Item 2. Code of Ethics.

(a) As of the end of the period covered by this report, the registrant has adopted a code of ethics for senior officers pursuant to the Sarbanes-Oxley Act of 2002 (“SOX Code”) that applies to the registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party.

For purposes of this item, "code of ethics" means written standards that are reasonably designed to deter wrongdoing and to promote:

1. Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;

2. Full, fair, accurate, timely, and understandable disclosure in reports and documents that a registrant files with, or submits to, the Commission and in other public communications made by the registrant.;

3. Compliance with applicable governmental laws, rules, and regulations;

4. The prompt internal reporting of violations of the code to an appropriate person or persons identified in the code; and

5. Accountability for adherence to the code.

(b) During the period covered by this report, there were no amendments to the Fund’s SOX Code.

(c) Waivers: During the period covered by the report, the registrant has not granted any express or implicit waivers from the provisions of the SOX Code.

(d) Not applicable.

(e) The Registrant’s SOX Code referred to in Item 2(a) above is attached as an Exhibit 19(a)(1), hereto.

Item 3. Audit Committee Financial Expert.

As of October 31, 2025, the Registrant's Board of Directors has determined that the following members of the Audit Committee are audit committee financial experts and independent: Carolyn N. Ainslie and Jill R. Cuniff. 

Item 4. Principal Accountant Fees and Services.

(a) Audit Fees

For the fiscal year ended October 31, 2025, the Registrant’s principal accountant was PricewaterhouseCoopers LLP (“PwC”). For the fiscal year ended October 31, 2025, PwC billed the Registrant $279,250 for the audit of the Registrant’s annual financial statements in connection with statutory and regulatory filings.

For the fiscal year ended October 31, 2024, the Registrant’s principal accountant was KPMG LLP (“KPMG”). For the fiscal year ended October 31, 2024, KPMG billed the Registrant $289,740 for the audit of the Registrant’s annual financial statements in connection with statutory and regulatory filings.

(b) Audit-Related Fees

For the fiscal year ended October 31, 2025, PwC did not bill the Registrant for audit-related services.

For the fiscal year ended October 31, 2024, KPMG did not bill the Registrant for audit-related services.

(c) Tax Fees

For the fiscal year ended October 31, 2025, PwC billed $71,550 for professional services rendered by for the review of domestic tax returns.

For the fiscal year ended October 31, 2024, KPMG billed $162,175 for professional services rendered by for the review of domestic tax returns.

(d) All Other Fees: The aggregate fees billed in each of the last two fiscal years for products and services provided by PwC in 2025 and KPMG in 2024, other than the services reported in paragraphs (a) through (c) of this Item are $0  and $0, respectively.

(e)(1) Disclose the audit committee pre-approval policies and procedures described in paragraph (c)(7) of Rule 2-01 of Regulation S-X. A copy of the Audit Committee’s Pre-Approval Policies and Procedures is incorporated by reference under Item 19(c)

(e)(2) There were no amounts that were pre-approved by the Audit Committee pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X.

(f) Not applicable.

(g) Not applicable.

(h) Not applicable.

(i) Not applicable.

(j) Not applicable.

Item 5. Audit Committee of Listed Registrants.

Not applicable.

Item 6. Investments.

(a) Schedule of Investments is included as part of the financial statements filed under Item 7(a) of this report on Form N-CSR.

(b) Not applicable.

Item 7. Financial Statements and Financial Highlights for Open-End Management Investment Companies.

(a) - (b) The Financial Statements and Financial Highlights are included herewith.