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Accordingly, Putnam employees should not engage in any lobbying activities without approval from the Legal and Compliance Department.B. Reference to the CFA Institute, the CFA designation, and the CFA Program.As part of their evaluation of the proposed management contracts, the Independent Trustees also reviewed the general approach taken by Putnam Management and the Independent Trustees in recent years in imposing appropriate limits on total fund expenses.D) Distributions to shareholders Income dividends are recorded daily by the fund and are paid monthly.You can use this information to compare the ongoing expenses (but not transaction expenses or total costs) of investing in the fund with those of other funds.A and B buy shares of the companies being acquired before the public announcement of the acquisition, and regularly profit from such purchases.

It is mandatory that all Access Persons file a quarterly transaction report in the PTA online system.The Independent Trustees did not view this change as having a material impact on shareholders of any fund.The Code of Ethics Oversight Committee is responsible for setting sanctions policies for violating the Code.International Style (architecture) - Wikipedia,. Online casino invites everyone to test the most popular slot machines. (LOC image) Louis Sullivan.This Rule does not prohibit an employee from tendering securities from his personal account in response to any and all tender offers, even if Putnam clients are also tendering securities.This Rule is designed to prohibit any employee from trading a security while Putnam may have inside information concerning that security or the issuer.Get the iPhone App. Portugalproperty.com for iPhone - all you need to find your dream property.

An employee may seek an ad hoc exemption under this Rule by following the procedures in Section VI.Krichmar, the Principal Financial Officer of the Funds listed on Attachment A, certify that, to my knowledge.

Curtis served as a member of the Trustee Advisory Council of the Applied Physics Laboratory, Johns Hopkins University.Putnam employees must disclose their brokerage accounts in the PTA system and complete all required information, which will facilitate the instructions to the broker.They also noted that applying various projections of growth equally to the aggregate net assets of the Fund Family and to the net assets of individual funds also showed revenue reductions for Putnam Management.Access Persons must disclose their personal securities holdings in the Code of Ethics monitoring system, PTA, upon commencement of employment (within ten days of hire) and thereafter on an annual basis.The policy with respect to employee trading in Putnam closed-end funds is attached as Appendix B.The decision whether or not to grant the pre-clearance request is in the sole discretion of the Code of Ethics Officer and the Deputy Code of Ethics Officer.

Retirement, pension, deferred compensation, and similar accounts that cannot be legally transferred to Putnam are not subject to the requirement.Code of Ethics Administrator The individual designated by the Code of Ethics Officer to assume responsibility for day-to-day, nondiscretionary administration of this Policy Statement.In the case of a portfolio manager, prior written approval of the proposed sale shall be obtained from a Chief Investment Officer to whom he reports or, in his absence, another Chief Investment Officer.Investors, however, should prepare for the possibility of this rapid ascent leveling off in coming quarters. The U.S. economy is improving, but headwinds remain.Putnam employees are strongly discouraged from engaging in writing (selling) naked options for their personal accounts.The Trustees were also mindful that many other leading firms in the industry had also been experiencing significant challenges due to the changing financial and competitive environment.

F. The Rule does not prohibit employees on business travel from using local transportation and arrangements customarily supplied by brokers or similar entities.Employees of PIL should contact the London Code of Ethics Administrator.

The Independent Trustees noted that Putnam Management proposed the addition of performance adjustments only for certain of the funds (performance adjustments were not proposed for your fund) and considered whether similar adjustments might be appropriate for other funds.While the Contract Committee noted the likelihood that the Trustees and Putnam Management would reach agreement on the strategic pricing matters in later months, the terms of the management contracts required that the Trustees approve the continuance of the contracts in order to prevent their expiration at June 30, 2009.ELEMENTS CASINO IN SURREY, BC. Elements Casino is home to the best gaming, entertainment, and dining options in Surrey. Feel the excitement as you hit the gaming.

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CFA Program, Members and Candidates must not misrepresent or exaggerate the meaning or implications of membership in the CFA Institute, holding the CFA designation, or candidacy in the CFA Program.Investment holdings in public companies that are not material to the employee are excluded from this prohibition.Thus, a portfolio manager or analyst who front runs a Putnam client purchase or sale of obligations of the U.S. government is in violation of this Rule. U.S. government obligations are excluded from the definition of security.

The fund pays Putnam Management for management and investment advisory services quarterly based on the average net assets of the fund.

Information is non-public until it has been effectively communicated to, and sufficient opportunity has existed for it to be absorbed by, the marketplace.All employees must follow and abide by the spirit of the Code of Ethics and the Standards of Professional Conduct of the CFA Institute.Securities and performance of a fund and an index will differ.

No employee may create, alter, or destroy (or participate in the creation, alteration, or destruction of) any record that is intended to mislead anyone or to conceal anything that is, or is reasonably believed to be, improper.As a result of such limitation, the expenses of the fund reflect a reduction of the following amounts (Note 2).Prior to February 1998, he was Executive Vice President and Director of Acquisitions of Cabot Partners Limited Partnership (a registered investment adviser involved in institutional real estate investments).Jonathan has been in the investment industry since he joined Putnam in 1990.

Net asset value (NAV) is the price, or value, of one share of a mutual fund, without a sales charge.Note, however, that the purchase or sale of securities obtained through the exercise of options must be pre-cleared.Drucker is Chair of the Board of Trustees of Commonfund (a not-for-profit firm managing assets for educational endowments and foundations), Vice Chair of the Board of Trustees of Sarah Lawrence College, and a member of the Investment Committee of the Kresge Foundation (a charitable trust).In those cases, the service providers enter into confidentiality agreements.Narrow-based derivative A future, swap, put or call option, or similar derivative instrument whose return is determined by reference to fewer than 25 underlying issuers.Employees may request an exception by submitting a written request to the Code of Ethics Officer.He is a member of the Chief Executives Club of Boston, the National Innovation Initiative, and the Council on Competitiveness.This information included trends in revenues, expenses and profitability of Putnam Management and its affiliates relating to the investment management and distribution services provided to the funds.Title: Spy Magazine July-August 1988, Author: Josh Gillette, Name: Spy Magazine July-August 1988, Length: 164 pages, Page: 1, Published: 2014-06-30. Issuu company logo.

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