EX-99.p.1
CODE
OF ETHICS (PERSONAL TRADING)
Rule
17j-1(b) under the Investment Company Act of 1940, as amended (the “1940 Act”), makes it unlawful for any affiliated person,
officer or Board member of the Funds in connection with the purchase or sale by such person of a Security (as defined below) “held
or to be acquired” by the Funds:
| 1. | To
employ any device, scheme or artifice to defraud the Funds; |
| 2. | To
make to the Funds any untrue statement of a material fact or omit to state to the Funds a
material fact necessary in order to make the statement made, in light of the circumstances
under which they are made, not misleading; |
| 3. | To
engage in any act, practice, or course of business which operates or would operate as a fraud
or deceit upon the Funds; or |
| 4. | To
engage in any manipulative practice with respect to the Funds’ investment portfolios. |
| II. | Purpose
of the Code of Ethics |
The
Funds expect that the officers and Fund Board members will conduct their personal investment activities in accordance with (1) the duty
at all times to place the interests of the Funds’ shareholders first; (2) the requirement that all personal Securities transactions
be conducted consistent with this Code of Ethics and in such a manner as to avoid any actual or potential conflict of interest or any
abuse of an individual’s position of trust and responsibility; and (3) the fundamental standard that investment company personnel
should not take inappropriate advantage of their positions.
In
view of the foregoing, the provisions of Section 17(j) of the 1940 Act, Rule 17j-1 under the 1940 Act, and various pronouncements by
the Securities and Exchange Commission (“SEC”) and the Investment Company Institute on personal investing by investment company
personnel, 1 the Funds have adopted this Code of Ethics to specify a code of conduct for certain types of personal Securities
transactions that might involve conflicts of interest or an appearance of impropriety, and to establish reporting requirements and enforcement
procedures. This Code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific
provisions will not shield Fund personnel from liability for personal trading or other conduct that violates a fiduciary duty to Fund
shareholders.
This
Code of Ethics does not apply to any officer, Board member or employee of the Funds who is also an Access Person or Investment Personnel
(as defined under Rule 17j-1 under the 1940 Act) employed by the Funds’ investment adviser, investment sub-advisers or principal
underwriter (“Excluded Advisory Personnel”). Those individuals are covered by the Codes of Ethics that have been adopted
by their respective entities and approved by the Board of each of the Funds in accordance with the provisions of Rule 17j-1 of the 1940
Act.
| 1 | See
Investment Adviser Code of Ethics, SEC Release No. IC-26492 (July 9, 2004); Personal Investment
Activities of Investment Company Personnel, SEC Release No. IC-23958 (August 24, 1999); Personal
Investment Activities of Investment Company Personnel, Report by the Securities and Exchange
Commission (September 1994); and Report of the Advisory Group on Personal Investing, Investment
Company Institute (May 9, 1994). |
| A. | “Access
Person” means (1) each Board member or officer of the Funds; and (2) any Advisory
Person of the Funds except Excluded Advisory Personnel. |
| B. | “Advisory
Person” means (1) each Board member, officer, general partner or employee of
the Funds (or of any company in a control relationship to the Funds) who in connection with
his or her regular functions or duties, makes, participates in, or obtains information regarding
the purchase or sale of a Reportable Security (as defined below) by the Funds or whose functions
relate to the making of any recommendations with respect to such purchases or sales; and
(2) any natural person in a control relationship to the Funds who obtains information concerning
recommendations made to the Funds with regard to the purchase or sale of a Reportable Security
by the Funds. |
| C. | “Automatic
Investment Plan” means a program in which regular periodic purchases (or withdrawals)
are made automatically in (or from) investment accounts in accordance with a predetermined
schedule and allocation. An Automatic Investment Plan includes a dividend reinvestment plan. |
| D. | “Beneficial
Ownership” shall be interpreted in the same manner as it would be in determining
whether a person is considered a “beneficial owner” as defined in Rule 16a-1(a)(2)
under the Securities Exchange Act of 1934, as amended (“1934 Act”), which generally
speaking, encompasses those situations where the beneficial owner has the right to enjoy
some economic benefit from the ownership of the Reportable Security. You will be treated
as a “beneficial owner” of a Security under this Code only if you have a direct
or indirect pecuniary interest in the Security. A direct pecuniary interest is the opportunity,
directly or indirectly, to profit, or to share the profit, from the transaction. An indirect
pecuniary interest is any nondirect financial interest, but is specifically defined in the
rules to include, among other things, Securities held by members of your immediate family
sharing the same household; Securities held by a partnership of which you are a general partner;
Securities held by a trust of which you are the settlor if you can revoke the trust without
the consent of another person, or a beneficiary if you have or share investment control with
the trustee; and equity Securities which may be acquired upon exercise of an option or other
right, or through conversion. For interpretive guidance on this test, you should consult
your counsel. A person is normally regarded as the beneficial owner of Reportable Securities
held in the name of his or her spouse or minor children and adults living in his or her household. |
| E. | “Control”
shall have the same meaning as set forth in Section 2(a)(9) of the 1940 Act. Generally, control
is the power to exercise a controlling influence over the management or policies of a company
unless such power is solely the result of an official position with such company. |
| F. | “Exempt
Transactions” means: (1) purchases or sales effected in any account over which
an Access Person or Investment Personnel has no direct or indirect influence or control;
(2) purchases or sales which are non-volitional2 on the part of the Access Person,
Investment Personnel or the Funds; (3) purchases which are part of an Automatic Investment
Plan; or (4) purchases effected upon the exercise of rights issued by an issuer pro-rata
to all holders of a class of its Reportable Securities, to the extent such rights were acquired
from such issuer, and sales of such rights so acquired. |
| 2 | Non-volitional
purchases or sales include those transactions, which do not involve a willing act or conscious
decision on the part of the Board Member, officer or employee. For example, shares received
or disposed of by Access Persons or Investment Personnel in a merger, recapitalization or
similar transaction are considered non-volitional. |
| G. | A
Security is “held or to be acquired” if within the most recent
15 days it (1) is or has been held by the Funds, (2) is being or has been considered by the
Funds or the investment adviser or investment sub-adviser for purchase by the Funds or (3)
any option to purchase or sell and any Security convertible into or exchangeable for a Reportable
Security that is described in (1) or (2) of this definition. |
| H. | An
Access Person’s “immediate family” means a spouse, minor
children and adults living in the same household as the Access Person. |
| I. | “Independent
Board Member” means each Board member who is not an “interested person”
of the Funds (as defined in Section 2(a)(19) of the 1940 Act) and who would be required to
make a report under Section V of this Code solely by reason of being a Board member of the
Funds. |
| J. | An
“Initial Public Offering” means an offering of Securities registered
under the Securities Act of 1933, the issuer of which, immediately before the registration,
was not subject to the reporting requirements of Sections 13 or 15(d) of the 1934 Act. |
| K. | “Investment
Personnel” of the Funds means (1) any employee of the Funds (or of any company
in a control relationship to the Funds) who, in connection with his or her regular functions
or duties, makes or participates in making recommendations regarding the purchase or sale
of Securities by the Funds or (2) any natural person who controls the Funds and who obtains
information concerning recommendations made to the Funds regarding the purchase or sale of
Securities by the Funds. |
| L. | A
“Limited Offering” means an offering that is exempt from registration
under the Securities Act of 1933 pursuant to Section 4(2) or Section 4(6) or pursuant to
Rule 504, Rule 505, or Rule 506 under the Securities Act of 1933. |
| M. | “Purchase
or sale of a Reportable Security” includes, among other things, the writing
of an option to purchase or sell a Reportable Security. |
| N. | “Reportable
Security” means a Security excluding (1) direct obligations of the Government
of the United States; (2) banker’s acceptances; (3) bank certificates of deposit; (4)
commercial paper; (5) high quality short-term debt instruments (any instrument having a maturity
at issuance of less than 366 days and that is rated in one of the two highest rating categories
by a nationally recognized statistical rating organization), including repurchase agreements;
and (6) shares of registered open-end investment companies other than those advised by an
Aberdeen Adviser. |
| | Access
Persons or Investment Personnel in a merger, recapitalization or similar transaction are
considered non-volitional. |
| | O. | “Security”
means a security as defined in Section 2(a)(36)of the 1940 Act which is defined as any note,
stock, treasury stock, security future, bond, debenture, evidence of indebtedness, certificate
of interest or participation in any profit-sharing agreement, collateral-trust certificate,
preorganization certificate or subscription, transferable share, investment contract, voting-trust
certificate, certificate of deposit for a security, fractional undivided interest in oil,
gas, or other mineral rights, any put, call, straddle, option, or privilege on any security
(including a certificate of deposit) or on any group or index of securities (including any
interest therein or based on the value thereof), or any put, call, straddle, option, or privilege
entered into on a national securities exchange relating to foreign currency, or, in general,
any interest or instrument commonly known as a “security,” or any certificate
of interest or participation in, temporary or interim certificate for, receipt for, guarantee
of, or warrant or right to subscribe to or purchase, any of the foregoing. |
| IV. | Policies
of the Funds Regarding Personal Securities Transactions |
No
Access Person of the Funds shall engage in any act, practice or course of business that would violate the provisions of Rule 17j-1(b)
set forth above, or in connection with any personal investment activity, engage in conduct inconsistent with this Code of Ethics.
| 1. | Restrictions
on Personal Securities Transactions by Independent Board Members |
| | | |
| | | The
Funds recognize that an Independent Board Member does not have on-going, day-to-day interaction
with the operations of the Funds. In addition, it has been the practice of the Funds to give
information about Securities purchased or sold by the Funds or considered for purchase or
sale by the Funds to Independent Board Members in materials circulated more than 15 days
after such Securities are purchased or sold by the Funds or are considered for purchase or
sale by the Funds. Accordingly, the Funds believe the following controls are appropriate
for Independent Board Members: |
| a. | Personal
Account Dealing in Fund Shares. |
| i. | Independent
Board Members are prohibited from buying or selling any Aberdeen-advised U.S. Registered
Fund (closed-end, open-end, and ETFs) shares during the two week period prior to or following
Board meetings of which they are aware. |
| ii. | Independent
Board Members are required to pre-clear with the Fund CCO or his/her designee all Aberdeen-advised
U.S. Registered Fund buys or sells including funds for which an Independent Board Member
does not serve as a director/trustee. |
| iii. | The
Fund CCO may waive this prohibition in exceptional circumstances and upon a determination
that the transaction does not violate any applicable laws or regulations. The Fund CCO will
document any such waivers. |
| b. | Limited
Pre-clearance. The Securities pre-clearance requirement contained in IV.B.2. below shall
only apply to an Independent Board Member if he or she knew that during the fifteen day period
before the proposed transaction in a Reportable Security (other than Exempt Transactions)
or at the time of the transaction that the Reportable Security to be purchased or sold by
him or her (other than Exempt Transactions) was also purchased or sold by the Fund(s) or
considered for the purchase or sale by the Fund(s) (i) for which such Independent Board Member
acts as a Director or Trustee or (ii) any Aberdeen-advised U.S. Registered Fund (closed-end,
open-end, and ETFs).3 |
| c. | Pre-clearance
Not Granted. When the securities pre-clearance requirement applies to an Independent Board
Member, no clearance will be given to the Independent Board Member to purchase or sell any
Reportable Security (1) on a day when any Fund has a pending “buy” or “sell”
order in that same Reportable Security until that order is executed or withdrawn or (2) when
the Funds’ Chief Compliance Officer has been advised by the Funds’ investment
adviser or investment sub-adviser that the same Reportable Security is being considered for
purchase or sale for any Fund. |
| 2. | Restrictions
on Initial Public Offering or Limited Offering Personal Securities Transactions by Access
Persons Who Are Not Independent Board Members |
| a. | Pre-clearance.
An Access Person who is not an Independent Board Member is prohibited from buying or selling
any Security through an Initial Public Offering or a Limited Offering for his or her personal
portfolio or the portfolio of a member of his or her immediate family without obtaining (i)
email or other written authorization or (ii) oral authorization from a Funds Chief Compliance
Officer prior to effecting such Reportable Security transaction. |
| | | |
| | | A
written authorization for such Security transaction will be provided by the Funds’
Chief Compliance Officer or his/her delegate to the person receiving the oral authorization
(if granted). The written authorization will also be provided to the Funds’ administrator
to memorialize the email and oral authorization that was granted. |
| | | |
| | | Note:
If an Access Person has questions as to whether purchasing or selling a Reportable Security
for his or her personal portfolio or the portfolio of a member of his or her immediate family
requires prior oral authorization, the Access Person should consult the Funds’ Chief
Compliance Officer for clearance or denial of clearance to trade prior to effecting any Reportable
Securities transition. |
| 3 | Because
monitoring the publication of the portfolio holdings of series of abrdn ETFs and abrdn Funds
that operate as ETFs is not construed to be within the ordinary course of fulfilling the
duties of a board member, the publication or availability of such portfolio holdings shall
not be construed to impart actual or constructive knowledge of such series’ portfolio
transactions on an Independent Board Member. |
| b. | Pre-clearance
Expiration. Pre-clearance approval will expire at the close of business on the trading day
after the date on which written or oral authorization is received, and the Access Person
is required to renew clearance for the transaction if the trade is not completed before the
authority expires. |
| c. | Pre-clearance
Not Granted. No pre-clearance will be given to purchase or sell any Reportable Security (1)
on a day when any Fund has a pending “buy” or “sell” order in that
same Reportable Security until that order is executed or withdrawn or (2) when the Funds’
Chief Compliance Officer has been advised by the Funds’ investment adviser or investment
sub-adviser that the same Reportable Security is being considered for purchase or sale for
any Fund. |
| 3. | Additional
Restrictions on Investment Personnel |
| a. | Gifts.
No investment personnel shall receive any gift or other thing of more than de minimis
value from any person or entity that does business with or on behalf of the Funds. |
| b. | Board
Service. Investment Personnel shall not serve on the boards of directors of publicly traded
companies absent prior authorization by the Funds’ Chief Compliance Officer. |
| V. | Procedures
– Initial Holdings Reports, Annual Holdings Reports and Quarterly Transaction Reports |
| A. | In
order to provide the Funds with information to enable it to determine with reasonable assurance
whether the provisions of this Code of Ethics are being observed by its Access Persons: |
| 1. | Independent
Board Members |
| a. | Holdings
Reports Not Required – Each Independent Board Member need not make initial or annual
holdings reports. |
| b. | Limited
Quarterly Transaction Reporting – An Independent Board Member must submit the same
quarterly transaction report as required under paragraph V.A.2.d below to the Chief Compliance
Officer of the Funds, but only for a transaction in a Reportable Security where he or she
knew at the time of the transaction or, in the ordinary course of fulfilling his or her official
duties as an Independent Board Member, should have known that during the 15-day period immediately
preceding or after the date of the transaction, such Reportable Security is or was purchased
or sold, or considered by the Funds, its investment adviser or investment sub-adviser for
purchase or sale by the Fund (i) for which such Independent Board Member acts as a Director
or Trustee or (ii) any Aberdeen-advised U.S. Registered Fund (closed-end, open-end, and ETFs). |
| 2. | Access
Persons Who Are Not Independent Board Members |
| a. | Initial
Holdings Reports – Each Access Person who is not an Independent Board Member will submit
to the Chief Compliance Officer or his/her designee of the Funds an Initial Holdings Report
in the form attached hereto as Exhibit A that lists all Reportable Securities in which
the Access Person has Beneficial Ownership. |
| (i) | The
Initial Holdings Report must be submitted within ten days of becoming an Access Person and
must contain information current as of a date no more than 45 days prior to becoming an Access
Person. |
| (ii) | The
Initial Holdings Report must include the title of each Reportable Security, the number of
shares held (for equity securities), the principal amount (for debt securities) of each Reportable
Security, the date the report is submitted as well as a list of any Securities accounts maintained
with any broker, dealer or bank in which any Securities were held for the direct or indirect
benefit of the Access Person as of the date the person became an Access Person of the Funds. |
| (iii) | An
Access Person need not include in the report transactions effected for, and Reportable Securities
held in, any account over which the Access Person has no direct or indirect influence or
control. |
| (iv) | The
report may contain a statement that the report shall not be construed as an admission by
the person making such report that he or she has any direct or indirect beneficial ownership
in the Reportable Security to which the report relates. |
| b. | Annual
Holdings Reports – Each Access Person of the Funds who is not an Independent Board
Member will also submit to the Chief Compliance Officer or his/her designee of the Funds
an Annual Holdings Report attached hereto as Exhibit A no later than 30 days after
the end of the calendar year. |
| (i) | The
information contained in the Annual Holdings Report must be current as of a date no more
than 45 days before the report is submitted. |
| (ii) | The
Annual Holdings Report must list all Reportable Securities in which the Access Person has
Beneficial Ownership, the title of each Reportable Security, the number of shares held (for
equity securities), the principal amount (for debt securities) of the Reportable Security,
and the date the report is submitted. The Report must also list any Securities accounts maintained
with any broker, dealer or bank in which any Securities were held for the direct or indirect
benefit of the Access Person. |
| (iii) | An
Access Person need not include in the report transactions effected for, and Reportable Securities
held in, any account over which the Access Person has no direct or indirect influence or
control. |
| (iv) | The
report may contain a statement that the report shall not be construed as an admission by
the person making such report that he or she has any direct or indirect beneficial ownership
in the Reportable Security to which the report relates. |
| c. | Securities
Confirmations – Each Access Person of the Funds who is not an Independent Board Member
shall direct his or her broker to supply to a Chief Compliance Officer or his/her designee
of the Funds, on a timely basis, duplicate copies of confirmation of all personal Securities
transactions and copies of periodic statements for all Securities accounts in which the Access
Person has Beneficial Ownership. |
| d. | Quarterly
Transaction Reports – Each Access Person of the Funds who is not an Independent Board
Member shall submit reports in the form attached hereto as Exhibit B to the Chief
Compliance Officer or his/her designee of the Funds, showing all transactions in Reportable
Securities in which the person has, or by reason of such transaction acquires, any direct
or indirect Beneficial Ownership, as well as all accounts established with brokers, dealers
or banks during the quarter in which any Securities were held for the direct or indirect
beneficial interest of the Access Person. |
| (i) | Quarterly
transaction reports shall be filed no later than 30 days after the end of each calendar quarter. |
| (ii) | The
report shall include (a) the date of the transaction, (b) the title of the Reportable Security,
(c) the interest rate and maturity date (if applicable), (d) the number of shares (for equity
securities), (e) the principal amount of each Reportable Security involved; (f) the nature
of the transaction (i.e., purchase, sale or any other type of acquisition or disposition),
(g) the price at which the transaction was effected, (h) the name of the broker, dealer or
bank with or through whom the transaction was effected; and (i) the date the report is submitted.
In addition, with respect to any account established by the Access Person in which any Reportable
Securities were held during the quarter for the direct or indirect benefit of the Access
Person, the Access Person shall report the following information: (a) the name and address
of the broker, dealer or bank with whom the Access Person established the account; (b) the
date the account was established; and (c) the date the report is submitted. |
| (iii) | An
Access Person of the Funds need not make a quarterly transaction report with respect to (a)
transactions effected pursuant to an Automatic Investment Plan, (b) a transaction if all
of the information required by paragraph (ii) above is contained in the brokerage confirmations
or account statements required to be submitted under paragraph (c) above, and (c) transactions
effected for, and Reportable Securities held in, any account over which the Access Person
has no direct or indirect influence or control. |
| (iv) | The
report may contain a statement that the report shall not be construed as an admission by
the person making such report that he or she has any direct or indirect beneficial ownership
in the Reportable Security to which the report relates. |
| 3. | Identification
of Access Persons – The Chief Compliance Officer or his/her designee of the Funds
shall notify each Access Person of the Funds who may be subject to the pre-clearance requirement
or required to make reports pursuant to this Code of Ethics that such person is subject to
the pre-clearance or reporting requirements and shall deliver a copy of this Code of Ethics
to each such person. |
| 4. | Compliance
Review – The Chief Compliance Officer or his/her designee of the Funds shall (i)
with regard to any Access Persons or Investment Personnel reporting directly under this Code
of Ethics, review any initial holdings reports, annual holdings reports, and quarterly transaction
reports that are received by the Chief Compliance Officer or his/her designee under this
Code of Ethics, and as appropriate compare the reports with the pre-clearance authorization
received; (ii) with regard to any Excluded Advisory Personnel reporting under a Code of Ethics
of the Funds’ investment adviser, sub-advisers or principal underwriter, quarterly
contact the compliance officer of such investment adviser, sub-advisers or principal underwriter
regarding the compliance of such Access Persons or Investment Personnel with their Code of
Ethics and (iii) report to the Funds’ Board: (a) with respect to any transaction that
appears to evidence a violation of this Code or the investment adviser’s, sub-advisers’
or principal underwriter’s Codes of Ethics; and (b) violations of the reporting requirement
stated in such Codes of Ethics. |
| 5. | Board
Review – The Board shall review the operation of this Code of Ethics at least once
a year. |
| 6. | Service
Provider Code of Ethics – The investment adviser, any investment sub-advisers and
the principal underwriter shall adopt, maintain and enforce a separate code of ethics with
respect to their personnel in compliance with Rule 17j-1 of the 1940 Act and Rule 204A-1
of the Investment Advisers Act of 1940, as applicable. Any material changes to the investment
adviser’s, investment sub-adviser’s or principal underwriter’s code will
be approved by the Board no later than six months after such change. |
| 7. | Board
Reporting – At each quarterly Board meeting, the Chief Compliance Officer of the
Funds’ investment adviser, any investment sub-adviser and the principal underwriter
of the Funds shall provide a written report to the Funds’ Board stating: |
| a. | any
reported Securities transaction that occurred during the prior quarter that materially violated
(either individually or in the aggregate) the provisions of the code of ethics adopted by
the investment adviser, any investment sub-adviser or principal underwriter; and |
| b. | all
disciplinary actions4 taken in response to such violations. |
| 8. | Annual
Reports – At least once a year, the Funds’ Chief Compliance Officer shall
provide to the Board a written report that contains any previously reported material violations
of the code or procedures and sanctions imposed in response to material violations, any recommended
changes in the code or procedures, and a certification that the procedures which have been
adopted are those reasonably necessary to prevent Access Persons (as defined under Rule 17j-1)
from violating their respective Codes of Ethics. The written report will also include an
assessment of the effectiveness of the Service Providers’ Codes of Ethics outlined
in Section 6 above. |
| 9. | Recordkeeping
– This Code, the codes of the investment adviser, any investment sub-adviser and
principal underwriter, a copy of each report by an Access Person, any record of any violation
of this Code of Ethics and any action taken as a result thereof, any written report hereunder
by the Chief Compliance Officer of the investment adviser, investment sub-adviser or the
principal underwriter, records of approvals relating to Initial Public Offerings and Limited
Offerings, lists of all persons required to make reports and a list of all persons responsible
for reviewing such reports shall be preserved with the Funds’ records for the period
required by Rule 17j-1 of the 1940 Act. |
Each
Access Person, including an Independent Board Member, will be required to certify annually that he or she has read and understood this
Code of Ethics, and will abide by it. Each Access Person, including an Independent Board Member, will further certify that he or she
has disclosed or reported all personal Securities transactions required to be disclosed or reported under the Code of Ethics. Certification
of compliance with the Code of Ethics by an Independent Board Member will occur annually.
| 4 | Disciplinary
action includes but is not limited to any action that has a material financial effect upon
the employee, such as fining, suspending, or demoting the employee, imposing a substantial
fine or requiring the disgorgement of profits. |
Code
of Ethics
Exhibit
A
HOLDINGS
REPORT
| For
the Year/Period Ended |
|
|
| |
(Month/day/year) |
|
[ ]
Check here if this is an Initial Holdings Report
| To: |
|
,
as the Chief Compliance Officer of [Name of Aberdeen Fund] |
As
of the calendar year/period referred to above, I have a direct or indirect beneficial ownership interest in the Securities listed below
which are required to be reported pursuant to the Code of Ethics of the Funds.
| Title
of Security |
Number
of Shares |
Principal
Amount |
| |
|
|
| |
|
|
| |
|
|
The
name and address of any broker, dealer or bank with whom I maintain an account in which my Securities are held for my direct or indirect
benefit are as follows.
For
Initial Holdings Reports: This report contains information current as of a date no more than 45 days prior to the date of becoming an
Access Person.
For
Annual Holdings Reports: This report contains information current as of a date no more than 45 days before the report is submitted.
This
report (i) excludes transactions with respect to which I had no direct or indirect influence or control, (ii) excludes other transactions
not required to be reported and (iii) is not an admission that I have or had any direct or indirect beneficial ownership in the Securities
listed above.
Code
of Ethics
Exhibit
B
QUARTERLY
SECURITIES TRANSACTION REPORT
| For
the Calendar Quarter Ended |
|
|
| |
(month/day/year) |
|
| To: |
|
,
Chief Compliance Officer |
During
the quarter referred to above, the following transactions were effected in Securities of which I had, or by reason of such transaction
acquired, direct or indirect beneficial ownership, and which are required to be reported pursuant to the Code of Ethics of the Funds:
| Security |
Date
of Transaction |
Number
of Shares |
Principal
Amount |
Interest
Rate and Maturity Rate (if applicable) |
Nature
of Transaction (Purchase, Sale, or Other) |
Price |
Broker/Dealer
or Bank Though Whom Effected |
| |
|
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|
|
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| |
|
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| |
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During
the quarter referred to above, I established the following accounts in which Securities were held during the quarter for my direct or
indirect benefit:
Name
and address of the broker, dealer or bank
with
which I established the account. |
The
date the account was established. |
| |
|
| |
|
| |
|
This
report (i) excludes transactions with respect to which I had no direct or indirect influence or control, (ii) excludes other transactions
not required to be reported, and (iii) is not an admission that I have or had any direct or indirect beneficial ownership in the Securities
listed above.