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Exhibit p(18)
TURNER INVESTMENT PARTNERS, INC.
PERSONAL TRADING POLICY/CODE OF ETHICS
February 17, 2000
A. Personal investments: An employee should consider himself the beneficial
owner of those securities held by him, his spouse, his minor children, a
relative who shares his house, or persons by reason of any contract,
arrangement, understanding or relationship that provides him with sole or
shared voting or investment power.
B. Employees are barred from purchasing any securities (to include Common
Stock and related Options, Convertible securities, Options, or Futures on
Indexes) in which the firm has either a long or short position. If an
employee owns a position in any security, he must get written pre-clearance
from the Chairman or President to add to or sell the position. ALL SECURITY
TRANSACTIONS (BUY OR SELL) REQUIRE WRITTEN CLEARANCE IN ADVANCE. Approval
is good for 48 hours; if a trade has not been executed, subsequent
approvals are necessary until the trade is executed. The Exception
Committee (the Chairman, Vice Chairman, President, and Director of
Compliance) must approve any exceptions to this rule.
C. Employees may not purchase initial public offerings. Private
placements/Limited partnerships require written pre-clearance. Mutual Fund
holdings are excluded from pre-clearance and reporting. IRA's, and Rollover
IRA's that are self-directed (i.e. stocks or bonds, not mutual funds), and
ESOP's (Employee stock ownership plans) require pre-clearance.
D. Blackout Restrictions: Employees are subject to the following restrictions
when their purchases and sales of securities coincide with trades of Turner
Clients (including investment companies):
1. Purchases and sales within three days following a client trade.
Employees are prohibited from purchasing or selling any security
within three calendar days after a client transaction in the same (or
a related) security. The Exception Committee must approve exceptions.
If an employee makes a prohibited transaction without an exception the
employee must unwind the transaction and relinquish any gain from the
transaction to charity.
2. Purchases within seven days before a client purchase. An employee who
purchases a security within seven calendar days before a client
purchases the same (or a related) security is prohibited from selling
the security of a period of six months following the client's trade.
The Exception Committee must approve exceptions. If an employee makes
a prohibited sale without an exception within the six month period,
the employee must relinquish any gain from the transaction to charity.
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PERSONAL TRADING POLICY/CODE OF ETHICS
February 17, 2000
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3. Sales within seven days before a client sale. An employee who sells a
security within seven days before a client sells the same (or a
related) security must relinquish to charity the difference between
the employee's sale price and the client's sale price (assuming the
employee's sale price is higher).
4. These restrictions do not apply to proprietary investment partnerships
for which the firm acts as an adviser in which the officers and
employees of the adviser have an equity interest of less than 50%.
These accounts may purchase the same or similar securities within the
black out period, if the partnership trades with the block or after
other clients. Where it is beneficial to client accounts and it is
possible to do so, they should be blocked with the partnership
account.
E. Short Term Trading Rule - Employees may not take profits in any security in
less than 60 days (includes Options, Convertibles and Futures). If an
individual must trade with in this period, the Exception Committee must
grant approval or the employee must relinquish such profits to charity. The
closing of positions at a loss is not prohibited. Options that are out of
the money may be exercised in less than 60 days. The proprietary
partnerships may take profits in less than 60 days.
F. Reporting: Consistent with the requirements of the Investment Advisers Act
of 1940 Rule 204-2 (a)(2) and (a)(3) and with the provisions of Rule 17j-1
of the Investment Company Act of 1940 all employees must submit duplicate
statements/disclosures within 10 days following the calendar quarter.
Statements are reviewed by one of the firms Series 24 principals.
Brokerage, IRA's, Rollover IRA's (which are self-directed), ESOP's, private
placement and limited partnerships must all be reported as personal
trading. New employees are required to file initial holdings within 10 days
of hire.
G. Violation of the Personal Investments/Code of Ethics policy may result in
disciplinary action, up to and including termination of employment.
