This Voya Financial Complaint Process for Accounting and Auditing Matters (“Complaint Process”) has been approved and adopted by the boards of the U.S. domiciled insurance companies which are members of the Voya family of companies (“Voya Companies”). The Voya Companies have a commitment to engage in and promote honest and ethical conduct and to produce full, fair, complete, accurate, timely and understandable financial disclosure. As a demonstration of this commitment, the Voya Companies have adopted this Complaint Process.

External parties who have complaints about accounting or auditing matters should call the Voya Ethics Helpline at (844) 418-7604. The ethics helpline is maintained by Voya’s Chief Compliance and Ethics Officer; detailed instructions for how to access the ethics helpline are provided in Voya’s Code of Conduct.

Corporate Special Investigations will investigate each complaint about an accounting or auditing matter and report to Voya’s Chief Compliance and Ethics Officer whether the complaint was unfounded or supported by fact, a minor or major complaint, and whether the complained of problem has been corrected or needs further remediation.

Voya’s Chief Compliance and Ethics Officer will keep a log of external complaints about accounting and auditing matters and investigative findings and will prepare a Quarterly Accounting and Auditing Complaint Report for the boards of the Voya Companies which states (i) the total number of external complaints received in the prior quarter and (ii) the facts of any substantiated complaint and the nature of the remedial action proposed or taken.

Any major external complaint about an accounting or auditing matter (one which poses a risk of significant reputational or economic loss to Voya, its shareholders or customers, or a material violation of the securities laws) will be promptly reported by Voya’s Chief Compliance and Ethics Officer to the boards of directors.