Common use of REPRESENTATIONS OF SUB-ADVISER Clause in Contracts

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser represents, warrants, and agrees as follows: A. The Sub-adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, the Advisers Act, the SEC, the FCA or other applicable law or regulation from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Act, and if it has not already done so, will provide the Adviser and each Fund with a copy of such code of ethics and its compliance policies and procedures, together with evidence of its adoption. C. Upon request, the Sub-adviser will provide the Adviser and each Fund with a copy of its Form ADV as most recently filed with the SEC and any amendments thereto.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each the Fund with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each the Fund with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser represents, warrants, and agrees as follows: A. The Sub-adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, the Advisers Act, the SEC, the FCA or other applicable law or regulation from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federalUnited States, state or foreign law United Kingdom requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Adviser and each the Fund with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the Sub-adviser will provide the Adviser and each the Fund with a copy of its Form ADV as most recently filed with the SEC and any amendments thereto.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser represents, warrants, and agrees as follows: A. The Sub-adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, the Advisers Act, the SEC, the FCA SEC or other applicable law or regulation from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Act, and and, if it has not already done so, will provide the Adviser and each Fund with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the Sub-adviser will provide the Adviser and each Fund with a copy of its Form ADV as most recently filed with the SEC and any amendments thereto.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each Fund Transamerica IDEX with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each Fund Transamerica IDEX with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each Fund IDEX with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each Fund IDEX with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviserAdviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agencyorganization, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Adviser and each Fund the Company with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Adviser and each Fund the Company with a complete copy of its Form ADV as most recently filed with the SEC and any amendments theretohereafter will furnish a copy of its annual amendment to the Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Adviser and each Fund the Company with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Adviser and each Fund the Company with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser represents, warrants, and agrees as follows: A. The Sub-adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA FSA and various other non-U.S. regulatory agencies, and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, the Advisers Act, the SEC, the FCA FSA or other applicable law or regulation from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federalUnited States, state or foreign law United Kingdom requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Adviser and each the Fund with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the Sub-adviser will provide the Adviser and each the Fund with a copy of its Form ADV as most recently filed with the SEC and any amendments thereto.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviserAdviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agencyorganization, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Adviser and each Fund the Company with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Adviser and each Fund the Company with a copy of its Form ADV as most recently filed with the SEC and any amendments theretohereafter will furnish a copy of its annual amendment to the Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will seek to continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately promptly notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each the Fund with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each the Fund with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviserAdviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Adviser and each Fund the Company with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Adviser and each Fund the Company with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; Agreement (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Adviser and each the Fund with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Adviser and each the Fund with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each Fund Trust with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each Fund Trust with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretomaterial amendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each Fund Transamerica IDEX with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each Fund Transamerica IDEX with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretomaterial amendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviserAdviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agencyorganization, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Adviser and each Fund the Company with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Adviser and each Fund the Company with a copy of its Form ADV as most recently filed with the SEC and any amendments theretohereafter will furnish a copy of its annual amendment to the Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviserAdviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will use its best efforts to continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agencyorganization, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Adviser and each Fund the Company with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Adviser and each Fund the Company with a copy of its Form ADV as most recently filed with the SEC and any amendments theretohereafter will furnish a copy of its annual amendment to the Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each Fund ATSF with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each Fund ATSF with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviserAdviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, Cayman Islands and U.S. federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each the Fund with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each the Fund with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each Fund Transamerica IDEX with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each Fund Transamerica IDEX with a copy of its Form ADV as most recently filed with the SEC and will, within a reasonable time after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser in connection with its annual contract renewal.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with has provided the requirements of Rule 206(4)-7 under the Advisers Act, and if it has not already done so, will provide the Investment Adviser and each Fund IDEX with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each Fund IDEX with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviserAdviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each Fund the Trust with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each Fund the Trust with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviserAdviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each Fund IDEX with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each Fund IDEX with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agencyorganization, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Adviser and each Fund the Company with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Adviser and each Fund the Company with a complete copy of its Form ADV as most recently filed with the SEC and any amendments theretohereafter will furnish a copy of its annual amendment to the Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each Fund ATSF with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption.its C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each Fund ATSF with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviserAdviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Adviser and each Fund the Trust with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Adviser and each Fund the Trust with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each Fund IDEX with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each Fund IDEX with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretomaterial amendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser represents, warrants, and agrees as follows: A. The Sub-adviser: adviser (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser has adopted a written code of ethics (the “Sub-adviser Code”) complying with the requirements of Rule 17j-1 17j-l under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Act, and if it as may be amended from time to time, and, has not already done so, will provide provided the Adviser and each Fund the Company with a copy of such code of ethics and its compliance policies and proceduresthe Sub-adviser Code, together with evidence of its adoption. C. Upon request, the . The Sub-adviser will provide the Adviser and each Fund with a copy of its Form ADV as most recently filed with the SEC and any amendments thereto.certifies that it has adopted procedures reasonably necessary to prevent

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; Agreement (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Adviser and each Fund the Company with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Adviser and each Fund the Company with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each Fund ATST with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each Fund ATST with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretoamendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.

REPRESENTATIONS OF SUB-ADVISER. The Sub-adviser Adviser represents, warrants, and agrees as follows: A. The Sub-adviser: Adviser: (i) is registered with the SEC as an investment adviser under the Advisers Act, and is registered or licensed with the FCA and various other non-U.S. regulatory agencies, Act and will continue to be so registered or licensed for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act, Act or the Advisers Act, the SEC, the FCA or other applicable law or regulation Act from performing the services contemplated by this Agreement; (iii) has met, and will continue to meet for so long as this Agreement remains in effect, any other applicable federal, federal or state or foreign law requirements, or the applicable requirements of any regulatory or industry self-regulatory agency, necessary to be met in order to perform the services contemplated by this Agreement; (iv) has the authority to enter into and perform the services contemplated by this Agreement; and (v) will immediately notify the Investment Adviser of the occurrence of any event that would disqualify the Sub-adviser Adviser from serving as an investment adviser of an investment company pursuant to Section 9(a9 (a) of the 1940 Act or otherwise. B. The Sub-adviser Adviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and a compliance program complying with the requirements of Rule 206(4)-7 under the Advisers Actand, and if it has not already done so, will provide the Investment Adviser and each Fund ATSF with a copy of such code of ethics and its compliance policies and proceduresethics, together with evidence of its adoption. C. Upon request, the The Sub-adviser will provide Adviser has provided the Investment Adviser and each Fund ATSF with a copy of its Form ADV as most recently filed with the SEC and will, promptly after filing any amendments theretomaterial amendment to its Form ADV with the SEC, furnish a copy of such amendment to the Investment Adviser.