<PAGE> 1
EXHIBIT (p)(v)
PFPC DISTRIBUTORS, INC.
CODE OF CONDUCT
NOVEMBER 1, 2000
This Code of Conduct has been adopted by the Firm's Board of Directors for the
purpose of avoiding and preventing certain actions constituting conflicts of
interest with the investment activities of a Fund or Funds for which the Firm
acts as distributor. This Code of Conduct applies to all officers, directors,
employees or associated persons of the Firm. The terms and conditions of this
Code shall supersede those of the PFPC Worldwide, Inc. Code of Conduct (the
"PFPC Code") to the extent that any term or condition of this Code is
inconsistent with the PFPC Code.
I. DEFINITIONS
The following definitions shall apply herein:
1. "Access Person" shall mean any Firm director or officer who, in the
ordinary course of business, makes, participates in or obtains information
regarding the purchase or sale of Covered Securities by a Fund for which the
Firm acts as distributor, or whose functions or duties as part of the ordinary
course of his or her business relate to the making of any recommendation to such
Fund regarding the purchase or sale of Covered Securities. An individual shall
be considered as Access Person only with respect to the Fund to which the
foregoing definition applies. A list of the current Access Persons is attached
to this Code as Appendix A.
2. "Beneficial Ownership" shall be interpreted in the same manner as it
would be in determining whether a person is subject to the provisions of Section
16 of the Securities Exchange Act of 1934 and the rules and regulations
thereunder. Application of this definition is explained in more detail in
Appendix B hereto.
3. "Code" shall mean this Code of Conduct.
4. "Covered Security" (in the plural, "Covered Securities") shall mean
any security or securities referred to in Section 2(a)(36) of the Investment
Company Act of 1940 (the "1940 Act") (including any option, contract, warrant or
exercisable right to purchase or sell any security) with the following
exceptions: direct obligations issued or guaranteed by the United States;
short-term securities issued or guaranteed by an agency or instrumentality of
the United States; commercial paper; bankers' acceptances; bank certificates of
deposit; commercial paper and high quality short-term debt instruments,
including repurchase agreements; shares of open-end registered investment
companies; and any other securities excepted by Rule 17j-1 under the 1940 Act.
5. "Firm" shall mean PFPC Distributors, Inc.
6. "Designated Person" shall mean any person designated by the Firm to
be authorized to take actions to carry out policies and procedures set forth in
the Code. As of the date of this Code, the President and Chief Compliance
Officer for the Firm has been named the Designated Persons.
7. "Employee" (in the plural, "Employees") shall mean each person
registered as a representative of the Firm with the National Association of
Securities Dealers, Inc.
8. "Fund" (in the plural, "Funds") shall mean any registered investment
company or investment portfolio for which the Firm acts as distributor.
9. "Material Information" shall mean information (i) which can
reasonably be expected to have a material impact on the financial condition or
operations of a Firm or (ii) which an investor would consider important in
determining whether to buy or sell securities of an issuer.
<PAGE> 2
10. "Personal Account" shall mean any account used for the purchase and
sale of securities in which an Employee has a direct or indirect Beneficial
Ownership.
11. "Purchase or Sale of a Covered Security" includes, among other
things, the writing of an option to purchase or sell a Covered Security.
12. "Security Held or to be Acquired by the Fund" shall mean any
Covered Security, which, within the most recent 15 days: (a) is being held by
the Fund; or (b) is being or has been considered by the Fund or its investment
adviser for purchase by the Fund, and any option to purchase or sell, and any
security convertible into or exchangeable for, a Covered Security.
II. REPORTING REQUIREMENTS
A. Initial Holdings Reports
No later than 10 days after a person becomes an Access Person, every
Access Person must file with the Chief Compliance Officer an initial holdings
report which shall set forth the following information:
(a) the title, number of shares and principal amount of each Covered
Security in which the Access Person had any direct or indirect beneficial
ownership when the person became an Access Person;
(b) the name of any broker, dealer or bank with whom the Access Person
maintained an account 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; and
(c) the date that the report is submitted by the Access Person.
A sample of the form of report is attached to this Code as Appendix C.
B. Quarterly Transaction Reports
Every Access Person must file with the Chief Compliance Officer not
later than 10 days after the end of each calendar quarter a confidential
personal securities transaction report for such quarter setting forth for every
transaction in a Covered Security in the Access Person's Personal Account the
following information:
(a) the date of the transaction, the title, the interest rate and
maturity date (if applicable), the number of shares and the principal amount of
each Covered Security involved;
(b) the nature of the transaction (i.e., purchase, sale, or any other
type of acquisition or disposition including gifts, exercise of conversion
rights, exercise or sale of subscription rights, reinvestment of dividends and
receipt of stock splits or stock dividends);
(c) the price at which the transaction was effected;
(d) the name of the broker, dealer, bank, other corporation, or person
with or through whom the transaction was effected; and
(e) the date the report is submitted by the Access Person.
A sample of the form of report is attached to this Code as Appendix D.
An Access Person need not make a quarterly transaction report if the
report would duplicate information contained in the broker trade confirmations
or account statements received by the Firm with
<PAGE> 3
respect to the Access Person, if all of the information required is contained in
the broker trade confirmations or accounts statements or the records of the
Firm.
C. Annual Holdings Reports
Annually every Access Person must file with the Chief Compliance
Officer a confidential personal securities transaction report (which must be
current as of a date no more than 30 days before the report is submitted)
setting forth for every transaction in a Covered Security in the Access Person's
Personal Account the following information:
(a) the title, number of shares and principal amount of each Covered
Security in which the Access person had an direct or indirect beneficial
ownership;
(b) the name of any broker, dealer or bank with whom the Access Person
maintains an account in which any securities are held for the direct or indirect
benefit of the Access Person; and
(c) the date the report is submitted by the Access Person.
A sample of the form of report is attached to this Code as Appendix E.
D. Statement Regarding Beneficial Ownership
Any such report may contain a statement to the effect that such report
shall not be construed as an admission by the reporting person as to any direct
or indirect beneficial ownership of the Security or Securities to which the
report relates.
E. Exception to Reporting Requirements
No Access Person shall be required to make the foregoing report where
the Firm (i) is not an affiliated person of any Fund or any investment adviser
of any Fund and (ii) has no officers, directors or general partners who serve as
officers, directors or general partners of such Fund or any such investment
adviser. As of the date of this Code, the foregoing exception to reporting
applies to all Access Persons. The Designated Supervisory Person shall notify
all Access Persons immediately in the event that the exception to the reporting
requirement is no longer applicable.
III. RESTRICTIONS ON PERSONAL SECURITIES TRANSACTIONS BY EMPLOYEES
A. Unlawful Actions
It is unlawful for any Employee, Firm director or Firm officer, in
connection with the purchase or sale, directly or indirectly, by the person of a
Security Held or to be Acquired by the Fund:
(a) to employ any device scheme or artifice to defraud the Fund;
(b) to make any untrue statement of a material fact to the Fund or to
omit to state a material fact necessary in order to make the statements made to
the Fund, in light of the circumstances in which they are made, not misleading;
(c) to engage in any act, practice or course of business that operates
or would operate as a fraud or deceit on the Fund; or
(d) to engage in any manipulative practice with respect to the Fund.
B. Trading Restrictions During Certain Periods
<PAGE> 4
No Employee, Firm director or Firm officer may, directly or indirectly,
purchase or sell a Covered Security for his or her Personal Account if such
individual knows or, in the ordinary course of fulfilling his or her duties as
an Employee, Firm director or Firm officer, should know that (i) a purchase or
sale of such Covered Security by a Fund is being considered by the Fund or its
investment adviser, or (ii) during the five (5) business day period immediately
preceding the date of the transaction in a Covered Security by the Employee,
Firm director or Firm officer, such Security was purchased or sold by a Fund.
C. Trading Restrictions While in Possession of Non-Public Material
Information
No Employee, Firm director or Firm officer may, directly or indirectly,
purchase or sell a Covered Security for his or her Personal Account while such
individual possesses non-public Material Information relating to that Covered
Security or its issuer. The most common examples of information that is
"non-public" are: (i) information that has neither been published by any news
agency nor filed with the Securities and Exchange Commission as part of a
publicly available filing and (ii) information that has been discussed only
within the confines of a board meeting.
D. Violations
Any Employee, Firm officer or Firm director who has violated Sections
III(A), (B) or (C) of the Code or who knows of such a violation by another
Employee, Firm director or Firm officer shall immediately notify the Designated
Person, in writing, of such violation.
E. General
Apart from the specific restrictions set forth in Sections II and III
of the Code, purchases and sales should be arranged in such a way as to avoid
transactions contrary to the intent of this Code. Any attempt by an Employee,
Firm director or Firm officer to do indirectly what this Code is meant to
prohibit will be deemed a direct violation hereof. If there is any doubt whether
your transactions may be in conflict with the intent of this Code you should
check before buying or selling with the Designated Person.
F. Registered Investment Adviser Employees
Certain associated persons of the Firm may also be employees of a
registered investment adviser and, accordingly, subject to codes of conduct,
including restrictions on personal securities transactions, more stringent than
those set forth in this Code. The Firm will rely on the registered investment
advisers to enforce their codes of conduct.
G. Sanctions
If the Designated Person determines that a violation of the Code has
occurred, she shall so advise the Firm's Board of Directors for referral to the
Executive Management Committee of PFPC Worldwide, Inc., the parent of the Firm
(the "Committee"). The Committee may impose such sanctions as it deems
appropriate, including, inter alia, a letter of censure or suspension or
termination of the employment of the violator. In any event, (i) any Employee,
Firm director or Firm officer who violates Section III(A) or (B) of the Code
shall be subject to disciplinary action which may include termination of
registration with the Firm and (ii) any profit realized from a securities
transaction that violates Section III(A) or (B) of the Code shall be disgorged
as directed by the Committee.
IV. ANNUAL CERTIFICATION
On an annual basis, each Employee, Firm director and Firm officer shall
certify in writing that such individual has read and understands the Code and
has complied with all of its provisions during the preceding year in which the
Code was in effect. The annual certification is attached to the Code. (Upon
employment, each employee will receive the Code and sign an initial
"Certification of Receipt.")
<PAGE> 5
V. MISCELLANEOUS
A. Administration of the Code
1. The Firm shall use reasonable diligence and institute procedures
reasonably necessary to prevent violations of this Code.
2. No less frequently than annually, the Firm shall furnish to the
Fund's board of directors a written report that
(a) describes any issues arising under the Code since the last
report to the board of directors, including, but not limited to, information
about material violations of the Code and sanctions imposed in response to
material violations; and
(b) certifies that the Firm has adopted procedures reasonably
necessary to prevent Access Persons from violating the Code.
B. Records
1. The Firm shall maintain records in the manner and to the extent set
forth below, which records may be maintained in any manner described in Rule
31a-2(f)(1) under the 1940 Act, as follows:
(a) a copy of the Code and any other code which is, or at any
time within the past five years has been in effect, shall be preserved in an
easily accessible place;
(b) a record of any violation of the Code, and of any action
taken as a result of such violation, shall be preserved in an easily accessible
place for a period of not less than five years following the end of the fiscal
year in which the violation occurs;
(c) a copy of each certification made by an Employee, Firm
director or Firm officer pursuant to the Code (including any information
provided in lieu of reports under Section II(B) of the Code) shall be preserved
for a period of not less than five years from the end of the fiscal year in
which it is made, for the first two years in an easily accessible place;
(d) a record of all persons, currently or within the last five
years, who are or were required to make reports under Section II of the Code, or
who are or were responsible for reviewing these reports, shall be preserved in
an easily accessible place; and
(e) a copy of each report required by Section V(A)(2) shall be
maintained for at least five years after the end of the fiscal year in which it
is made, the first two years in an easily accessible place.
2. The Firm shall make such records available for examination at the
Firm headquarters by representatives of the Securities and Exchange Commission
at such time as said representatives may reasonably request.
3. Except as may be required pursuant to Section III(E) and Section V
(A)(2) of the Code, all reports and any other information of a personal nature
shall be treated as confidential by the Designated Supervisory Person.
C. Interpretation of Code
The Designated Person in consultation with the Firm's Chief Legal
Officer shall determine how the provisions of the Code shall be interpreted, and
may from time to time establish administrative procedures to assist in carrying
out the intent of the Code.
<PAGE> 6
APPENDIX A
LIST OF ACCESS PERSONS
<TABLE>
<CAPTION>
NAME TITLE ACCESS PERSON?
---- ----- --------------
<S> <C> <C>
Robert Crouse Director No*
Gary Gardner Director, President & Chief No*
Executive Officer
Joseph Gramlich Chairman No*
Francis Koudelka Director, Vice President No*
Rita Adler Vice President, Chief Compliance No*
Officer, Assistant Secretary and
Assistant Clerk
Christine Ritch Chief Legal Officer, Secretary & No*
Clerk
Craig Stokarski Treasurer No*
Bradley Stearns Assistant Secretary & Assistant No*
Clerk
Doug Castagna Controller & Assistant Treasurer No*
</TABLE>
*Not an Access Person because (1) such person does not in the ordinary course of
his/her business make, participate in or obtain information regarding the
purchase or sale of securities for a Fund; and (2) such person's duties as part
of the ordinary course of his/her business do not relate to the making of any
recommendation to such Fund regarding the purchase or sale of securities.
<PAGE> 7
APPENDIX B
This Code of Conduct relates to the purchase or sale of securities of which a
person has a direct or indirect "beneficial ownership" except for purchases or
sales in accounts over which the person has no direct or indirect influence or
control as described below.
BENEFICIAL OWNERSHIP
"Beneficial ownership" means that one directly or indirectly, by written or
unwritten understanding, has a (or shares a direct or indirect) financial
interest regardless of who is the owner of record. Financial interest means the
opportunity, directly or indirectly, to participate in the risks and rewards of
a transaction. Securities owned by a person or by a trust of which one has a
beneficial ownership or a similar arrangement include, but are not limited to:
(1) Securities owned by your spouse, your minor children and relatives of you
and your spouse who live in your home, including trusts of which such persons
are beneficiaries (other than interests in a trust over which neither you nor
such person has any direct or indirect influence or control over investments);
(2) A proportionate interest in securities held by a partnership of which you
are a general partner;
(3) Securities in which you have a right to dividends that is separated or
separable from the underlying securities;
(4) Securities that you have a right to acquire through the exercise or
conversion of another security, whether or not presently exercisable; and
(5) Securities held in accounts from which you receive a performance related fee
based on less than one year's performance.
You do not have a financial interest in securities held by a corporation of
which you are not a controlling shareholder and do not have or share investment
control over its portfolio.
NO INFLUENCE OR CONTROL
The Code does not apply to purchases and sales of securities effected in any
account over which you do not have "any direct or indirect influence or
control". However, this "no direct or indirect influence or control" exception
is limited to few situations. The principal one is that described in paragraph
(1) above, where securities are held in a trust, in which you have a beneficial
interest, but where you are not the Trustee and have no control or influence
over the Trustee.
<PAGE> 8
APPENDIX C
INITIAL HOLDINGS REPORTS
To: PFPC Distributors, Inc.
Chief Compliance Officer
From: Date Became Access Person:
--------------------------- ------------- ----
Employee Name
In accordance with the PFPC Distributors, Inc. Code of Conduct
governing personal securities transactions to which I am subject, I have
attached to this form copies of the most recent statements for each and every
Personal Account and Related Account, including Fully Discretionary Accounts,
that holds or is likely to hold a Security or Futures Contract in which I have a
Beneficial Ownership interest, as well as copies of confirmations for any and
all transactions subsequent to the effective dates of those statements.
In addition, I hereby supply the following information for each and
every Personal Account and Related Account in which I have a Beneficial
Ownership interest for which I CANNOT supply the most recent account statement:
(1) The person in whose name the
account is held (if different from mine):
------------------------------
The relationship of that person to me:
------------------------------
(2) Name of the firm (e.g. securities broker-
dealer or futures commission merchant)
at which the account is maintained:
----------------------------------------
Address of that firm:
-------------------------------
-------------------------------
The account number at that firm:
-------------------------------
(3) Name of the representative responsible
for that account:
-------------------------------------
His or her telephone number:
-------------------------------
NOTE: This Report must be submitted to Compliance within 5 days of being
designated a fund officer / access person.
<PAGE> 9
(4) Account holdings:
<TABLE>
<CAPTION>
Identity of Security Or Cusip Quantity Value Valuation
Futures Contract ----- -------- ----- Date
---------------- ----
<S> <C> <C> <C> <C>
(a)
-------------------- --------- -------- ------ ---------
(b)
-------------------- --------- -------- ------ ---------
(c)
-------------------- --------- -------- ------ ---------
(d)
-------------------- --------- -------- ------ ---------
</TABLE>
I also supply the following information for each and every Security or
Futures Contract in which I have a Beneficial Ownership interest, to the extent
this information is not available elsewhere on this form or from the statements
and confirmations attached to this form:
<TABLE>
<CAPTION>
Person Who Description
Owns the Security of the Security Valuation
Or Futures Contract Or Futures Contract Cusip Quantity Value Date Custodian
------------------- ------------------- ----- -------- ----- ---- ---------
<S> <C> <C> <C> <C> <C> <C>
(a)
------------- --------------- ------- ------- ----- -------- ---------------
(b)
------------- --------------- ------- ------- ----- -------- ---------------
(c)
------------- --------------- ------- ------- ----- -------- ---------------
(d)
------------- --------------- ------- ------- ----- -------- ---------------
</TABLE>
(Attach additional sheets if necessary)
I hereby certify that this form and the documents attached hereto (if any)
identify all of the Securities and Futures Contracts in which I have a
Beneficial Ownership interest as of this date.
Date:
----------------------------- ------------------------------------
Print Name
---------------------------------- ------------------------------------
Dept. Number and Location Signature
NOTE: This Report must be submitted to Compliance within 5 days of being
designated a fund officer / access person.
<PAGE> 10
TO: ALL EMPLOYEES WHO ARE ACCESS PERSONS OF PFPC DISTRIBUTORS, INC.
RE: PERSONAL SECURITIES TRANSACTION REPORT
EFFECTIVE IMMEDIATELY, PLEASE COMPLETE THIS FORM AND RETURN WITHIN 5 DAYS AFTER
THE END OF THE CALENDAR QUARTER TO PFPC DISTRIBUTORS, INC. COMPLIANCE
DEPARTMENT, MAIL STOP W3-F400-01-9
NOTE: FAILURE TO SUBMIT YOUR REPORT WITHIN THE REQUIRED TIMEFRAME WILL BE
CONSIDERED A BREACH OF PFPC DISTRIBUTORS, INC.'S CODE OF CONDUCT AND MAY BE
REPORTABLE TO THE BOARD OF DIRECTORS. INCLUDE IN THIS REPORT ANY TRANSACTION IN
ANY SECURITY IN WHICH YOU HAVE, OR WILL HAVE AS A RESULT OF THE TRANSACTION, ANY
DIRECT OR INDIRECT BENEFICIAL OWNERSHIP IN THE SECURITY.
<TABLE>
<CAPTION>
-----------------------------------------------------------------------------------------------------------------------------------
ISSUE NAME,
DATE NATURE OF CUSIP CLASS OF STOCK, PRINCIPAL NUMBER PRICE AT BROKER/DEALER
OF TRANSACTION NUMBER INTEREST RATE, AMOUNT OF WHICH BANK/THROUGH
TRANSACTION (PURCHASE, SALE FOR EACH MATURITY DATE OF EACH UNITS OR TRANSACTION WHOM
OTHER) SECURITY (IF APPLICABLE) SECURITY SHARES WAS EFFECTED EFFECTED
===================================================================================================================================
<S> <C> <C> <C> <C> <C> <C> <C>
-----------------------------------------------------------------------------------------------------------------------------------
</TABLE>
INCLUDE IN THIS REPORT: ALL PERSONAL SECURITIES TRANSACTIONS INCLUDING OPTIONS,
WARRANTS AND FUTURES CONTRACTS
EXCLUDE IN THIS REPORT: SECURITIES ISSUED BY THE U.S. GOVERNMENT AND ITS
AGENCIES, MONEY MARKET INSTRUMENTS, OPTIONS AND FUTURES ON U.S. GOVERNMENTS AND
MONEY MARKET INSTRUMENTS, SHARES OF A REGISTERED OPEN-END INVESTMENT COMPANY,
DIVIDEND REINVESTMENT PLANS, PURCHASES IN PNC STOCK PURCHASE PLAN AND, PNC BANK
CORP.'S INCENTIVE SAVINGS PLAN
<TABLE>
<CAPTION>
===================================================================================================================================
TO: EMPLOYEES WHO SERVE AS OFFICERS OF FUNDS, PLEASE LIST: FUND NAME OFFICER TITLE
--------- -------------
<S> <C> <C> <C>
===================================================================================================================================
PERSONAL SECURITIES TRANSACTIONS REPORT
FOR ----------------------------- -------------
THE CALENDAR QUARTER ENDED PRINT NAME DEPT #
--------------------------------
(MONTH/DATE/YEAR)
SIGNATURE DATE
===================================================================================================================================
</TABLE>
<PAGE> 11
APPENDIX E
ANNUAL HOLDINGS REPORT
AS OF DECEMBER 31, 20__
To: PFPC Distributors, Inc.
Chief Compliance Officer
From:
--------------------------
Employee Name
In accordance with the PFPC Distributors, Inc. Code of Conduct
governing personal securities transactions to which I am subject, I have
attached to this form copies of the most recent statements for each and every
Personal Account and Related Account, including Fully Discretionary Accounts,
that holds or is likely to hold a Security or Futures Contract in which I have a
Beneficial Ownership interest.
In addition, I hereby supply the following information for each and
every Personal Account and Related Account in which I have a Beneficial
Ownership interest for which I CANNOT supply the most recent account statement:
(1) The person in whose name the
account is held (if different from mine):
----------------------------
The relationship of that person to me:
----------------------------
(2) Name of the firm (e.g. securities broker-
dealer or futures commission merchant)
at which the account is maintained:
-----------------------------------------
Address of that firm:
----------------------------
----------------------------
The account number at that firm:
----------------------------
(3) Name of the representative responsible
for that account:
-----------------------------------------
His or her telephone number:
----------------------------
NOTE: This Report must be submitted to Compliance within 20 days after year-end.
<PAGE> 12
(4) Account holdings:
<TABLE>
<CAPTION>
Identity of Security Or Valuation
Futures Contract Cusip Quantity Value Date
----------------------- ----- -------- ----- ---------
<S> <C> <C> <C> <C> <C>
(a)
----------------------- --------- -------- ------ ---------
(b)
----------------------- --------- -------- ------ ---------
(c)
----------------------- --------- -------- ------ ---------
(d)
----------------------- --------- -------- ------ ---------
</TABLE>
I also supply the following information for each and every Security or
Futures Contract in which I have a Beneficial Ownership interest, to the extent
this information is not available elsewhere on this form or from the statements
and confirmations attached to this form:
<TABLE>
<CAPTION>
Person Who Description
Owns the Security of the Security Valuation
Or Futures Contract Or Futures Contract Cusip Quantity Value Date Custodian
------------------- ------------------- ----- -------- ----- --------- ---------
<S> <C> <C> <C> <C> <C> <C>
(a)
------------------- ------------------- --------- -------- ------- --------- ===========
(b)
------------------- ------------------- --------- -------- ------- --------- ===========
(c)
------------------- ------------------- --------- -------- ------- --------- ===========
(d)
------------------- ------------------- --------- -------- ------- --------- ===========
</TABLE>
(Attach additional sheets if necessary)
I hereby certify that this form and the documents attached hereto identify all
of the Securities and Futures Contracts in which I have a Beneficial Ownership
interest as of December 31, 20___.
Date:
---------------------------- ------------------------------------
Print Name
--------------------------------- ------------------------------------
Dept. Number and Location Signature
NOTE: This Report must be submitted to Compliance within 20 days after year-end.
<PAGE> 13
ANNUAL ACKNOWLEDGEMENT FORM
PFPC DISTRIBUTORS, INC. CODE OF CONDUCT
--------------------------------------------------------------------------------
I am a representative of PFPC Distributors, Inc. I have received a copy of the
PFPC Distributors, Inc. Code of Conduct.
I understand that I may not enter into any personal securities transactions on
the basis of information with respect to fund portfolio transactions received in
connection with my employment by, or association with, PFPC, until such
information has become publicly available.
I acknowledge and fully understand my responsibilities as outlined in the PFPC
Distributors, Inc. Code of Conduct.
I agree to submit written reports of my securities transactions within five days
of the end of the calendar quarter should I become an "Access Person" as such
term in defined in the Code of Conduct.
I understand that failure to timely remit my written report of personal
securities transactions within the time required constitutes a breach of PFPC
Distributors, Inc.'s Code of Conduct and may be reportable to PFPC Distributors,
Inc.'s Board of Directors.
I agree to comply with all aspects of PFPC Distributors, Inc. Code of Conduct'
requirements and standards as outlined.
--------------------------------------------------------------------------------
Full Name (print)
---------------------------------------------------------------
Signature
---------------------------------------------------------------
Date
---------------------------------------------------------------
Please return your completed acknowledgement to: PFPC DISTRIBUTORS, INC.
COMPLIANCE DEPT
MAIL STOP: W3-F400-01-9
