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Exhibit (p)(2)
Policy 4.05 Personal Trading
as revised August 18, 2000
from
Banc One Investment Advisors Corporation's Compliance Manual
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4.05 Personal Trading
Banc One Investment Advisors Corporation / Compliance Manual
General Principles
It is the policy of Banc One Investment Advisors Corporation ("Investment
Advisors") that all employees must (1) at all times place the interest of the
accounts which are managed by Investment Advisors first; (2) conduct all
personal securities transactions in a manner that is consistent with the
Personal Trading Policy of Investment Advisors and the individual employee's
position of trust and responsibility; and (3) adhere to the fundamental standard
that Investment Advisors employees must not take inappropriate advantage of
their position.
Trading while in possession of material, non-public information, which may or
may not be obtained through Investment Advisors analyst's research function is
prohibited. The disclosure of any such material, non-public information to any
person is also prohibited.
Governing Standards
This Personal Trading Policy is designed to comply with Rule 17j-1 of the
Investment Company Act of 1940, Rule 204-2(a)(12) of the Investment Advisers Act
of 1940 and the Investment Company Institute's ("ICI") Guidelines on Personal
Investing issued in 1994.
This Personal Trading Policy, unless otherwise specifically stated, shall apply
to all employees of Investment Advisors. This policy will also apply to members
of the Board of Directors of Investment Advisors.
Restrictions on Personal Trading Activities
1. Initial Public Offerings
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All employees of Investment Advisors are prohibited from acquiring any security
in an initial public offering. There are three (3) exceptions. They are: 1)
mutual savings bank conversions where an employee maintains an account with the
converting savings bank; 2) insurance company offering where an employee is a
policy holder of the insurance company; and, 3) an
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offering that is made to an employee's spouse by the spouse's employer. In all
cases, the employee must provide documentation of the offering.
2. Private Placements
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All employees must, when purchasing securities in a private placement:
a. obtain the prior written approval of Investment Advisors Corporate Legal
Counsel, and b. disclose the investment, in writing, when they are involved in
any subsequent decision to invest in the issuer on behalf of an account (i.e.
mutual fund, clones, common/collective funds, personal trust and institutional
accounts) which they manage and refer the decision to purchase securities of the
issuer for the account to the Senior Managing Director of Equity Securities or
Senior Managing Director of Fixed Income Securities. A copy of the written
disclosure must be provided to the appropriate Senior Managing Director listed
above in order for the appropriate Senior Managing Director to make a decision
on the purchase of the securities.
3. Blackout Periods
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a. Same Day
All employees, other than employees in the following divisions of Alternative
Assets: Farm and Ranch, Minerals, Oil and Gas, and Real Estate, are prohibited
from executing a securities transaction (buy or sell) on a day when a mutual
fund, investment trust portfolio or clone account of the mutual fund (i.e.
institutional clones or common/collective trust funds) has a pending "buy or
sell" order in the same (or equivalent) security until that mutual fund,
investment trust portfolio or clone account order is executed or withdrawn. An
exception will be granted for trades pending ONLY in one of the following funds:
Equity Index, Market Expansion Index or International Equity Index. Any personal
trades executed within the proscribed blackout periods will be considered a
violation of the Policy and subject to the sanctions contained within the
Penalty Section of the Policy.
b. Seven Day
All mutual fund team members including portfolio managers, research analysts and
traders, are prohibited from buying or selling a security within at least seven
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(7) calendar days before and after the mutual fund,
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investment trust portfolio or clone fund (i.e. institutional clones or
common/collective trust funds) their team manages trades in the same (or
equivalent, i.e. any option to purchase or sell and any security convertible
into or exchangeable for that security) security. Any personal trades executed
by any employee listed above, within the proscribed blackout period, will be
considered a violation of the Policy and subject to the sanctions contained
within the Penalty Section of the Policy. Please see the Disclosure and
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Reporting Requirements section of this Policy for information regarding
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pre-clearance and post-clearance of personal securities transactions.
4. Ban on Short-Term Trading Profits
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All employees, other than employees in the following divisions of Alternative
Assets: Farm and Ranch, Minerals, Oil and Gas, and Real Estate, are prohibited
from profiting in the purchase and sale, or the sale and purchase of the same
(or equivalent) securities within sixty (60) calendar days. Any personal trades
executed within the banned period will be considered a violation of the Policy
and subject to the sanctions contained within the Penalty Section of the Policy.
This prohibition does not apply to: 1.) Transactions in exempted securities
(i.e., direct obligations of the government of the United States, its agencies
and instrumentalities, registered investment companies (i.e. shares Fidelity,
Putnam, Janus funds, etc.), Banc One Corporation stock (ONE); 2.) incentive
compensation stock option transactions; 3.) transactions which do not result in
a gain.
5. Gifts
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All employees must follow the guidelines of the Bank One Corporation Code of
Ethics, which is incorporated into Investment Advisors Compliance Policy No.
4.01, Conflicts of Interest & Business Ethics, when receiving any gift or other
thing of value.
6. Service as a Director
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All employees must follow the guidelines of the Bank One Corporation Code of
Ethics, which is incorporated into Investment Advisors Compliance Policy No.
4.01, Conflicts of Interest & Business Ethics, regarding their ability to serve
as a corporate director.
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7. Internal Research Reports
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Trading in an employee account, other than employees in the following divisions
of Alternative Assets: Farm and Ranch, Minerals, Oil and Gas, and Real Estate,
is prohibited for 48 hours (two (2) trading days) before and after a research
report regarding a particular security is distributed. Trading of a security in
an employee account is also not permitted for 48 hours (2 trading days) before
and after the addition or deletion of the security to or from an Approved List
or Model Portfolio. No employee is permitted to trade securities in a manner
contrary to recommendations by Investment Advisors without written permission
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from a Compliance Officer.
8. Bank One Securities
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The Bank One Corporation Insider Trading Policy (which is a part of Investment
Advisors Insider Trading Policy) states:
As an officer or employee of a Bank One Corporation affiliate, you are
prohibited from trading in Bank One securities at any time that you are in
possession of inside information. Additionally, you are strongly advised to
limit your trading in Bank One securities to the "window period" commencing 48
hours after Bank One's release of its quarterly financial results and ending
fifteen (15) days prior to the quarter end. During such "window period" the
investing public presumably is in possession of all material financial
information about Bank One.
However, if you have inside information relative to Bank One, you may not trade
even during the "window period." Reporting Persons (as defined in the Bank One
Corporation Insider Trading Policy) may not be able to trade in Bank One
securities during a "window period" even when they are not in possession of
inside information.
ALL employees of a Bank One Corporation affiliate, are prohibited from selling
Bank One stock which they do not own ("selling short") and purchasing or selling
options on shares of Bank One stock (except for the exercise of stock options
granted under a Bank One stock option or similar Bank One plan). This
prohibition also applies to a Bank One announced acquisition target, a Bank One
supplier or candidate for entering into a joint venture or other significant
business relationship with Bank One.
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9. Investment Clubs
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All employees of Investment Advisors are prohibited from participating in an
investment club.
Disclosure and Reporting Requirements
1. Preclearance
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All employees, other than employees in the following divisions of Alternative
Assets: Farm and Ranch, Minerals, Oil and Gas, and Real Estate, are required to
preclear all securities transactions (both buys and sells) in which the employee
has, or by reason of the transaction acquires, any direct or indirect beneficial
ownership, with the Senior Managing Director of Equity Securities, or in their
absence the Manager of the Equity Trading Desk or some other designee, for all
transactions in equity securities and the Senior Managing Director of Fixed
Income Securities, or in their absence the Director of Fixed Income Research or
the Manager of the Fixed Income Taxable Bond Team or Tax-Exempt Bond Team for
all transactions in fixed income securities. Those individuals listed above must
receive preclearance from the Chief Compliance Officer.
Preclearance is good only for the business day on which it is granted and for
the following business day. For example, if you received clearance to trade a
security on Monday, you must trade that security on Monday or Tuesday. If you
decide you do not want to place the trade on Monday or Tuesday and want to place
the trade on Wednesday instead, you must obtain new preclearance for Wednesday.
Trades placed on the second business day of the preclearance window must be
executed during trading hours. You must obtain a separate preclearance for each
buy and sell transaction.
The employee may receive preclearance orally from one of the above-referenced
individuals which must then be followed up in writing by the individual granting
preclearance within 24 hours after clearance is granted. A copy of the
preclearance approval must be sent to the employee as well as to the Chief
Compliance Officer. Any trade for which a preclearance approval in writing is
not received may be considered a violation of this Personal Trading Policy.
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It is not necessary to receive preclearance for the following exempt securities:
(1) direct obligations of the government of the United States, its agencies or
instrumentalities; (2) shares of registered investment companies; and, (3) ONE.
Beneficial ownership of a security is determined in the following manner: an
employee should consider themselves the beneficial owner of securities held by
their spouse, their minor children, another person who shares their home or
other persons if by reason of any contact, understanding, relationship agreement
or other arrangement they obtain from such ownership. The employee should also
consider themselves the beneficial owner of securities if they can invest or
revest title in themselves now or in the future.
Both the Investment Company Act of 1940 and the Investment Advisers Act of 1940
define securities as: any note, stock, treasury stock, bond, debenture, evidence
of indebtedness, certificate of interest or participation in any profit-sharing
agreement, collateral-trust certificate, preorganization certificate or
subscription, transferable share, investment contract, voting-trust certificate,
certificate of deposit for a security, fractional undivided interest in oil, gas
or other mineral rights, any put, call, straddle, option or privilege on any
security, (including a certificate of deposit) or on any group or index of
securities including any interest therein (or based on the value thereof) or any
put, call, straddle, option or privilege entered into on a national securities
exchange relating to foreign currency, or, in general, any interest or
instrument commonly known as a "security", or any certificate of interest or
participation in, temporary or interim certificate for, receipt for, guarantee
of, or warrant or right to subscribe to or purchase any of the foregoing.
Registered Investment Company is defined as: open-end mutual funds, closed-end
mutual funds, Unit Investment Trusts (UITs), and exchanges traded funds such as
QQQ, Diamonds, Spiders, etc.
Any questions regarding the definition of securities or registered investment
companies should be directed to the Compliance Department.
2. Post-clearance
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In addition to pre-clearance, all mutual fund team members, including portfolio
managers, research analysts and traders, are required to post-clear all personal
securities transactions (both buys and sells) on the 8th calendar day following
the date of the trade. Failure to post-clear a trade will be considered a breach
of the Policy and subject to the sanctions contained within the Penalty section
of the Policy.
If a trade (buy or sell) has been executed in a mutual fund, investment trust
portfolio or clone account which the employee's team manages within the 7
(seven) calendar days following the date of the employee's trade, the following
action must be taken by the employee:
A) If the trade is part of a program trade (Program Trade):
1. If the employee is designated as "Level 2", the employee must reverse the
non-qualifying trade, after obtaining the necessary preclearance, and disgorge
any profit, to a charity of their choice, within 10 (ten) business days of
notification. The employee must provide a copy of the letter to the charity and
the check made payable to the charity for the amount of the disgorgement to the
Compliance Department. In addition, the employee must provide a copy of the
canceled check once it is available. After the third non-qualifying trade, the
employee will be restricted to trading in exempt securities as defined in the
"Preclearance" section of the Policy for a period of 6 (six) months. If an
employee is restricted from trading 3 (three) times, the employee will then be
restricted to only trading in exempt securities for the remainder of their
tenure at Investment Advisors.
2. If the employee is designated as "Level 3", the employee must reverse the
non-qualifying trade, after obtaining the necessary preclearance, and pay a
penalty of 25% of the market value of the original transaction within 10
business days of notification. The penalty shall be paid to a charity that the
employee chooses. The employee must provide a copy of a letter and check made
payable to the charity for the amount of the penalty to the Compliance
Department. In addition, the employee must provide a copy of the canceled check
once it is available. After the second non-qualifying trade, the employee will
be restricted to trading in exempt securities as defined in the "Preclearance"
section of the Policy for a period of 6 (six) months. If an employee is
restricted from trading 2 (two) times, the
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employee will then be restricted to only trading in exempt securities for the
remainder of their tenure at Investment Advisors.
B. If the trade is not a Program Trade (Non-Program Trade); this will
be considered a violation of the Policy and subject to the sanctions
contained within the Penalty section of the Policy.
Definitions
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Program Trade is defined as: (i) cash being added to an account which causes
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securities to be bought in a manner that maintains the accounts existing
allocation or (ii) cash being withdrawn from an account which causes securities
to be sold in a manner that maintains the account's current securities
allocation.
Non-Program Trade is defined, as any trade that is not a Program Trade as
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defined above.
"Level 2" designation is an employee of Investment Advisors who is a member of a
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mutual fund team but does not authorize trades.
"Level 3" designation is an employee of Investment Advisors who is a member of a
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mutual fund team and who does authorize trades.
Authorize Trades is defined as a person who has authority to place the trade and
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is responsible for its generation.
The designation of Level 2 and Level 3 employees is the responsibility of the
Senior Managing Director of Equity Securities and the Senior Managing Director
of Fixed Income Securities. The initial reporting of these designations must be
made to the Preclearance Group and the Compliance Department upon the effective
date of this policy. In addition, it will be their responsibility to notify the
Compliance Department and the Preclearance Group of any changes in designations
immediately upon their effectiveness. Failure to provide the Preclearance Group
and the Compliance Department of any changes in Level designations may have
adverse consequences on an employee's personal trading.
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3. Records of Securities Transactions
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All employees are required to direct, in writing with a copy to the Chief
Compliance Officer, their brokers to provide the Chief Compliance Officer with
duplicate copies of confirmations of all reportable personal securities
transactions and copies of all statements for all securities accounts.
Reportable transactions do not include (1) direct obligations of the United
States Government, its agencies or instrumentalities; and, (2) shares of
registered investment companies.
4. Disclosure of Personal Holdings
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All employees are required to disclose all personal securities holdings
(including direct obligations of the U.S. Government, its agencies and
instrumentalities, registered investment companies and ONE), in writing to the
Chief Compliance Officer upon commencement of employment and thereafter on an
annual basis. Reports must be received within ten (10) calendar days of
employment and within ten (10) calendar days of each year-end (i.e., January
10).
5. Certification of Compliance with the Personal Trading Policy
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All employees are required to certify annually in writing to the Chief
Compliance Officer that they have read and understand the Personal Trading
Policy. Each employee must further certify that they have complied with the
requirements of the Personal Trading Policy and that they have disclosed or
reported all personal securities transactions required to be disclosed or
reported.
Compliance Procedures
In order to provide information to determine with reasonable assurance whether
all employees are observing the provisions of the Personal Trading Policy:
1. The Chief Compliance Officer shall notify each employee of the reporting
requirements of the Personal Trading Policy and deliver a copy of the Policy to
each employee.
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2. Each employee and director to whom this policy applies must submit to the
Chief Compliance Officer on an annual basis, an Annual Certification of
Compliance with the Personal Trading Policy as prescribed in the attached
Exhibit A.
The annual certification must be filed with the Chief Compliance Officer within
ten (10) calendar days after year-end.
3. Each employee and director to whom this policy applies must submit to the
Chief Compliance Officer upon commencement of employment and thereafter on an
annual basis, reports in the form prescribed in the attached Exhibit B, Personal
Securities Holdings. The annual report must be filed with the Chief Compliance
Officer within ten (10) calendar days after year-end.
4. Each employee and director, to whom this policy applies, must submit to the
Chief Compliance Officer on a quarterly basis, reports in the form prescribed in
the attached Exhibit C, Personal Securities Transactions. The quarterly report
must be filed with the Chief Compliance Officer within ten (10) calendar days
after each quarter-end. If an employee is on an approved leave of absence (i.e.:
military, maternity, etc.) over a quarter end, the Chief Compliance Officer may
waive the requirement of quarterly reporting for the employee. Circumstances
that will be considered in granting a reporting waiver include: past trading
history, current brokerage arrangements and any other relevant factors.
5. The individual granting the preclearance must document decisions regarding
the preclearance of all securities transactions in writing. The written
preclearance authorization must document that the trade does not violate any
terms of the Personal Trading Policy.
6. The Compliance Department will review all trades for violations of the ban on
short-term trading profits.
7. All employees are required to direct, in writing with a copy to the Chief
Compliance Officer, their brokers to provide the Chief Compliance Officer with
duplicate copies of confirmations of all reportable personal securities
transactions and copies of all statements for all securities accounts. The
Compliance Department will verify on a quarterly basis that all statements for
accounts reported are received.
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8. The Personal Trading Violations Committee, made up of senior management of
the firm, will review each alleged violation and determine whether or not a
violation of the policy has occurred. The Committee may decide, if appropriate,
to either impose additional sanctions for a policy violation or may choose not
to impose any sanction for a policy violation. These determinations will be made
by a unanimous vote of the Committee. All non-unanimous decisions of the
Committee will be reviewed and decided by the Chief Operating Officer of
Investment Advisors. Quarterly, the Chief Compliance Officer must report, to
Senior Management of Investment Advisors, to Investment Advisors' Board of
Directors and to the Trustees of One Group the results of each quarterly review
of employee personal trading files, status of the quarterly report of securities
transactions and the annual report of holdings, the result of the Committee
meetings and any review of the Committee decisions and the outcome of that
review.
9. The following sanctions will be imposed for violations of the Policy:
(a) Personal Security Transaction Violations
Employees will be required to break or unwind the transaction (e.g. if the trade
is a buy, the employee must sell the security or if the trade is a sell, the
employee must buy back the security) and pay a penalty of 25% of the market
value of the transaction. The penalty will be paid to a charity that the
employee chooses. The employee must provide a copy of a letter and check made
payable to the charity for the amount of the penalty to the Compliance
Department. In addition, the employee must provide a copy of the canceled check
once it is available.
This penalty will be imposed for failure to preclear a Transaction, failure to
post-clear a Transaction if required, violations of the Same Day Blackout
Period, violation of the Seven Day Blackout Period for Non-Program Trades, and
violations of the Ban on Short-Term Trading Profits.
Non-investment employees of Investment Advisors will be granted one "grace
trade" exception from the policy. A second violation will result in the
sanctions being imposed.
This exception will not be granted to employees of Investment Advisors
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who are investment personnel (i.e., all employees, except for support staff, of
any division of the Fixed Income Department or Equity Department, including the
Portfolio Management Group (PMG). Any violation of this policy will result in
the sanctions being imposed.
A third violation by any employee of Investment Advisors of section 9(a) of this
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policy will result in termination.
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(b) Failure to Provide Brokerage Statements for Reportable Accounts
Each employee will be required to pay a $100.00 fine for every missing brokerage
statement for a reportable account. Missing statements will be identified during
quarterly reviews of all personal trading files. The fine will be paid to a
charity chosen by the employee. The employee must provide to the Compliance
Department a copy of a letter and check made payable to the charity for the
amount of the penalty. In addition, the employee must provide a copy of the
cancelled check once it is available. This fine may be waived, at the discretion
of the Chief Compliance Officer, if its is determined that the employee was not
responsible for non-receipt of account statement(s).
(c) Failure to Disclose a Reportable Brokerage Account Opened During the
Calendar Year
Any employee who opens a new brokerage account and fails to report the new
brokerage account on Exhibit C at the end of the quarter in which the account
was opened will be required to pay a $100.00 fine. The fine will be paid to a
charity chosen by the employee. The employee must provide to the Compliance
Department a copy of a letter and check made payable to the charity for the
amount of the penalty. In addition, the employee must provide a copy of the
cancelled check once it is available.
(d) Failure to Disclose a Reportable Brokerage Account
Any employee who fails to disclose a reportable brokerage account either on the
Brokerage Account Information Form (at the time of employment or at the time of
the annual renewal) or on Exhibit C (quarterly), will be required to pay a
$100.00 fine for the first identified account which was not reported. The fine
will be paid to a charity chosen by the employee. The employee must provide to
the Compliance Department a copy of a letter
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and check made payable to the charity for the amount of the penalty, In
addition, the employee must provide a copy of the cancelled check once it is
available.
Any subsequent violations of this section of the policy could, at the discretion
of Senior Management, result in termination.
10. The Personal Securities Policy, a copy of each Personal Securities Holding
Report and Personal Securities Transactions Report, any written report prepared
by the Chief Compliance Officer and lists of all persons required to make
reports will be preserved by the Chief Compliance Officer for the period
required by the Investment Company Act of 1940 and The Investment Advisers Act
of 1940.
11. This section addresses the requirements for married couples who are both
employees of BOIA.
A. Commencement of Employment & Initial Reporting
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Upon commencement of employment with BOIA, all employees must complete the
initial certifications, disclosures and reporting requirements under this policy
as an individual, regardless of whether the information requested has been
previously reported.
1. Brokerage Account Information Form
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when completing the Brokerage Account Information Form, the employee must report
all accounts, which are required to be reported under the policy, even if an
account is already being reported by the spouse. For joint accounts, the
employee should indicate which spouse would be the primary contact. The person
who is listed as the primary contact for each account is responsible for
ensuring that duplicate statements and confirmations are provided to the
Compliance Department by the broker.
B. Quarterly reporting
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both spouses must sign and date the Personal Securities Transaction Report
(Exhibit C). All documentation required of either spouse may be submitted in one
package for both.
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C. Annual Reporting
----------------
Annually, each spouse must sign and submit a separate Exhibit A certifies that
each employee has read and will abide by the terms of the BOIA Personal Trading
Policy.
The annual Personal Securities Holdings Disclosure (Exhibit B) and the Brokerage
Account Information Form may be filled out jointly and must be signed by both
spouses. For all brokerage accounts, the employees must indicate which spouse is
the primary contact for purposes of this policy.
D. Preclearance & Trading
----------------------
Spouses that are listed as the primary contact for accounts noted on the
Brokerage Account Information Form will be looked to for compliance with this
section of the policy.
E. Standard of Care
----------------
the highest standard of care with respect to this policy of either spouse shall
be the standard of care required by both spouses. For example, if one spouse is
a money manger and the other spouse is in marketing, both spouses will be held
to the standard of care required of a money manager. This common standard of
care also includes trading restrictions and penalties. Using the above example,
normally an employee of the marketing department would be eligible for a first
time "Oops" violation. However, if they are a spouse of an employee that is not
eligible for an "Oops" violation, they are likewise not eligible.
F. Violations & Penalties
----------------------
If there is found to be a violation of any portion of this policy in any
reportable account(s), the violation will be counted against BOTH spouses.
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However, any monetary penalty associated with any violation will be enforced
only against the spouse listed as the primary contact on the account in which it
occurred. Please be advised that multiple violations that would constitute
termination of employment under this policy may result in BOTH spouses being
terminated.
Amended: August 2000
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[LOGO]
EXHIBIT A
BANC ONE INVESTMENT ADVISORS CORPORATION
PERSONAL TRADING POLICY
NEW EMPLOYEE CERTIFICATION OF COMPLIANCE
As an employee or director of Banc One Investment Advisors Corporation to whom
this policy applies, I certify that I have read and understand the Personal
Trading Policy. I further certify that I will comply with the requirements of
the Policy and that I disclose or report all personal securities holdings and/or
transactions required to be disclosed or reported by the Policy.
Signature _____________________________________
Print Name _____________________________________
Date _____________________________________
<PAGE>
EXHIBIT A
BANC ONE INVESTMENT ADVISORS CORPORATION
PERSONAL TRADING POLICY
NEW EMPLOYEE CERTIFICATION OF COMPLIANCE
As an employee or director of Banc One Investment Advisors Corporation to whom
this policy applies, I certify that I have read and understand the Personal
Trading Policy. I further certify that I have complied with the requirements of
the Policy and that I have disclosed or reported all personal securities
holdings and/or transactions required to be disclosed or reported by the Policy.
Signature _____________________________________
Print Name _____________________________________
Date _____________________________________
<PAGE>
EXHIBIT B
BANC ONE INVESTMENT ADVISORS CORPORATION
PERSONAL TRADING POLICY
PERSONAL SECURITIES HOLDINGS DISCLOSURE
Calendar Year Ending _______________
As an employee or director of Banc One Investment Advisors to whom this policy
applies, I am disclosing the following information regarding all personal
securities holdings to comply with the Personal Trading Policy.
1. I certify that I have no personal securities holdings that
require disclosure as of ______________________.
------------------------
Signature
------------------------
Print Name
------------------------
Date
2. I certify that the attached report containing the name, value,
par/share amount and the brokerage firm or bank (if any) which
hold, of all personal securities holdings which require
disclosure by me is accurate and complete as of
______________________________ .
------------------------
Signature
------------------------
Print Name
------------------------
Date
<PAGE>
EXHIBIT B
BANC ONE INVESTMENT ADVISORS CORPORATION
PERSONAL TRADING POLICY
PERSONAL SECURITIES HOLDINGS DISCLOSURE
(New Employees)
Employment Start Date _______________
As an employee or director of Banc One Investment Advisors to whom this policy
applies, I am disclosing the following information regarding all personal
securities holdings to comply with the Personal Trading Policy.
1. I certify that I have no personal securities holdings that
require disclosure as of ________________________ which is my
employment start date with Banc One Investment Advisors
Corporation.
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Signature
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Print Name
------------------------
Date
2. I certify that the attached report containing the name, value,
par/share amount, and the brokerage firm or bank (if any)
which hold, all personal securities holdings which require
disclosure by me is accurate and complete as of
______________________________ which is my employment start
date with Banc One Investment Advisors Corporation.
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Signature
------------------------
Print Name
------------------------
Date
<PAGE>
Exhibit C
BANC ONE INVESTMENT ADVISORS CORPORATION
PERSONAL TRADING POLICY
PERSONAL SECURITIES TRANSACTION REPORT
For the Calendar Quarter Ending _________________
As an employee or director to whom this policy applies of Banc One Investment
Advisors Corporation, I am reporting the following information, in addition to
the required duplicate confirmations and periodic statements, regarding my
personal securities transactions to comply with the Personal Trading Policy. I
further understand that the Policy does not require me to report transactions in
(1) direct obligations of the government of the United States, its agencies or
instrumentalities and (2) shares of registered investment companies.
1. I certify that no purchases or sales of personal securities that require
reporting were made during the quarter ending ___________.
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Signature
--------------------------------
Print Name
--------------------------------
Date
2. I certify that duplicate confirmations and statements were provided by
the executing broker/dealer of all personal security transaction(s)
which require reporting made during the quarter ending __________.
--------------------------------
Signature
--------------------------------
Print Name
--------------------------------
Date
3. I certify that the attached report contains the following information
regarding personal security transaction(s) made during the quarter
ending ___________ for which no duplicate confirmation or statement was
provided: name of security, price of security, amount of security,
interest rate and maturity date (if applicable) date of transaction,
nature of transaction (buy/sell), name, if any, of broker or bank used.
--------------------------------
Signature
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BANC ONE INVESTMENT ADVISORS CORPORATION
Private Placement Request Form
Employee Name: __________________________________________________
BOIA Division: ___________________________________________________
Telephone Number (Office): _________________________________________
Fax Number (Office): ______________________________________________
Describe the Private Placement Offering:
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
_____________________________________________________
Describe how you obtained access to the private placement:
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
_____________________________________________________
Please attach all supporting documentation.
<PAGE>
BANC ONE INVESTMENT ADVISORS CORPORATION
Initial Public Offering Request Form
Employee Name: __________________________________________________
BOIA Division: ___________________________________________________
Telephone Number (Office): _________________________________________
Fax Number (Office): ______________________________________________
Initial Public Offering (IPO): ________________________________________
(Name of Company and Symbol)
Describe how you obtained access to the IPO:
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
_____________________________________________________
Please attach all supporting documentation.
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Print Name
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Date
Amended: August, 2000
