Nike Securities L.P.
Code of Ethics
I. STATEMENT OF GENERAL PRINCIPLES
This Code of Ethics is being adopted by Nike Securities L.P. (the "Company"),
The First Trust Special Situations Trust, The First Trust Combined Series, The
First Trust of Insured Municipal Bonds, The First Trust GNMA, and The First
Trust of Insured Municipal Bonds - Multi-State (the "Trusts") in recognition of
the fact that the Company owes a duty at all times to place the interests of
holders of Units of the Trusts and Shareholders of the Funds first. In
recognition of such duty it is the Company's policy that the personal securities
transactions and other activities of Company personnel 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 that could occur through such activities as "insider trading"
or "frontrunning" Trust or Fund securities trades. It is also the Company's
policy that Company personnel should not take inappropriate advantage of their
position with respect to Trusts or Funds sponsored by the Company and that such
personnel should avoid any situation that might compromise, or call into
question, their exercise of fully independent judgment in the interest of Unit
holders or Shareholders.
II. DEFINITIONS
For Purposes of this Code of Ethics:
A. "Company" shall mean Nike Securities L.P.
B. "Trust" shall mean any unit investment trust sponsored by the
Company.
C. "Unit holder" shall mean the holder of any unit of any Trust.
D. "Fund" shall mean any open-end management investment company for
which the Company acts as distributor or principal underwriter.
E. "Shareholder" shall mean the holder of any share of any Fund.
F. "Access Person" shall mean any partner, officer or employee of the
Company who makes, participates in or obtains information regarding the
purchase or sale of securities for a Trust's or Fund's portfolio or
whose functions or duties as part of the ordinary course of his
business relate to the making of any recommendation regarding the
purchase or sale of securities for a Trust or Fund and includes, but is
not limited to, all personnel in the Company's research, new products,
securities trading, unit investment trust trading, wholesaling,
evaluation, marketing, trust administration, compliance, legal,
corporate publishing and investment advisory departments and any and
all supervisors thereof.
G. "Investment Person" shall mean any officer or employee of the Company
who makes, participates in or executes decisions regarding the purchase
or sale of securities for a Trust's or Fund's portfolio and includes,
but is not limited to, all personnel in the Company's research, new
products, securities trading, trust administration and investment
advisory departments and any and all supervisors thereof ; provided,
however, that any person shall be deemed to be an Investment Person for
purposes of this Code of Ethics only with respect to the type of
security for which such person makes, participates in or executes
purchase or sale decisions and provided further that any person who is
an Investment Person with respect to any type of security under the
Code shall be an Access person for purposes of all provisions of the
Code.
III. PROHIBITED PRACTICES
In furtherance of the policies set forth in paragraph I above, the following
practices shall be prohibited:
A. No Investment Person shall purchase any security during the initial
public offering of such security.
B. No Investment Person shall purchase any security in a private
placement transaction unless the purchase has been approved in writing
and in advance by the Compliance Department. In considering whether to
approve any such transaction, the Compliance Department shall take into
account, among other factors, whether the investment opportunity should
be reserved for any existing or proposed Trust and its Unit holders or
any Fund and its Shareholders and whether the opportunity is being
offered to an individual by virtue of his position. Any Investment
Person who has been authorized to acquire securities in a private
placement shall disclose that investment to the Compliance Department
before he takes part in a subsequent consideration of any Trust's or
Funds investment in that issuer, and the decision to include securities
of such issuer in a Trust or Fund shall be subject to independent
review by General Counsel of the Company.
C. No Access Person shall purchase or sell any security prior to the
initial public offering period of a Trust which it is proposed may
contain that security in its portfolio. No Access Person shall purchase
or sell any security on a day during which there is "buy" or a "sell"
order from a Trust or Fund for that security until such order is
executed or withdrawn. No Investment Person shall purchase or sell a
security within seven days before or after that security is bought or
sold by a Trust or Fund. Any profits realized on transactions
prohibited by this Section shall be disgorged.
D. No Investment Person shall profit from the purchase and sale, or
sale and purchase, of the same (or equivalent) securities within 30
days. Any profits realized on transactions prohibited by this Section
shall be disgorged.
E. No Investment Person shall serve on the Board of Directors of a
publicly traded company absent prior authorization of the Compliance
Department upon a determination that board service would be consistent
with the interests of Trusts and their Unit holders and the Funds and
their Shareholders and the establishment of appropriate "Chinese wall"
procedures by the Compliance Department.
F. Any provision of this Code of Ethics prohibiting any transaction by
an Access Person or Investment Person shall prohibit any transaction in
which such person has, obtains or disposes of any beneficial ownership
interest.
IV. COMPLIANCE PROCEDURES
In order to effectuate and monitor the foregoing policies and prohibitions, all
Access Persons and Investment Persons shall be required to comply with the
following procedures:
A. The securities trading personnel of the Company shall provide the
Compliance Department with a daily summary of buy and sell orders
entered by, on behalf of, or with respect to both Trusts, Funds and the
Company's unit investment trust accumulation account or accounts. The
Research Department shall notify the Compliance Department, in writing,
of the composition of the proposed portfolio of any proposed Trust on
the day that portfolio is determined. The Trust Administration
Department shall provide the Compliance Department with a daily written
summary of the Trusts, if any, for which a public offering has either
commenced or been terminated.
B. Each Access Person shall direct any firms at which he maintains
brokerage accounts to provide on a timely basis duplicate copies of
confirmations of all personal securities transactions and periodic
statements for all securities accounts to the Compliance Department.
The Compliance Department shall date stamp all duplicate copies of
personal securities transactions and account statements upon receipt.
C. Each Access Person shall disclose all personal securities holdings
to the Compliance Department both upon commencement of employment with
the Company and within 15 days of the end of each calendar year by
submitting the form attached to this Code of Ethics as Exhibit A.
D. Within 15 days following the end of each calendar year, each Access
Person shall certify to the Company that he has read and understands
this Code of Ethics and recognizes that he is subject to it and that he
has complied with the requirements of this Code of Ethics by submitting
the form attached hereto as Exhibit B.
E. Within 10 days following the end of each calendar quarter, each
Access Person shall report to the Compliance Department all personal
securities transactions effected during such quarter by submitting the
form attached hereto as Exhibit C.
F. Any provision of this Code of Ethics requiring an Access Person or
Investment Person to report securities transactions or securities
positions to the Company shall require the reporting of any transaction
or position in which such person has, acquires or disposes of any
beneficial ownership interest.
V. EXEMPTIONS
The following transactions shall be exempted from the provisions of Article III
and, in the case of paragraph A and C, Article IV of this Code of Ethics:
A. The purchase or sale of U.S. government securities, money market
instruments, mutual funds or unit investment trusts.
B. The purchase or sale of shares of issuers whose shares are traded on
a national or foreign securities exchange and which have a market
capitalization of at least $1 billion.
C. Purchases which are part of an automatic dividend reinvestment plan
or which involve no investment decision by the purchaser.
VI. SANCTIONS
Upon discovery of a violation of this Code of Ethics, including either
violations of the enumerated provisions or the general principles
provided, the Company may impose such sanctions as it deems
appropriate, including, inter alia, a fine, letter of censure or
suspension or termination of the employment of the violator.
EXHIBIT A
NIKE SECURITIES L.P.
ACCESS/INVESTMENT PERSON
SECURITIES HOLDINGS REPORT
Name of Access/Investment Person: ______________________________________
Date: ______________________________________________________
I hereby certify that as of _________________, I had a beneficial ownership
interest in no securities other than those set forth below.
Issuer # of shares/principal amount Market Value
______ ____________________________ ____________
OR
I hereby certify that as of __________________, I had a beneficial ownership
interest in no securities other than those set forth on the attached brokerage
account statements.
OR
I hereby certify that as of __________________, I had a beneficial interest in
no securities.
_____________________________-
Signature
EXHIBIT B
NIKE SECURITIES L.P.
ACCESS/INVESTMENT PERSON
CODE OF ETHICS CERTIFICATION
I, ___________________________, hereby certify that I have read, and understand
the NIKE SECURITIES L.P. Code of Ethics. Furthermore, I certify that I have
complied with its provisions during the preceding year.
____________________________ ___________________
Signature Date
EXHIBIT C
NIKE SECURITIES L.P.
ACCESS/INVESTMENT PERSON
QUARTERLY TRANSACTION REPORT
Name of Access/Investment Person: ________________________________________
Date: _____________________
I hereby certify that during the calendar quarter ended _____________, I had a
beneficial ownership interest in the following securities transactions:
Type of Type of
Transaction Security Issuer # of shares/principal amount $ amount
___________ _______________ ____________________________ ________
OR
I hereby certify that during the calendar quarter ended __________, I had a
beneficial ownership interest in no securities transactions other than those set
forth on the attached brokerage account confirmations.
OR
I hereby certify that during the calendar quarter ended ___________, I had a
beneficial ownership interest in no securities transactions.
-----------------------------------------
Signature
First Trust Advisors L.P.
Investment Company Code of Ethics
I. STATEMENT OF GENERAL PRINCIPLES
This Code of Ethics is being adopted by First Trust Advisors L.P. (the
"Company"), in recognition of the fact that the Company owes a duty at all
times to place the interests of investors in investment companies for which
the Company provides investment advisory services first. In recognition of
such duty it is the Company's policy that the personal securities
transactions and other activities of Company personnel 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 that could occur through such
activities as "insider trading" or "frontrunning" investment company
securities trades. It is also the Company's policy that Company personnel
should not take inappropriate advantage of their position with respect to
investment companies for which the Company provides investment advisory
services and that such personnel should avoid any situation that might
compromise, or call into question, their exercise of fully independent
judgment in the interest of investors in investment companies for which the
Company provides investment advisory services.
II. DEFINITIONS
For Purposes of this Code of Ethics:
A. "Company" shall mean First Trust Advisors L.P.
B. "Investment Company" shall mean any investment company for which the
Company provides investment advisory services.
C. "Investor" shall mean any investor of any Investment Company.
D. "Access Person" shall mean any partner, officer or employee of the
Company who makes, participates in or obtains information regarding the
purchase or sale of securities for an Investment Company's portfolio or
whose functions or duties as part of the ordinary course of his business
relate to the making of any recommendation regarding the purchase or sale
of securities for an Investment Company and includes all personnel listed
in the Company's form ADV.
E. "Investment Person" shall mean any officer or employee of the Company
who makes, participates in or executes decisions regarding the purchase or
sale of securities for an Investment Company's portfolio.
III. PROHIBITED PRACTICES
In furtherance of the policies set forth in paragraph I above, the
following practices shall be prohibited:
A. No Investment Person shall purchase any security during the initial
public offering of such security.
B. No Investment Person shall purchase any security in a private placement
transaction unless the purchase has been approved in writing and in advance
by the Compliance Department. In considering whether to approve any such
transaction, the Compliance Department shall take into account, among other
factors, whether the investment opportunity should be reserved for any
existing or proposed Investment Company and its Investors and whether the
opportunity is being offered to an individual by virtue of his position.
Any Investment Person who has been authorized to acquire securities in a
private placement shall disclose that investment to the Compliance
Department before he takes part in a subsequent consideration of any
Investment Company's investment in that issuer, and the decision to include
securities of such issuer in an Investment Company shall be subject to
independent review by General Counsel of the Company.
C. No Access Person shall purchase or sell any security on a day during
which there is "buy" or a "sell" order from an Investment Company for that
security until such order is executed or withdrawn. No Investment Person
shall purchase or sell a security within seven days before or after that
security is bought or sold by an Investment Company.
D. No Investment Person shall profit from the purchase and sale, or sale
and purchase, of the same (or equivalent) securities within 30 days.
E. No Investment Person shall serve on the Board of Directors of a publicly
traded company absent prior authorization of the Compliance Department upon
a determination that board service would be consistent with the interests
of Investment Companies and their investors and the establishment of
appropriate "Chinese wall" procedures by the Compliance Department.
F. Any provision of this Code of Ethics prohibiting any transaction by an
Access Person or Investment Person shall prohibit any transaction in which
such person has, obtains or disposes of any beneficial ownership interest.
IV. COMPLIANCE PROCEDURES
In order to effectuate and monitor the foregoing policies and prohibitions,
all Access Persons and Investment Persons shall be required to comply with
the following procedures:
A. The securities trading personnel of the Company shall provide the
Compliance Department with a daily summary of buy and sell orders entered
by, on behalf of, or with respect to Investment Companies.
B. Each Access Person shall direct any firms at which he maintains
brokerage accounts to provide on a timely basis duplicate copies of
confirmations of all personal securities transactions and periodic
statements for all securities accounts to the Compliance Department. The
Compliance Department shall date stamp all duplicate copies of personal
securities transactions and account statements upon receipt.
C. Each Access Person shall disclose all personal securities holdings to
the Compliance Department both upon commencement of employment with the
Company and within 15 days of the end of each calendar year by submitting
the form attached to this Code of Ethics as Exhibit A.
D. Within 15 days following the end of each calendar year, each Access
Person shall certify to the Company that he has read and understands this
Code of Ethics and recognizes that he is subject to it and that he has
complied with the requirements of this Code of Ethics by submitting the
form attached hereto as Exhibit B.
E. Within 10 days following the end of each calendar quarter, each Access
Person shall report to the Compliance Department all personal securities
transactions effected during such quarter by submitting the form attached
hereto as Exhibit C.
F. Any provision of this Code of Ethics requiring an Access Person or
Investment Person to report securities transactions or securities positions
to the Company shall require the reporting of any transaction or position
in which such person has, acquires or disposes of any beneficial ownership
interest.
G. The requirements of Section IV(B), IV(C), IV(D) and IV(E) shall be
deemed to be complied with by any Access Person who complies with
substantially similar requirements contained in the Nike Securities L.P.
Unit Investment Trust Code of Ethics.
V. EXEMPTIONS
The following transactions shall be exempted from the provisions of Article
III and, in the case of paragraph A and C, Article IV of this Code of
Ethics:
A. The purchase or sale of U.S. government securities, money market
instruments, mutual funds or unit investment trusts.
B. The purchase or sale of shares of issuers whose shares are traded on a
national or foreign securities exchange and which have a market
capitalization of at least $1 billion.
C. Purchases which are part of an automatic dividend reinvestment plan or
which involve no investment decision by the purchaser.
VI. SANCTIONS
Upon discovery of a violation of this Code of Ethics, including either
violations of the enumerated provisions or the general principles provided,
the Company may impose such sanctions as it deems appropriate, including,
inter alia, a fine, letter of censure or suspension or termination of the
employment of the violator.
EXHIBIT A
FIRST TRUST ADVISORS L.P.
ACCESS/INVESTMENT PERSON
SECURITIES HOLDINGS REPORT
Name of Access/Investment Person: ______________________________________
Date: ______________________________________________________
I hereby certify that as of _________________, I had a beneficial ownership
interest in no securities other than those set forth below.
Issuer # of shares/principal amount Market Value
______ ____________________________ ____________
OR
I hereby certify that as of __________________, I had a beneficial ownership
interest in no securities other than those set forth on the attached brokerage
account statements. OR
I hereby certify that as of __________________, I had a beneficial interest in
no securities.
______________________________________
Signature
EXHIBIT B
FIRST TRUST ADVISORS L.P.
ACCESS/INVESTMENT PERSON
CODE OF ETHICS CERTIFICATION
I, ___________________________, hereby certify that I have read, and understand
the FIRST TRUST ADVISORS L.P. Code of Ethics. Furthermore, I certify that I have
complied with its provisions during the preceding year.
___________________________________ __________________
Signature Date
EXHIBIT C
FIRST TRUST ADVISORS L.P.
ACCESS/INVESTMENT PERSON
QUARTERLY TRANSACTION REPORT
Name of Access/Investment Person:________________________________________
Date: _____________________
I hereby certify that during the calendar quarter ended _____________, I had a
beneficial ownership interest in the following securities transactions:
Type of Type of
Transaction Security Issuer # of shares/principal amount $ amount
___________ _______________ ____________________________ ________
OR
I hereby certify that during the calendar quarter ended __________, I had a
beneficial ownership interest in no securities transactions other that those set
forth on the attached brokerage account confirmations.
OR
I hereby certify that during the calendar quarter ended ___________, I had a
beneficial ownership interest in no securities transactions.
_________________________________________
Signature
CODE OF ETHICS DISTRIBUTION LIST
ACCESS PERSONS
MARK BRADLEY
W. SCOTT JARDINE
WILLIAM WEBB
RICHARD OLSON
CODE OF ETHICS DISTRIBUTION LIST
INVESTMENT PERSONS
JAMES BOWEN
MIKE BOYLE
CHARLES BRADLEY
ROBERT BREDEMEIER
SUSAN BRIX
ROBERT CAREY
STEVE CLAIBORNE
CHUCK CRAIG
JON ERICKSON
FRANK FICHERA
DAVID FIELD
JENNIFER FRIEBELE
ALEX GARBER
JOHN HAGERSON
SCOTT HALL
RON MCALISTER
DAVE MCGAREL
VANCE MEYER
CARLOS NARDO
CHRIS PETERSON
JOHN PHILLIPS
OMAR SEPULVEDA
JOHN SHERREN
JOHN SOUTHARD
STEVE STARKOVICH
RICHARD SWIATEK
First Defined Sector Fund
Code of Ethics
I. STATEMENT OF GENERAL PRINCIPLES
This Code of Ethics is being adopted by First Defined Sector Fund (the
"Company"), in recognition of the fact that the Company owes a duty at
all times to place the interests of its investors first. In recognition
of such duty it is the Company's policy that the personal securities
transactions and other activities of Company personnel 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 that could occur
through such activities as "insider trading" or "frontrunning"
investment company securities trades. It is also the Company's policy
that Company personnel should not take inappropriate advantage of their
position with respect to the Company and that such personnel should
avoid any situation that might compromise, or call into question, their
exercise of fully independent judgment in the interest of investors in
the Company.
II. DEFINITIONS
For Purposes of this Code of Ethics:
A. "Company" shall mean First Defined Sector Fund.
B. "Investor" shall mean any investor in the Company, whether directly
or indirectly through a separate account of an insurance company.
C. "Access Person" shall mean any trustee, officer or employee of the
Company who makes, participates in or obtains information regarding the
purchase or sale of securities for the Company's portfolio or whose
functions or duties as part of the ordinary course of his business
relate to the making of any recommendation regarding the purchase or
sale of securities for the Company.
D. "Investment Person" shall mean any officer or employee of the
Company who makes, participates in or executes decisions regarding the
purchase or sale of securities for the Company's portfolios.
III. PROHIBITED PRACTICES
In furtherance of the policies set forth in paragraph I above, the
following practices shall be prohibited:
A. No Investment Person shall purchase any security during the initial
public offering of such security.
B. No Investment Person shall purchase any security in a private
placement transaction unless the purchase has been approved in writing
and in advance by the Compliance Coordinator. In considering whether to
approve any such transaction, the Compliance Coordinator shall take
into account, among other factors, whether the investment opportunity
should be reserved for the Company and its Investors and whether the
opportunity is being offered to an individual by virtue of his
position. Any Investment Person who has been authorized to acquire
securities in a private placement shall disclose that investment to the
Compliance Coordinator before he takes part in a subsequent
consideration of the Company's investment in that issuer, and the
decision to include securities of such issuer in the Company shall be
subject to independent review by Counsel to the Company.
C. No Access Person shall purchase or sell a security within seven days
before or after that security is bought or sold by the Company if such
Access Person knows or should know that such security is being bought
or sold by the Company.
D. No Investment Person shall profit from the purchase and sale, or
sale and purchase, of the same (or equivalent) securities within 30
days.
E. No Investment Person shall serve on the Board of Directors of a
publicly traded company absent prior authorization of the Compliance
Coordinator upon a determination that board service would be consistent
with the interests of the Company and its investors and the
establishment of appropriate "Chinese wall" procedures by the
Compliance Coordinator.
F. Any provision of this Code of Ethics prohibiting any transaction by
an Access Person or Investment Person shall prohibit any transaction in
which such person has, obtains or disposes of any beneficial ownership
interest.
IV. COMPLIANCE PROCEDURES
In order to effectuate and monitor the foregoing policies and
prohibitions, all Access Persons and Investment Persons shall be
required to comply with the following procedures:
A. The securities trading personnel of the Company shall provide
the Compliance Coordinator with a daily summary of buy and sell orders
entered by, on behalf of, or with respect to the Company.
B. Each Access Person shall direct any firms at which he maintains
brokerage accounts to provide on a timely basis duplicate copies of
confirmations of all personal securities transactions and periodic
statements for all securities accounts to the Compliance Coordinator.
The Compliance Coordinator shall date stamp all duplicate copies of
personal securities transactions and account statements upon receipt.
C. Each Access Person shall disclose all personal securities holdings
to the Compliance Coordinator both upon commencement of employment with
the Company and within 15 days of the end of each calendar year by
submitting the form attached to this Code of Ethics as Exhibit A.
D. Within 15 days following the end of each calendar year, each
Access Person shall certify to the Company that he has read and
understands this Code of Ethics and recognizes that he is subject to it
and that he has complied with the requirements of this Code of Ethics
by submitting the form attached hereto as Exhibit B.
E. Within 10 days following the end of each calendar quarter, each
Access Person shall report to the Compliance Coordinator all
personal securities transactions effected during such quarter by
submitting the form attached hereto as Exhibit C.
F. Any provision of this Code of Ethics requiring an Access Person
or Investment Person to report securities transactions or
securities positions to the Company shall require the reporting of any
transaction or position in which such person has, acquires or
disposes of any beneficial ownership interest.
G. The requirements of Section IV(B), IV(C) and IV(E) shall be deemed
to be complied with by any Access Person who complies with
substantially similar requirements contained in the Nike Securities
L.P. Code of Ethics or First Trust Advisors L.P. Investment Company
Code of Ethics.
H. The requirements of Section IV(B), IV(C) and IV(E) shall not apply
to any member of the Board of Trustees of the Company unless such
member knows or, in the ordinary course of fulfilling his official
duties as a Trustee of the Company, should have known that during the
seven day period immediately preceding or after the date of any
transaction in a security by the member such security was purchased
or sold by the Company or such purchase or sale was considered by the
Company or its investment adviser.
V. EXEMPTIONS
The following transactions shall be exempted from the provisions of
Article III and, in the case of paragraph A and C, Article IV of this
Code of Ethics:
A. The purchase or sale of U.S. government securities, money market
instruments, mutual funds or unit investment trusts.
B. The purchase or sale of shares of issuers whose shares are
traded on a national or foreign securities exchange and which have a
market capitalization of at least $1 billion.
C. Purchases which are part of an automatic dividend reinvestment plan
or which involve no investment decision by the purchaser.
VI. SANCTIONS
Upon discovery of a violation of this Code of Ethics, including either
violations of the enumerated provisions or the general principles
provided, the Company may impose such sanctions as it deems
appropriate, including, inter alia, a fine, letter of censure or
suspension or termination of the employment of the violator.
EXHIBIT A
FIRST DEFINED SECTOR FUND
ACCESS/INVESTMENT PERSON
SECURITIES HOLDINGS REPORT
Name of Access/Investment Person: ______________________________________
Date: ______________________________________________________
I hereby certify that as of _________________, I had a beneficial ownership
interest in no securities other than those set forth below.
Issuer # of shares/principal amount Market Value
______ ____________________________ ____________
OR
I hereby certify that as of __________________, I had a beneficial ownership
interest in no securities other than those set forth on the attached brokerage
account statements.
OR
I hereby certify that as of __________________, I had a beneficial interest in
no securities.
________________________________
Signature
EXHIBIT B
FIRST DEFINED SECTOR FUND
ACCESS/INVESTMENT PERSON
CODE OF ETHICS CERTIFICATION
I, ___________________________, hereby certify that I have read, and understand
the FIRST DEFINED SECTOR FUND Code of Ethics. Furthermore, I certify that I have
complied with its provisions during the preceding year.
__________________________ ____________________
Signature Date
EXHIBIT C
FIRST DEFINED SECTOR FUND
ACCESS/INVESTMENT PERSON
QUARTERLY TRANSACTION REPORT
Name of Access/Investment Person:________________________________________
Date: _____________________
I hereby certify that during the calendar quarter ended _____________, I had a
beneficial ownership interest in the following securities transactions:
Type of Type of
Transaction Security Issuer # of shares/principal amount $ amount
----------- ---------------- ---------------------------- --------
OR
I hereby certify that during the calendar quarter ended __________, I had a
beneficial ownership interest in no securities transactions other that those set
forth on the attached brokerage account confirmations.
OR
I hereby certify that during the calendar quarter ended ___________, I had a
beneficial ownership interest in no securities transactions.
________________________________
Signature
CODE OF ETHICS DISTRIBUTION LIST
ACCESS PERSONS
Patrick M. Fitzgerald
Niel Nielson
Robert J. Bartel
Richard Erickson
W. Scott Jardine
Mark Bradley
CODE OF ETHICS DISTRIBUTION LIST
INVESTMENT PERSONS
James A. Bowen
David Field
Robert Carey
Sue Brix
Robert W. Bredemeier
