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Exhibit 99 (p)(viii)
DFA INVESTMENT DIMENSIONS GROUP INC.
AMENDMENT TO THE CODE OF ETHICS
This amendment to the Code of Ethics of DFA Investment Dimensions Group
Inc. (the "Fund," formerly DFA Small Company Fund Inc.) is adopted on March 31,
1988 pursuant to the requirements of Rule 17j-1 under the Investment Company Act
o f 1940, as amended (the "Act").
The Articles of Incorporation of the Fund have been amended to provide
for the issuance of seven diversified series of shares, each of which represents
a separate class ("Portfolio") of the Fund's common stock, each having a
different investment objective and different investment policies.
4. GENERAL
All the provisions of the Code of Ethics shall apply to each of the
Portfolios of the Fund as if each fund were a separate and distinct investment
company under the Act. Each reference to "Fund" in the Code of Ethics shall be
deemed to apply to each of the Portfolios of the Fund, in addition to the Fund
itself.
5. PORTFOLIOS
The Fund is made up of the following Portfolios:
THE U.S. 9-10 SMALL COMPANY PORTFOLIO -- Invests in readily marketable
stocks of small companies which are traded in the U.S. securities markets.
THE JAPANESE SMALL COMPANY PORTFOLIO -- Invests in readily marketable
stocks of small Japanese companies.
THE UNITED KINGDOM SMALL COMPANY PORTFOLIO -- Invests in readily
marketable stocks of small United Kingdom companies.
THE CONTINENTAL SMALL COMPANY PORTFOLIO -- Invests in readily
marketable stocks of small companies organized and traded in the European
continent.
THE U.S. LARGE COMPANY PORTFOLIO -- Invests in the stocks of companies
that comprise Standard & Poor's 500 Composite Stock Index.
THE DFA ONE-YEAR FIXED INCOME PORTFOLIO - The investment objective of
The DFA One-Year Fixed Income Portfolio is to achieve stable real value of the
capital with a minimum of risk by investing in high quality obligations.
THE DFA FIVE-YEAR FIXED INCOME PORTFOLIO -- The investment objective of
The DFA Five-Year Fixed Income Portfolio is to maximize total returns available
from the universe of high quality debt obligations which mature within five
years from the date of settlement.
THE DFA FIVE-YEAR GOVERNMENT PORTFOLIO -- The investment objective of
The DFA Five-Year Government Portfolio is to maximize total returns available
from the universe of U.S. Government and U.S. Government Agency debt obligations
which mature within five years from the date of settlement.
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DFA INVESTMENT DIMENSIONS GROUP INC.
AMENDMENT TO THE CODE OF ETHICS
This amendment to the Code of Ethics of DFA Investment Dimensions Group
Inc. (the "Fund," formerly DFA Small Company Fund Inc.) is adopted on March 31,
1988 pursuant to the requirements of Rule 17j-1 under the Investment Company Act
of 1940, as amended (the "Act").
The Articles of Incorporation of the Fund have been amended to provide
for the issuance of seven diversified series of shares, each of which represents
a separate class ("Portfolio") of the Fund's common stock, each having a
different investment objective and different investment policies.
1. GENERAL
All the provisions of the Code of Ethics shall apply to each of the
Portfolios of the Fund as if each fund were a separate and distinct investment
company under the Act. Each reference to "Fund" in the Code of Ethics shall be
deemed to apply to each of the Portfolios of the Fund, in addition to the Fund
itself.
2. PORTFOLIOS
The Fund is made up of the following Portfolios:
THE SMALL COMPANY PORTFOLIO--Invests in readily marketable stocks of
small companies which are traded in the U.S. securities markets.
THE JAPANESE SMALL COMPANY PORTFOLIO--Invests in readily marketable
stocks of small Japanese companies.
THE UNITED KINGDOM SMALL COMPANY PORTFOLIO--Invests in readily
marketable stocks of small United Kingdom companies.
THE CONTINENTAL SMALL COMPANY PORTFOLIO--Invests in readily marketable
stocks of small companies organized and traded on the European continent.
THE DFA FIXED INCOME PORTFOLIO--The investment objective of The DFA
Fixed Income Portfolio is to achieve stable real value of capital with a minimum
of risk by investing in high quality obligations.
THE DFA FIVE-YEAR FIXED INCOME PORTFOLIO--The investment objective of
The DFA Five-Year Fixed Income Portfolio is to maximize total returns available
from the universe of high quality debt obligations which mature within five
years from the date of settlement.
THE DFA FIVE-YEAR GOVERNMENT PORTFOLIO--The investment objective of The
DFA Five-Year Government Portfolio is to maximize total returns available from
the universe of U.S. Government and U.S. Government Agency debt obligations
which mature within five years from the date of settlement.
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DFA INVESTMENT DIMENSIONS GROUP INC.
AMENDMENT TO THE CODE OF ETHICS
This amendment to the Code of Ethics of DFA Investment Dimensions Group
Inc. (the "Fund," formerly DFA Small Company Fund Inc.) is adopted on March 31,
1988 pursuant to the requirements of Rule 17j-1 under the Investment Company Act
of 1940, as amended (the "Act").
The Articles of Incorporation of the Fund have been amended to provide
for the issuance of seven diversified series of shares, each of which represents
a separate class ("Portfolio") of the Fund's common stock, each having a
different investment objective and different investment policies.
1. GENERAL
All the provisions of the Code of Ethics shall apply to each of the
Portfolios of the Fund as if each fund were a separate and distinct investment
company under the Act. Each reference to "Fund" in the Code of Ethics shall be
deemed to apply to each of the Portfolios of the Fund, in addition to the Fund
itself.
2. PORTFOLIOS
The Fund is made up of the following Portfolios:
THE SMALL COMPANY PORTFOLIO--Invests in readily marketable stocks of
small companies which are traded in the U.S. securities markets.
THE JAPANESE SMALL COMPANY PORTFOLIO--Invests in readily marketable
stocks of small Japanese companies.
THE UNITED KINGDOM SMALL COMPANY PORTFOLIO--Invests in readily
marketable stocks of small United Kingdom companies.
THE CONTINENTAL SMALL COMPANY PORTFOLIO--Invests in readily marketable
stocks of small companies organized and traded on the European continent.
THE DFA FIXED INCOME PORTFOLIO--The investment objective of The DFA
Fixed Income Portfolio is to achieve stable real value of capital with a minimum
of risk by investing in high quality obligations.
THE DFA FIVE-YEAR FIXED INCOME PORTFOLIO--The investment objective of
The DFA Five-Year Fixed Income Portfolio is to maximize total returns available
from the universe of high quality debt obligations which mature within five
years from the date of settlement.
THE DFA FIVE-YEAR GOVERNMENT PORTFOLIO--The investment objective of The
DFA Five-Year Government Portfolio is to maximize total returns available from
the universe of U.S. Government and U.S. Government Agency debt obligations
which mature within five years from the date of settlement.
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DFA INVESTMENT DIMENSIONS GROUP INC.
AMENDMENT TO THE CODE OF ETHICS
This amendment to the Code of Ethics of DFA Investment Dimensions Group
Inc (the "Fund," formerly DFA Small Company Fund Inc.) is adopted on June 8,
1983 pursuant to the requirements of Rule 17j-1 under the Investment Company Act
of 1940, as amended (the "Act").
The Articles of Incorporation of the Fund have been amended to provide
for the issuance of three diversified series of shares, each of which represents
a separate class ("Portfolio") of the Fund's common stock, each having a
different investment objective and different investment policies.
1. GENERAL
All the provisions of the Code of Ethics shall apply to each of the
Portfolios of the Fund as if each fund were a separate and distinct investment
company under the Act. Each reference to "Fund" in the Code of Ethics shall be
deemed to apply to each of the Portfolios of the Fund, in addition to the Fund
itself.
2. PORTFOLIOS
The Fund is made up of the following Portfolios:
The Small Company Portfolio, which has an investment objective of
achieving capital appreciation by investing in readily marketable stocks of
small companies;
Inflation Hedge Portfolio A, which has the investment objective of
achieving stable real value of capital with a minimum of risk by investing in
high quality obligations, such as U.S. Government obligations, high quality
commercial paper and corporate obligations and obligations issued by U.S. banks
and U.S. branches and subsidiaries of foreign banks;
Inflation Hedge Portfolio B, which has the investment objective of
achieving stable real value of capital without assuming undue risk by investing
in Eurodollar obligations, obligations issued by U.S. banks and U.S. branches
and subsidiaries of foreign banks, commercial paper, U.S. and foreign corporate
obligations and U.S. Government obligations to the extent necessary to meet
redemptions.
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DFA INVESTMENT DIMENSIONS GROUP INC.
AMENDMENT TO THE CODE OF ETHICS
This amendment to the Code of Ethics of DFA Investment Dimensions Group
Inc (the "Fund," formerly DFA Small Company Fund Inc.) is adopted on June 8,
1983 pursuant to the requirements of Rule 17j-1 under the Investment Company Act
of 1940, as amended (the "Act").
The Articles of Incorporation of the Fund have been amended to provide
for the issuance of three diversified series of shares, each of which represents
a separate class ("Portfolio") of the Fund's common stock, each having a
different investment objective and different investment policies.
1. GENERAL
All the provisions of the Code of Ethics shall apply to each of the
Portfolios of the Fund as if each fund were a separate and distinct investment
company under the Act. Each reference to "Fund" in the Code of Ethics shall be
deemed to apply to each of the Portfolios of the Fund, in addition to the Fund
itself.
2. PORTFOLIOS
The Fund is made up of the following Portfolios:
The Small Company Portfolio, which has an investment objective of
achieving capital appreciation by investing in readily marketable stocks of
small companies;
Inflation Hedge Portfolio A, which has the investment objective of
achieving stable real value of capital with a minimum of risk by investing in
high quality obligations, such as U.S. Government obligations, high quality
commercial paper and corporate obligations and obligations issued by U.S. banks
and U.S. branches and subsidiaries of foreign banks;
Inflation Hedge Portfolio B, which has the investment objective of
achieving stable real value of capital without assuming undue risk by investing
in Eurodollar obligations, obligations issued by U.S. banks and U.S. branches
and subsidiaries of foreign banks, commercial paper, U.S. and foreign corporate
obligations and U.S. Government obligations to the extent necessary to meet
redemptions.
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DFA SMALL COMPANY FUND INC.
CODE OF ETHICS
GENERAL
This Code of Ethics of DFA Small Company Fund Inc. is adopted on
December 11, 1981 pursuant to the requirements of Rule 17j-l under the
Investment Company Act of 1940, as amended.
1. DEFINITIONS
(1) "Access Person" means each officer and director of the Fund and its
investment adviser and any employee of these organizations, who, in connection
with his regular functions or duties, makes, participates in, or obtains
information regarding the purchase or sale of a security by the Fund, or whose
functions relate to the making of any recommendations with respect to such
purchases or sales; and any natural person in a control relationship to the Fund
or its investment adviser who obtains information with respect to the Fund with
regard to the purchase or sale of a security.
(2) "Security" means all securities except securities issued by the
Government of the United States, bankers acceptances, certificates of deposit,
commercial paper and shares of registered open-end investment companies.
(3) A "security held or to be acquired" means a security which, within
the most recent 15 days (i) is or has been held by the Fund; or (ii) is being or
has been considered by the Fund or its investment adviser for purchase by the
Fund.
(4) "Beneficial Ownership" shall have the meaning. ascribed thereto
under Section 16 of the Securities Exchange Act of 1934.
2. PROHIBITIONS
No Access Person of the Fund:
(a) In connection with the purchase or sale by such person of a
Security held or to be acquired by the Fund:
(i) shall employ any device, scheme or artifice to defraud the Fund;
(ii) make to the any untrue statement of a material fact or omit to
state to the Fund a material fact necessary in order to make the statements
made, in light of the circumstances under which they are made, not misleading;
(iii) engage in any act, practice, or course of business which operates
or would operate as a fraud or deceit upon the Fund; or
(iv) engage in any manipulative practice with respect to the Fund.
(b) Shall purchase or sell, directly or indirectly, any security in
which he has, or by reason of such transaction acquires, any direct or indirect
Beneficial Ownership and which to his actual knowledge at the time of such
purchase or sale:
(i) is being considered for purchase or sale by the Fund; or (ii) is
then being purchased or sold by the Fund; or
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(ii) is then being purchase or sold by the Fund.
3. EXEMPTED TRANSACTIONS
The prohibitions of Section 2 of this Code shall not apply to:
(a) Purchases or sales effected in any account over which the Access
Person has no direct or indirect influence or control.
(b) Purchases or sales of securities which are not eligible for
purchase or sale by the Fund.
(c) Purchases or sales which are non-volitional on the part of either
the Access Person or the Fund.
(d) Purchases which are part of an automatic dividend reinvestment
plan.
(e) Purchases effected upon the exercise of rights issued by an issuer
pro rata to all holders of a class of its securities, to the extent such rights
were acquired from such issuer, and sales of such rights so acquired.
(f) Purchases or sales which receive the prior approval of the
President or an Executive Vice President of the Fund because there exists only a
remote potential for a conflict of interest with the Fund because they would be
very unlikely to affect a highly institutional market, or because they clearly
are not related economically to the securities to be purchased, sold or held by
the Fund. The secretary of the Fund shall record "any action taken pursuant to
this subsection 3(f).
4. PROCEDURAL MATTERS
(a) The Secretary of the Fund shall:
(i) Furnish a copy of this Code to each Access Person of the Fund.
(ii) Notify each such Access Person of his obligation to file reports
as provided by Section 5 of this Code.
(iii) Report to the Board of Directors the facts contained in any
reports filed with the Secretary pursuant to Section 5 of this Code when any
such report indicates that an Access Person engaged in a transaction in a
security held or to be acquired by the Fund.
(iv) Maintain the records required by paragraph (d) of Rule 17j-1.
(v) Maintain any records furnished to him pursuant to Section 3(f)
herein.
5. REPORTING
(a) Every Access Person shall report to the Fund the information
described in Section 5(c) of this Code with respect to transactions in any
security in which such Access Person has, or by reason of such transaction
acquires, any direct or indirect Beneficial ownership in the security; provided,
however, that an Access Person shall not be required to make a report with
respect to transactions effected for any account over which such person does not
have any direct or indirect influence.
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(b) A disinterested director of the Fund need only report a transaction
in a security if such director, at the time of that transaction, knew or, in the
ordinary course of fulfilling his official duties as a director of the Fund,
should have known that, during the 15-day period immediately preceding the date
of the transaction by the director, such security was purchased or sold by the
Fund or was being considered for purchase or sale by its investment adviser.
(c) Every report shall be made not later than 10 days after the end of
the calendar quarter in which the transaction to which the report relates was
effected, and shall contain the following information:
(i) The date of the transaction, the title and the number of shares,
and the principal amount of each security involved;
(ii) The nature of the transaction (i.e., purchase, sale or any other
type of acquisition or disposition);
(iii) The price at which the transaction was effected; and,
(iv) The name of the broker, dealer or bank with or through whom the
transaction was effected.
(d) Any such report may contain a statement that the report shall not
be construed as an admission by the person making such report that he has any
direct or indirect Beneficial Ownership in the security to which the report
relates.
6. VIOLATIONS
Upon being apprised of facts which indicate that a violation of Code
may have occurred, the Board of Directors of the Fund shall determine whether,
in their judgment, the conduct being considered did in fact violate the
provisions of this Code. If the Board of Directors determines that a violation
of the Code has occurred, the Board may impose such sanctions as it deems
appropriate in the circumstances. If the person whose conduct is being
considered by the Board is a director of the Fund, he shall not be eligible to
participate in the judgment of the Board as to whether a violation exists or in
whether, or to what extent, sanctions should be imposed.
