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The purpose of this Code is to help to ensure that the Independent Directors (“Directors”) of each Company place the interests of the Company and its shareholders ahead of the Directors’ own personal interests. The terms the “Companies”, the “Company”, and the “Advisers” will each have the meaning ascribed to them in the Rule 38a-1 Compliance Manual. The term “Independent Director” refers to the directors or trustees of the respective Company’s board who are not “interested persons” (as defined in Section 2(a)(19) of the Investment Company Act of 1940, as amended) of the Company.

Rule 17j-1 under the Investment Company Act of 1940 (“Rule 17j-1”) makes it unlawful for any affiliated person of the Company, or any affiliated person of an investment adviser for the Company, in connection with the purchase or sale, directly or indirectly, by the person of a security held or to be acquired by the Company, to (i) employ any device, scheme or artifice to defraud the Company or its shareholders; (ii) make any untrue statement of a material fact to the Company or its shareholders or omit to state to the Company or its shareholders a material fact necessary in order to make the statements made, in light of the circumstances under which they are made, not misleading; (iii) engage in any act, practice or course of business that operates or would operate as a fraud or deceit upon the Company or its shareholders; or (iv) engage in any manipulative practice with respect to the Company or its shareholders.

The securities industry is highly regulated and its participants are expected to adhere to high standards of behavior, including in their personal trading. A violation of the Code can have an adverse effect on you, your fellow Directors, the Advisers, and Nuveen, LLC and its affiliates (“Nuveen”), as well as the Companies and their shareholders. The Code does not address every ethical issue that might arise.

It is important for Directors to be sensitive to investments that may compromise your independence, directly or indirectly. The Code applies to appearance as well as substance. Always consider how any action might appear to an outside observer such as a regulator. If you have any doubt after consulting the Code, contact the Nuveen Legal Department.

For purposes of this Policy, the obligations and requirements for Directors also apply to the Directors’ Household Members (as defined herein) as well as any account for which the Director or Household Member has Beneficial Ownership (also as defined herein).

1.Beneficial Ownership: Any interest by which you or any Household Member – directly or indirectly – derives a monetary benefit from purchasing, selling, or owning a security or account, or exercises investment discretion. You have Beneficial Ownership of securities held in accounts in your own name, or any Household Member’s name, and in all other accounts over which you or any Household Member exercise or may exercise investment decision-making powers, or other influence or control, including trust, partnership, estate, and corporate accounts or other joint ownership or pooling arrangements.

3.Household Member: Any of the following who reside, or are expected to reside for at least 90 days a year, in the same household as a Director: Spouse or Domestic Partner, Sibling, Child, Stepchild, Grandchild, Parent, Stepparent, Grandparent, In-laws (mother, father, son, daughter, brother, sister).

4.Inside Information: Inside information is information that is both material and non-public. Information is material if: (1) a reasonable investor would likely consider it important when making an investment decision; and (2) public release of the information would likely affect the price of a security. Information is non-public if it has not been distributed through a widely used public medium such as a press release or a report, filing or other periodic communication.

C.Do not purchase or sell any securities if you know at the time of the proposed transaction that the Company has purchased or sold the same securities within the past 15 days, or is considering purchasing or selling the same securities within the next 15 days. This is the “15 day window.”

D.Avoid conflicts of interest. This applies not only to actual conflicts of interest, but also to any situation that might appear to an outside observer to be improper or a breach of fiduciary duty.

i.Seek prior approval before purchasing or selling shares of the Company via e-mail to BDC-Transaction@nuveen.com (the “BDC Transaction Mailbox”). The Company’s Chief Compliance Officer (the “CCO”) and/or the Nuveen Legal Department will review the pre-clearance request and respond with approval or disapproval of the request.

C.Comply with the Company’s Section 16 Policy: Section 16 of the Securities Exchange Act of 1934 imposes reporting requirements on purchases and sales of shares of the Company by Directors and prohibits Directors from profiting on sales (purchases) of such shares purchased (sold) within the preceding six months. The Company has adopted a separate Section 16 Policy to ensure compliance with these requirements.

B.Exceptions: The Code exists to ensure that Directors place the interests of the Company and its shareholders ahead of Directors’ own personal interests. No exceptions that would violate that principle will be granted.

C.Reporting and Enforcement: The CCO will alert the Audit Committee of any known potential violations of this Code. The Audit Committee shall determine whether a violation of the Code occurred and what remedial action is appropriate for any such violation.

I acknowledge receipt of the Joint Independent Director Code of Ethics (the “Code of Ethics”). I have read and understand the Code of Ethics and agree to be governed by it at all times. Further, if I have been subject to the Code of Ethics during the preceding year, I certify that I have complied with the requirements of the Code of Ethics and have disclosed or reported all personal securities transactions required to be disclosed or reported pursuant to the requirements of the Code of Ethics.