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Exhibit (p)(3)
Policy 4.02 Employee Brokerage Accounts,
as amended August 18, 2000,
from
Banc One Investment Advisors Corporation's
Compliance Manual
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4.02 Employee Brokerage Accounts
Banc One Investment Advisors Corporation/ Compliance Manual
Section 204-2(a)(12) of The Investment Advisers Act of 1940 requires Banc One
Investment Advisors Corporation to maintain a record of every transaction in a
security by an "advisory representative" in which a direct or indirect
beneficial ownership is acquired. In order to comply with this regulation as
well as section of The Investment Company Act of 1940, Investment Advisors
requires each employee to complete an Brokerage Account Form and report security
transactions in affiliated (Banc One Securities Corporation, Banc One Capital
Corporation, etc.) or non-affiliated brokerage accounts to the Compliance
Department. Brokerage accounts include accounts of the employee, accounts of
employee family members including spouse, minor children or adults living in the
same household, accounts where the employee is named as trustee, or any account
in which the employee exercises discretion (i.e. self-directed IRA's, custodial
accounts). It is not necessary to report brokerage accounts which hold only
registered investment company securities.
In order to meet the requirements set forth above, each employee must contact
the broker/dealer and request that the broker/dealer, not the employee, send
duplicate confirmations of each security transaction and copies of brokerage
statements to the Compliance Department. The Compliance Officer will review
employee statements, as needed, for compliance with requirements specified in
other policies of Investment Advisors. Those accounts selected will be carefully
reviewed for any transactions which appear to be exceptions to firm policy or
regulations. The Compliance Officer must obtain a written explanation from the
employee and must note any disciplinary action taken against the employee on the
report.
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Every employee will complete the Brokerage Account Information form at the time
of their initial employment with Investment Advisors. In addition, on an annual
basis, each employee will be required to update their Brokerage Account Form.
Employees will confirm previously reported accounts, provide information on new
accounts and report the closing of any accounts. Employees should also contact
the Compliance Department immediately upon opening or closing a brokerage
account that was not reported at the time of their initial employment or during
an annual account update.
The Compliance Officer must maintain the reviewed account statements in a
separate file entitled, "Employee Account Review" in employee order. These files
must be preserved for a continuous period of seven years.
Amended: August, 2000
BROKERAGE ACCOUNT INFORMATION
(New Employees)
Information must be provided for all brokerage accounts including those of the
employee, the employees' immediate family members (spouse, children, adults
living in the same household), accounts for which the employee acts as trustee,
or any other type of account for which the employee exercises discretion (i.e.
self-directed IRA's, custodial accounts). Accounts which hold only registered
investment company securities do not need to be reported.
Broker Account Account Relationship
Name Name Number to BOIA Employee
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Signature: ___________________________________________
Print Name: ___________________________________________
Date: ______________________
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Amended: August, 2000
BROKERAGE ACCOUNT INFORMATION
(Annual Update)
Information must be provided for all brokerage accounts including those of the
employee, the employees' immediate family members (spouse, children, adults
living in the same household), accounts for which the employee acts as trustee,
or any other type of account for which the employee exercises discretion (i.e.
self-directed IRA's, custodial accounts). Accounts which hold only registered
investment company securities do not need to be reported.
Existing Accounts
Broker Account Account Relationship
Name Name Number to BOIA Employee
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Accounts Opened During the Past Year
Broker Account Account Relationship
Name Name Number to BOIA Employee
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Accounts Closed During the Past Year
Broker Account Account Relationship
Name Name Number to BOIA Employee
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Date: _______________
Signature: ___________________________________
Print Name: ___________________________________
Amended: August, 2000
