipal AM LinkedIn guidelines for program participantsPrincipal AM employees can participate in the Social Sales Enablement Program administered by Principal and monitored by Principal AM. Administrators for the Program will help program users through the appropriate setup procedures to ensure appropriate monitoring and retention of authorized LinkedIn account activity. Program participants areafforded greater online capabilities and will be required to use specific programs to publish and capture social media activity. The table below illustratesfunctionality differences between non-program users and program participantsincluding those registered with Principal Funds Distributor.Principal will provision single-sign on access to Seismic LiveSocial (publishing platform) and Proofpoint Patrol (compliance tool). As a program participant, you must complete the following setup process:STEP ONE: Complete social media training course.STEP T WO: Read the guidelines and ensure your LinkedIn profile meets the requirements.STEP THREE: Agree to Program terms and conditions to complete onboarding process.STEP FOUR: Connect LinkedIn account with Seismic LiveSocial and Proofpoint Patrol, and complete profile review/approval process.STEP FIVE: Begin sharing content on LinkedIn.

LinkedIn about sectionTwo options:1. Leave blank.2. Create an appropriate bio that is accurate and up-to-date. As a program user, your initial profile and subsequent changes to it will be subject to pre-approval by Compliance via the monitoring tool. Note: Only mention industry designations that are currently held by you and which are Compliance approved for use. Additional requirements:• If adding an email address, it must be your principal.com email address.• If applicable, include designation disclosures.A LinkedIn profile must comply with the following guidelines:• Use your principal.com email accountas the email address on file.• You may make edits by clicking onMe > View Profile and using the“pencil” icon next to each section.• Use a professional headshot withoutany other people or objects present inthe image.• The Principal logo may not appear in the background of the photo. Principal AM marketing may provideapproved headers.• Your name and title must appear exactly as on your approved business card. If you don’t have a business card, the title displayed must match your Outlook title. Exceptions must be pre-approved by Compliance.BDClassification: Internal Use6ACBCAGuidelines for Program Participants:

LinkedIn experience section• May include the name of school/ college/university at which you studied (attendance dates are optional).• May include degrees obtained or field(s) of study.• May include college activities or society membership.• May include industry designations only if such designations have been approved for use on your business card.• Contact PGI Social* if you need toverify if your designation is approvedfor use and if any disclosures arerequired.*PGI Social is an email distribution list. LinkedIn licenses and certifications section• Industry designations must be limited to what is approved for use on your business card and must be active/currently held, otherwise they should not be mentioned.• FINRA / NASAA registrations (i.e. Series exams) listed must be active/currently held, otherwise they should not be mentioned.• Relevant certifications can generally be listed.E• May include: Company approvedawards but generally may not includeawards or recognitions received at prioremployers.• Previous positions. Position title and company names are permissible (with location and time periods optional).• Job descriptions must be accurate and can generally list duties/ responsibilities of current and past roles• Specific accomplishments, claims, and awards may not be listed without pre-approval by Compliance.FLinkedIn education sectionClassification: Internal Use7FEGuidelines for Program Participants:

Permitted uses• Make connections. Add contacts to your LinkedIn network.• Use LinkedIn Messenger with new or current contacts.• Know the rules. Get familiar with the Principal AM policies and understand therules governing the use of LinkedIn forprogram users.• Follow and post in industry related Groups. Posting in Groups must follow the same guidelines as all LinkedIn posts. Messaging should be broad, not personalized, avoiding the appearance of specific recommendations.• You may participate in LinkedInGroups that are unrelated to activitiesofyour employment (i.e., alumni groups, community groups, etc.), provided you do not post content related to your role.• A summary chart for guidance purposes appears at Exhibit C of the Socialmedia policy.• LinkedIn mail service (InMail).Communication through InMail is permitted for Program users using enrolled accounts. Messages are subject to monitoring and are captured through Proofpoint Patrol. Limitations on use• Recommendations are allowed on your profile with the following conditions.₋ You are not allowed to solicit recommendations or offer recommendations in exchange forcompensation or any incentive(including the offer to write arecommendation). All recommendations must be fair andbalanced, should not promisereturns and should not contain any personally identifiable information about specific clients financial situation. If any of these conditions are not met the recommendation should be hidden, contactcompliance for questions about thepolicy.₋ Recommendations given or received are subject to review and may be hidden or deleted by Proofpoint Patrol.Classification: Internal Use8GGGuidelines for Program Participants:

Prohibited uses (continued)• Endorsements are permitted for allowedskills. All endorsementsmust be fair and balanced and meet the communication requirements in the Marketing materials section of the manual. If any endorsement languagecontains any non-compliant information please contact compliance promptly.• If you do elect to include endorsements the following disclosure MUST be included in your about me section:(1) Testimonials or endorsements are made by business relationship and or potential institutional client and no testimonials or endorsements are made on the basis of personal individual investor beliefs; (2) no cash or non-cash compensation was paid for any testimonials or endorsements (3) any conflicts of interests will be disclosed and noted in the endorsement as appropriate.• If you do not wish to have endorsements, instructions to Hide them are below.Hide all endorsements:- Click Me > View Profile.- Under the Skills & Expertise section, click the “pencil” icon.- Click adjust endorsements settings.- Click No under I want to be endorsed.- Click Save.SkillsSkills are allowed but are subject to review/approval by Compliance. • Skills should be accurate and relevant for the user. • Skills can generally reflect past experience but cannot imply that a past function is current or imply an offer of services.• Licenses or designations must be currently held and active in order to be listed.• For program participants, the following disclosure is automatically added to a user’s profile when they join the program: “The skills list below does not imply licensure, training, or the ability to solicit products or services.”IJClassification: Internal Use9IHHJGuidelines for Program Participants:

Classification: Internal Use 9EXHIBIT BPrincipal AM LinkedIn guidelines for users who do not opt in to the Program (non-program users) Social media communications, like all communications with the public, are considered advertisements and covered by the Investment Advisers Act of 1940 Rule 206(4)-1. If you’re registered with a broker dealer, the content is also subject to the content standards present in FINRA Rule 2210 for registered representatives. While the advisers recognize that employees may use LinkedInfor personal purposes, LinkedIn is used primarily as a business social media site. Assuch, LinkedIn activity must be afforded the same level of care where your activitycould be perceived as representing your employer.

A LinkedIn profile must comply with the following guidelines:For Employees with an existing profile, Employees may make edits by clicking on Me > View Profile and using the “pencil” icon next to each section.• Employees should use a professional headshot.• The Principal logo may not appear in the background of the photo.LinkedIn about section• May not include references to securities, insurance, or informationabout Principal.• May include a general description of professional skills and experience and/or personalhobbies and interests.• May not include any compliance disclosures to give the profile the appearance of being “for business use.”LinkedIn education section• May include the name of school/ college/university at which you studied (attendance dates are optional).• May include degrees obtained or field(s) of study.• May include college activities or society membership provided such entries are unrelated to financial services.• May include industry designations only if such designations were approved for use on your business card.• Contact your leader to verify whether any such designation is approved for use as well as to verify whether any related disclosures are required.LinkedIn licenses and certifications section• Industry designations must be limited to what is approved for use on your business card and must be active/currently held, otherwise they should not be mentioned.• FINRA / NASAA registrations (i.e. Series exams) listed must be active/currently held, otherwise they should not be mentioned.• Relevant certifications can generally be listed.BACACDClassification: Internal Use11BDGuidelines for Non-Program Users:

Classification: Internal Use12General prohibitions• Do not use LinkedIn for investment/ financial services related business purposes.• Do notpost anything investment or financial services related.• Do notlike or comment on investment related or financial services related posts.Permitted uses• Post and interact with (e.g., like or comment on) content that is notinvestment or financial services industry related.• Interact with (but not post) certain Principal content:- It is permissible to interact with a Principal post that is notproduct/strategy, investment, or financial services related. For example, liking a corporate post about a charitable or community event or an employee's change in role i.e. starting a new job, promotion, etc.• Limited exception to post an HR-provided job link for a job opening at Principal (see page 3 for other limitations/details)• Search for people. Use the LinkedIn search function to search by name or emailaddress.• Make connections. Add contacts to your LinkedIn network.• Follow groups related to your activities butmay not post content or interact in such groups.• Participate in LinkedIn groups that are notwork related (i.e., alumni groups, communitygroups, etc.), provided you do not post contentrelated to your role.Guidelines for Non-Program Users:Other limitations for profiles and activity:• Experience section may list prior work including title, name of company, and dates of employment. If included, job descriptions must be accurate and can generally list duties/responsibilities of current and past roles. However, specific accomplishments, claims, and awards may not be listed without pre-approval by Compliance.• Recommendations are not allowed. Recommendations must be deleted immediately. Further, you may not solicit oradd any new recommendations.• Endorsements are allowed; however, compensating others, directly or indirectly, for an endorsement related to financial services is prohibited.• You may not use any LinkedIn messaging ormail services (including “InMail”) to sendmessages related to your role or activities forPrincipal.• Profiles may not contain any mention ofsecurities, products, services, or any Principal entity (except in a job title, which shouldmatch information contained on yourbusiness card if different than title in Outlook).• Skills are allowed but are subject to review/approval by Compliance. Skills should be accurate and relevant for the user. Skills can generally reflect past experience but cannot imply that a past function is current or imply an offer of services. Licenses or designations must be currently held and active in order to be listed.

Classification: Internal Use 12EXHIBIT COverview of LinkedIn Functionality by EmployeeCategoryThe advisers reserve the right to monitor, access, delete, and disclose any and all information on company-owned devices, as well as any and all electronic communications and internet usage via company-owned property and/or systems, with or without prior notice.With respect to LinkedIn usage, the advisers recognize three categories of employees:Program participants registered or associated with PFDProgram participants not associated with PFDNon-program users who have not opted in to the Program

LinkedIn functionalityPFD registered rep or associateNot registered or associated with PFDEmail address principal.com principal.com PersonalCreate profile Personal use only, no content related to financial services or PrincipalMake connectionsJoin group*Participate in groups*Create or host groups*Create a postPublish Principal and third-party content (with exceptions) via Seismic LiveSocialNo access to LiveSocialcontentUse InMail (pay for the ability to send messages to people who aren’t connections)Personal use only, not for business communicationsUse messaging (no charge and to connections only)Website Approved options: Principal.com PrincipalAM.comWebsites at leftplus boutique sitesand ex-US websitesas applicableLeave blank.Receive, solicit, or post recommendationsadd or endorsements (without providing compensation)Recommendations are not allowed. Endorsements are allowed with limitations.“Like” itemsAvoid financial services-related and Principal-relatedcontent.Exercisepersonal discretion on unrelated topics.“Comment” on postsBrief and professional contentBrief and professional contentProjectsHonors and awardsBusiness use:Program ParticipantsPersonal use:non-programusersClassification: Internal Use14

LinkedIn functionalityPFD registered rep or associateNot registered or associated with PFDPatentsAvoid financial services-related and Principal-relatedcontent.Exercisepersonal discretion on unrelated topics.Write an articleMarketing creates contentMarketing creates contentUpload an imageCoursesShare a videoApproved content onlyApproved content onlyPost on LinkedIn jobsList skillsSkills should be accurate and relevant for the user. (See policy details)Skills should be accurate and relevant for the user. (See policy details)Skills should be accurate and relevant for the user. (See policy details)CertificationsOnly certifications approved for display onbusiness cardOnly certifications approved for display onbusiness cardOnly certifications approved for display onbusiness cardLanguagesCreate profile in another languageTest scoresBusiness use:Program ParticipantsPersonal use:non-programusers* Participation in LinkedIn groups is subject to the following requirements:• Program participants may follow and post in Groups but must follow the same guidelines as all LinkedIn posts. Messaging should be broad, not personalized, avoiding the appearance of specific recommendations..• Program participants and non-program users may participate in LinkedIn groups that are unrelated to their role or activities (i.e., alumni groups, community groups, etc.), provided they do not post content related to their role.Updated 11/20/2024Classification: Internal Use15