CODE OF CONDUCT

Revised as of January 2013

These guidelines define the standards to which all employees of OppenheimerFunds, Inc. and its
subsidiaries and affiliates (all of which are referred to jointly as the “Company”) are expected to
adhere during the course of their employment with and when conducting business on behalf of
the Company.

Personal honesty and integrity must be consistently exercised, encouraged and reinforced
throughout all levels of the Company and with respect to all Company-related activities, even
those that may not be explicitly addressed in this code or in any other Company policy. It is
essential that every employee understand the importance of communicating with complete
candor when conferring with senior management, legal, compliance and human resources staff,
independent auditors, and our internal audit staff on all matters arising in the normal course of
business. These people cannot perform their functions properly without full disclosure.
Concealment of any pertinent information, for whatever reason, will not be tolerated. When the
Company identifies real or potential problems early, it can usually solve them much more easily,
and with less potential exposure of the Company to liability or regulatory action. Each
individual should promptly inform senior management of the Company of matters that might
adversely affect the Company.

No code of conduct can anticipate every potential conflict or problem that an employee may face
in dealings with investors, brokers, dealers, analysts, suppliers, other third parties and other
employees. This Code is meant to serve as a guide to behavior, and to help establish for each
employee a basis for using good judgment and great care in complying with the spirit of the law
and basic standards of ethical conduct. The Company may have other detailed practices and
policies on specific issues discussed in the Code, and those other practices and policies should be
reviewed and followed as well. All such Company policies are posted on the Company’s
intranet system, OPnet, and /or distributed to employees. You should be sure to review these
policies periodically and every time that they are revised or updated.

I. Adhering to and Promoting Compliance with the Law

Employees are required to act in a lawful manner with respect to all Company-related matters.
In particular, every employee must comply with all Federal, state and local laws and regulations
that apply specifically to our particular businesses, as well as with all current and future
Company policies, and with the generally accepted standards of integrity and honesty that apply
to our industry. Employees are expected to consult with our Legal Department to seek assistance
in understanding and complying with any law or Company policy that they believe appears
unclear. The provisions set forth below highlight some of the legal and regulatory related
matters and requirements to which employees should pay particular attention and explain the
related standards to which employees are expected to adhere.

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 A. Reporting Certain “Disabling Conduct”

Section 9(a) of the Investment Company Act bars persons who have committed certain acts from
serving as employees, officers or directors of a mutual fund or its distributor, and bars a company
from serving as an investment advisor to a mutual fund if any of its affiliated persons or
companies are so barred. Because any violation of Section 9(a) would threaten the very basis of
our business, advising and distributing mutual funds, any person who has committed any of the
following acts must immediately notify senior management, the Human Resources Department
or the Legal Department:

(1) Conviction, within the last ten years, of any felony that occurred in the U.S.,
or of any misdemeanor or foreign felony conviction involving the purchase or
sale of any security or commodity or arising out of such person’s conduct as
an affiliated person, salesman or employee of any investment advisor or
insurance company; or

(2) Permanent or temporary injunction of any person, by order of any court, from
acting as an affiliated person, salesman or employee of any investment
company, bank, broker, dealer or investment advisor or insurance company, or
in connection with the purchase or sale of any security.

B. Reporting Other Legal Matters

In order to insure that the Company is able to comply with all of its regulatory, fidelity bonding
and other contractual requirements, all employees are required to report promptly to the
Company’s Compliance Department if they are convicted in any criminal matter, including any
felony conviction, during the time of their employment with the Company. This reporting
requirement is in addition to any convictions that must be reported on the Company’s
employment application. Employees are required to report all such criminal convictions, even if
they intend to appeal the conviction(s) or to seek any other form of legal relief.

In addition, employees who hold any professional licenses that relate to their employment with
the Company, including, but not limited to, securities licenses, are required to notify the
Compliance Department if they are or become subject to any civil or regulatory proceeding or
any other matter that would be reportable under the relevant rules and regulations governing
those licenses. Such reportable proceedings or matters may include, but are not necessarily
limited to, matters reportable by FINRA-licensed personnel under applicable FINRA Rules.
Employees must also promptly report to the Compliance Department if their license is suspended
or terminated for any reason. In addition, employees who, during their employment with the
Company, are named as respondents or defendants in a legal proceeding, regulatory proceeding
or arbitration in connection with their prior employment must promptly report the matter to the
Compliance Department.

Employees are required to report the matters or convictions described above to the Company’s
Compliance Department on the first business day after he or she learns of the conviction or
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matter. Employees who fail to report such convictions and matters as required may be subject to
disciplinary action as the Company deems appropriate, up to and including termination of
employment. An employee’s criminal conviction or involvement in any legal or regulatory
proceeding will not necessarily result in the termination of his or her employment with the
Company.

C. Personal Investments

Employees may invest in stock and other securities. However, you must never select your
personal investments based on information you learn about the investment activities or the
strategies used by the Company in managing the mutual funds or other accounts for which it
serves as investment advisor. Employees are expected to conduct any personal trading and
investing, including but not limited to their trading and investing in any mutual funds or other
investments managed or advised by or otherwise affiliated with the Company, in accordance
with all applicable laws, rules and regulations. The Company routinely monitors employees’
exchange and investment activity in certain funds, and investments and the Company reserves
the right, in its sole discretion, to take any disciplinary action that it deems appropriate, up to and
including termination of employment, against any employee whose personal investment activity
it deems improper. However, employees should understand that the Company’s failure to take
any specific remedial action with respect to any of their personal investment activities does not
constitute an assessment or assurance by the Company that the activity is proper or would be
deemed as such by any regulatory agency or government officials.
All employees must comply with a separate Code of Ethics established by the Company as
required by Rule 17j-1 of the Investment Company Act of 1940. Those of you who have ready
access to the daily portfolio transactions of the managed mutual funds or other accounts and all
employees who do not normally have ready access to information about the funds’ portfolio
activities but who may learn of such information in the course of their employment may not use
that information for their personal investment activity or provide such information to any person.
Strict compliance with the procedures adopted under this Rule is mandatory for employees to
whom it applies.

All employees of the Company or its subsidiaries under the Code of Ethics are required to
comply with the Company’s requirements as follows: (1) they should obtain prior permission to
establish brokerage accounts and (2) they should provide to the administrator of the Company’s
Code of Ethics duplicate copies of account statements and transaction records for their
brokerage accounts.

D. Potentially Manipulative Conduct

Company policy and applicable law strictly prohibit employees from discussing or otherwise
disseminating any material, non-public information or any information that they have reason to
believe is false or fraudulent. In addition, employees are strictly prohibited from engaging or
participating in any actions designed to create or spread false information that is intended to
affect securities prices or to manipulate the financial markets in any other manner. Such actions
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could include (but are not necessarily limited to) circulating sensational rumors that might
reasonably be expected to affect market conditions or activities.
Employees who receive any securities-related information that they have reason to believe may
be false and/or designed to manipulate the financial markets are expected to notify the
Company’s Chief Compliance Officer, or his or her delegate, of the matter promptly. Employees
are also strictly prohibited from sharing such false or manipulative information with any other
entity or individual, other than as required by the Company’s Chief Compliance Officer or his or
her delegate, or by applicable law.

E. Accounting Policies

All employees must comply with the Company’s established accounting rules and internal
controls. The accounting records must be complete, accurate, and in reasonable detail. All
underlying transactions must be authorized by the appropriate management personnel and
recorded on a timely basis. No revenues, expenses, assets, or liabilities that are not fully
recorded on the Company’s books are permitted. All employees must cooperate with
management’s efforts to assure that the Company will be in compliance at all times with the
accounting rules and requirements of the various regulatory agencies to which it is subject, and
all financial information will be maintained in accordance with generally accepted accounting
principles.

F. Reporting Suspected Illegal or Improper Activities

Any employee who has personal knowledge of any questionable or possibly illegal activities that
could affect the Company should report such activity promptly to the appropriate Company
authorities pursuant to any applicable Company procedures.

The Company has established various procedures through which employees should report certain
matters. Concerns relating to possible improper accounting and auditing activities and related
regulatory violations, for example, should be reported to the Company’s Audit Committee,
President, General Counsel or Chief Compliance Officer pursuant to the Company’s Procedures
for Receiving and Responding to Employee Complaints Regarding Accounting, Internal
Accounting Controls or Auditing Matters and Regulatory or Other Compliance Issues.
Similarly, concerns relating to violations of Company policies or the laws, rules or regulations
relating to suspected employment discrimination or harassment should be reported to the Human
Resources Department or the appropriate members of Company management as proscribed by
the complaint procedure set forth in the Company’s EEO, Anti-Discrimination and Anti-
Harassment Policy.

Employees are required to make all complaints relating to suspected improprieties honestly and
in good faith. The Company encourages all employees to cooperate fully with any investigations
of complaints or suspected regulatory violations that may be conducted by or with respect to the
Company and expects them to treat as highly confidential all information relating to such
investigations. Further, no employee may discriminate against, harass or retaliate against any

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other employee for having filed a complaint in good faith under either of the above-mentioned
policies or as otherwise prohibited by applicable law.

II. Misappropriation of Company Property and Opportunities

The requirement that employees act in a lawful and honest manner also governs the way in
which they conduct themselves with respect to the opportunities, property and information to
which they may have access in the course of their work for the Company. Company policy, as
well as applicable law, generally prohibits employees from misappropriating Company property
and opportunities and requires that they inform the appropriate Company authorities when the
Company’s rights with respect to such property or opportunities may be at risk. The following
provisions address matters relating to some such prohibitions and requirements in further detail.

A. Conflicts of Interest

You may not act on behalf of the Company in any transaction involving other persons or
organizations with whom you have any financial or any other connection without prior approval
of the Legal Department. It will be the continuing responsibility of each employee to avoid
participation in such situations or, if avoidance is not possible, to deal with any conflict in a fair
and ethical manner. If your personal interests might affect your ability to represent the Company
as you would in an unbiased “arms-length” transaction, you should remove yourself form the
transaction.

Contracts must be awarded and commitments must be made to suppliers without favoritism:
transactions of this nature must be conducted strictly on the basis of what will provide the
greatest benefit to the Company. Contracts may be entered into on behalf of the Company or one
of the investment companies we manage only by persons who have specific authority to do so,
and only after the contracts have been reviewed by the Legal Department.

You may not serve as a director, trustee, officer, owner or partner of any other business
organization, with or without compensation, without prior written approval of either the
Company’s General Counsel or it Chief Compliance Officer, or their respective designee. You
may serve without compensation as a director, trustee, officer or representative of a non-profit
organization (e.g., school board, hospital, professional or social organization) with the prior
written approval of your department manager and either the Company’s General Counsel or its
Chief Compliance Officer, or their respective designee. Licensed employees may be required to
provide the Code Administrator a report of all such activities no less than annually. (See also the
section titled “Restrictions on Outside Business Activities” in the Code of Ethics.)

If you are employed outside the company in a capacity other than stated above, you must not
allow such employment to interfere with your job performance at the Company, including
requested or necessary overtime. Employment outside the Company is subject to the Company’s
approval. Such approval may be requested by advising your supervisor and the Human
Resources Department in writing as to the nature of the position, the name of the employer and
expected hours of work. Every employee is expected to devote full time to the Company’s
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subsidiaries without permission from the Compliance or Legal Department.
business during their hours of employment. No one should conduct personal business during
working hours or on the Company’s premises.

Finally, the Company and members of its senior management, whether in a corporate or personal
capacity, are prohibited from engaging in any business relationship or dealings with an
independent Director/Trustee of any of the Oppenheimer funds. Further, any business
relationship between an independent director/trustee of an Oppenheimer funds and any company
in which any Company officer has a financial interest is subject to prior review by the Conflicts
Review Committee of OppenheimerFunds, Inc.

B. Confidentiality

Confidentiality is a fundamental principle of any financial institution. You must take great care
to protect the confidentiality of all information about our operations, and all records relating to
the Company’s business, the business of each of the mutual funds (including shareholder
records) and to preserve the privacy of records relating to our funds’ investors. Any
communication of mutual fund activities or shareholder account balances, account numbers, or
transactions to persons outside the Company, including discussions with family or friends, is
absolutely prohibited except for the Company’s proper business purposes. You should not
disclose any such information unless you are certain that the person receiving the information is
authorized to receive it. If at any time you suspect that any confidential information may have
been inadvertently disclosed (e.g., loss of a laptop, PDA or paper files), you are required to
respect the possible disclosure to Company management immediately.

The confidential treatment of the Company’s business records and plans must be maintained
even after you leave the Company’s employ. Please keep in mind that, both Company policy
and various laws and regulations require you to adhere to the confidentiality provisions described
below. Thus, violation of these provisions could result in not only Company disciplinary
actions, but also civil and/or criminal penalties.

1. Company Information: Any information about the Company’s business activities and records
are the Company’s proprietary business records and may not be disclosed to any third person
outside the Company except for proper business and regulatory purposes. The Company’s
books, records, business plans, and data about its activities, finances, customers and employees
are confidential business information and may not be duplicated or copied for use by third
persons outside the Company other than for proper business purposes.

During the course of your work for the Company, you may have access to sensitive or
confidential Company information that should not be shared even with certain other Company
employees. You should refrain from disclosing any such information to anyone, including your
co-workers who are not authorized or required to have access to such information. If you are
not certain whether a particular individual or entity is authorized or required to have access to
any Company information, you should refrain from disclosing that information until after you
have discussed the matter with the appropriate member of Company management.

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Employees are expected to take great care to protect the security of any materials that contain
confidential or proprietary Company information, regardless of whether those materials contain
information maintained in hardcopy, electronic or any other form. In the event that you lose or
misplace any such materials, or in the event that they are stolen from you, the Company expects
that you will notify your manager immediately and that you will take all reasonable steps
necessary to recover them and/or to minimize the impact of the loss.

2. Shareholder-Related Information: You are strictly prohibited from making hard-copies or

print-outs of any documents or files containing shareholder-related information except for proper
business purposes. Such shareholder-related information may include (but is not necessarily
limited to) account balances, account numbers, transactions, investment selections, information
regarding broker/dealers, social security numbers, addresses, telephone numbers and
beneficiaries, as well as the mere fact that someone has or previously had an account with the
Company. Similarly, you may not download or copy any such shareholder-related information
contained in documents or files that are maintained electronically, other than for proper business
purposes. No shareholder-related information, whether maintained in hard-copy, electronic or
any other format, may be shared with any outside party, or with any individual within the
Company who has not previously been authorized to access it, without prior written
authorization from the appropriate member of Company management. Further, if you are
authorized to disseminate any shareholder-related information electronically, you must use a
secure method, such as by secure mail, secure FTP, or encrypted email.

3. Legal and Other Privileged Matters: During the course of your employment, Company
attorneys or outside counsel retained by the Company may require your assistance or
participation in handling legal matters on the Company’s behalf. Please bear in mind that all
such conversations, as well as all documents, emails and other materials related to any legal
matter, are confidential Company property and are not to be disclosed to anyone without specific
authorization from the Company attorney(s) involved.

Requests by regulatory or legal authorities for information (other than what is provided in routine
filings) must be cleared through the Legal Department. Requests by members of the press, other
individuals or entities with which the Company does business or any other third party for
information relating to Company must be cleared through the Corporate Communications
Department.

C. Removal and/or Copying of Company Materials

During the course of your employment with the Company, you are likely to work with or create
various documents, files and other materials. The Company regards all documents, files or other
materials created by or at the direction of Company employees or agents in connection with their
work for the Company (collectively and individually, “Company materials”) as Company
property. Employees are strictly prohibited from removing any originals or copies of Company
materials from the Company’s premises or systems, unless (1) such copying or removal is
carried out for proper business purposes and in a manner consistent with all other provisions of
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the Company’s Code of Conduct, Corporate Technology Resources Policy and any other
applicable policies, laws and regulations or (2) the employee has obtained the prior written
consent of the Company’s Chief Compliance Officer to copy and/or remove the specific
Company materials at issue.

The prohibition against copying and/or removing Company materials applies to taking such
actions by any method (e.g., making hard copies, downloading files, emailing data, etc.).
“Company materials” include, but are not necessarily limited to, any materials created, in whole
or in part, by or at the direction of any Company employee or agent in connection with any
aspect of the Company’s business or operations, regardless of whether such materials are
maintained in hardcopy, electronic, digital or any other format. You should understand that the
term “Company materials” includes materials created solely by you. This means, for example,
that you are strictly prohibited from taking samples of documents that you authored in
connection with your work for the Company for use in your future work at another company.

Both Company policy and various laws and regulations prohibit you from copying or removing
Company materials. Thus, violation of these provisions could result in not only Company
disciplinary actions, but also civil and/or criminal penalties.

D. Use of Company Property

The Company provides employees access to its property, including all of its physical property
and its technological systems, to help employees carry out their job-related functions. You
should use such Company property primarily for business purposes. You may not use or permit
others to use Company property in any way that facilitates the violation of any federal, state or
local law or regulation or the violation of any Company policy. The unauthorized removal of,
damage to, or destruction of Company property, as well as that of other employees or associates
of the Company, is strictly prohibited. Employees are required to return all Company property to
their manager or their Human Resources Department representative immediately at the time that
their employment with the Company terminates, as further described in the Company’s
Employee Handbook or pursuant to any other applicable Company policies or procedures.
Employees should understand that Company documents, records and information (whether
maintained in hardcopy, electronic or any other form) also constitute “Company property,” and
that your use of such materials is governed by this Section II. C, as well as the provisions of
Section II. B (”Confidentiality”) set forth above.

Specific guidelines governing the use of certain Company property and systems are set forth in
separate Company policies that are provided to all employees and/or posted on OPnet. Examples
of such policies include, but are not limited to, the Company e-mail system, Internet access and
OPnet. Access to such systems are provided to employees to assist them in their job-related
functions, and employees are expected to use them primarily for business-related purposes.
Company policy strictly prohibits the use of such systems in any manner that contravenes any
Company policy (for example, among others, its EEO, Anti-Discrimination and Anti-Harassment
Policy or its Insider Trading Policy) or any Federal, state or local law, rule or regulation.
Employees should not routinely engage in the excessive use of Company systems or equipment
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(including, but not limited to, computers, Internet access, email and telephones) for purposes not
related to Company business.

E. Preparation of Time Records and Reports for Reimbursement

You are expected to report honestly and document accurately all requests for reimbursement of
business expenses that you have properly incurred while conducting business on behalf of the
Company and for reimbursement from petty cash for any such expenses. Those of you who are
eligible for overtime pay are expected (1) to report honestly and accurately the number of regular
and overtime hours you work each day and (2) to prepare and/or review personally any time
reports that are to be submitted on your behalf. Altering time records to falsify the record of
hours worked or submitting requests for reimbursement of expenses not incurred or not properly
incurred in conducting business on behalf of the Company may subject an employee to
disciplinary action, up to and including termination of employment.

F. Company-Sponsored Benefits Programs

The Company may offer employees various benefits and privileges in connection with their
employment – examples of which may include, but are not limited to, the opportunity to take
paid and unpaid time-off pursuant to the Company’s leave of absence and salary continuance
policies, the opportunity to invest in the Company’s Capital Accumulation Plan, the opportunity
to obtain medical and dental coverage, etc. Employees are required to act honestly with respect
to all matters relating to their application for and receipt of such benefits and to use their best
efforts to insure that all information that they may be asked to provide in connection with any
such benefits is accurate and truthful. Falsification of any materials or information provided to
the Company, any entity that it has engaged to administer any of its benefits programs or any
government body is strictly prohibited, regardless of whether the Company has offered the
benefits or programs at issue voluntarily or in accordance with any legal requirements.

G. Gifts and Entertainment

You face potential conflicts of interest whenever you give or receive gifts or entertainment
associated with conducting business on behalf of the Company.

You or members of your immediate family may not give or receive gifts of significant value,
lavish entertainment, or any other valuable considerations as an employee of the Company.

Please refer to the OFI Gift Policy for specific guidance and reporting obligations on this matter.
Employees associated with OFDI should also refer to the OFDI Cash and Non-Cash
Compensation Policy.

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 H. Bribes and Preferential Treatment

You may not accept, offer or give any bribes, kickbacks, or preferential treatment in the course
of your business-related dealings with any person or organization for any reason whatsoever.
Further, if you are the object of an attempted bribe, kickback, or preferential treatment
arrangement, you must immediately report such activity to senior management or the Legal
Department.

III. Others Matters Relating to Employee Conduct while on

Company Premises or in the Course of Company-Related Activities

Employees are expected to conduct themselves professionally at all times that they are on
Company premises or in the course of Company-related activities, or any time that they may be
deemed to be holding themselves out as Company representative, and to treat anyone with whom
they may come into contact in the course of their work with the Company in a respectful manner
and in a manner consistent with all applicable laws, rules and regulations. The following
sections address some additional matters relating to employee conduct in further detail.

A. Service to and Regard for Others

Employees are expected to treat investors, brokers, dealers, vendors, suppliers and other
employees with respect and consideration. The Company demands courteous service for the
investors in its managed mutual funds, and each of you should constantly bear in mind that we
are a service organization. Your actions as an employee do have an effect on the service we
provide and on the Company’s image as a financial institution, whether or not you are in daily
direct contact with our investors and brokers/dealers.

The Company also strives to provide a safe and comfortable working environment for all
employees. To this end, physical violence in the workplace or on the job will not be tolerated.
Furthermore, as set forth in the Company’s Equal Employment, Anti-Discrimination and Anti-
Harassment Policies, the Company strictly prohibits employees from discriminating against or
harassing any other employees or business associates on the basis of any legally protected
classification, and it further prohibits them from retaliating against any individual who complains
about such discrimination or harassment. You should be sensitive to the fact that comments or
actions that may seem funny or innocuous to you may offend, embarrass or humiliate others.
Potentially offensive statements or acts -- for example, ethnic jokes or slurs, remarks about an
individual’s age, or the access of obscene websites in the workplace -- may constitute illegal
discrimination or harassment, and, in any event, have no place on the job. Employees who
witness any potentially discriminatory or harassing behavior should promptly discuss the matter
with their managers or the Human Resources Department. And employees who believe that they
are victims of any such behavior are reminded that they should promptly notify the appropriate
Human Resources Department representative or Company manager.

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 B. Controlled Substances

Because the use of controlled substances (including but not limited to illegal drugs,
cannabis/marijuana and alcohol) is known to effect work performance adversely, a workplace
free of such substances is vital to our business, the health and productivity of our employees and
the quality of our services. The use of such controlled substances in the workplace or during
business-related activities is generally inconsistent with the behavior expected of employees and
may violate federal and state laws, as well as the regulations applicable to our industry.

For these reasons, the sale, manufacture, distribution, dispensation, possession or use of
controlled substances, including cannabis/marijuana, on Company premises or while engaged in
Company-related activities is strictly prohibited, unless (in the case of alcohol) otherwise
approved by management. Being under the influence of illegal drugs, alcohol, or other
controlled substances while performing Company business, or while in a Company facility or
vehicle, is also strictly prohibited, as such conduct may affect the employee’s job performance,
the safety of coworkers or the general public, and the safe and efficient operation of our
business. And, in any event, the Company cannot accept responsibility for any employee’s
actions when he or she is under the influence of any controlled substances.

Additionally, each employee is under an affirmative duty to notify the Company of any criminal
drug statute conviction for a violation occurring in the workplace no later than five (5) days after
such conviction.

Compliance with this controlled substances policy is a condition of your employment with the
Company.

Violations of this policy may result in disciplinary action, up to and including termination.

Any employees who are observed or suspected to be under the influence of controlled substances
or to have a substance abuse problem should be reported to the Human Resource Department.
Such employees may be referred for an immediate drug/alcohol screening test. Refusal to
submit to a drug/alcohol screening test when requested in accordance with this policy may result
in disciplinary action, up to and including termination of employment.

The Company urges any employees who are concerned that they may have a substance abuse
problem to take advantage of the Company’s Employee Assistance Program, which can direct
you to available drug counseling and/or rehabilitation programs.

C. Visitors

Non-business visitors may be a distraction to other employees. For this reason, as well as for
safety and security concerns, employees are asked to greet guests in the reception area and not to
take visitors into any department without the prior approval of their supervisors. All employees
should adhere to these visitor-control guidelines, bearing in mind that they apply to all non-
business visitors -- including, but not limited to, children and former employees. While the
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Company may, from time to time, designate certain days upon which employees may bring
children to work, (provided that they comply with any relevant Company-prescribed guidelines),
employees are expected to refrain from bringing children into the office at any other time.

Business visitors will be asked to sign in at the reception area and should then either be greeted
at reception by the employee with whom they are visiting or escorted to that individual by
another employee of the Company.

Vendors are not permitted to solicit on Company premises unless they have been given prior
permission by the Company to do so.

D. Recording of Meetings and Conferences

Business-related meetings -- including, but not limited to, formal and informal meetings,
conferences, conversations and discussions, whether in-person, over the telephone, by video-
conference or otherwise -- are essential to the efficient and successful operation of the Company.
Participants in such meetings must be able to share information and opinions freely and frankly,
without concern that sensitive or confidential information may be improperly disclosed. The
guidelines regarding the use of confidential information outlined above extend to sensitive
matters discussed during such meetings, as well as to any written notes that you or others may
take during them. Moreover, you may never electronically record any business-related meeting,
conference, conversation or discussion that is held between and among any Company
manager(s), employee(s), and/or business associate(s) without first obtaining the written
permission of your manager or the Legal Department. This prohibition of unauthorized
recordings extends to any form of electronic recordings, including, but not limited to, audio
and/or video recordings. You also should not permit, encourage or help individuals who are not
parties to a business-related meeting to hear, view or otherwise partake in that meeting without
first disclosing their presence to all of the other participants. And, if you have reason to believe
that any or all of the other participants in a meeting may not be aware that another individual is
listening and/or observing the proceedings, you should disclose that individual’s identity to all of
the other participants immediately.

E. Political Contributions

The Company generally will not contribute, directly or indirectly, corporate cash, goods, or
services to any political party, committee or candidate at any level of government. However, the
Company may organize political action committees from time to time for voluntary contribution
by employees. The Company does not prevent its employees from participating in political
activities of their choice, on their own time. Such individual voluntary activities may not be
conducted on the Company’s premises, nor may individual employees distribute political
literature or solicit votes for particular candidates, causes or parties on Company premises.
Please note that the preceding prohibitions on individual conduct do not apply to Company-
organized or Company-sponsored initiatives. From time to time, the Company may prohibit
certain employees and officers from making certain political contributions and/or may require
them to pre-clear such contributions with the Compliance Department. The Compliance
12
For Internal Use Only
This policy may not be shared with, nor circulated to, any non-employee of OppenheimerFunds and its affiliates and
subsidiaries without permission from the Compliance or Legal Department.
Department typically notifies affected employees of such prohibitions and preclearance
requirements.

F. Solicitations

Employees should not engage in solicitation for any entity, interest or cause (e.g., charitable, for-
profit, religious, or political) on the Company’s premises. This policy applies to all forms of
solicitations by one or more individual employees, including, but not limited to, in-person
solicitations and those conducted through the Company’s e-mail, telephone and voicemail
systems. From time to time, however, the Company may sponsor events to benefit various
charitable or other interests, and employees may participate in such Company-sponsored events
and initiatives. Such Company-sponsored events and initiatives are not subject to the
prohibitions set forth in the first two sentences of this section.

IV. Violations

Any employees who compromise or violate any of the laws to which the Company is subject, or
the standards contained in this Code or in any other Company policy, may be subject, at the
Company’s sole discretion, to disciplinary action, up to and including termination of
employment. Such employees may also be subject to criminal or civil proceedings under the
applicable law(s).

Approved by OFI Global’s Legal Department and Compliance Department on January 8, 2013
Approved by OFI Global’s Human Resources Department on January 14, 2013

13
For Internal Use Only
This policy may not be shared with, nor circulated to, any non-employee of OppenheimerFunds and its affiliates and
subsidiaries without permission from the Compliance or Legal Department.