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As Amended: April 1, 2000
DALTON, GREINER, HARTMAN, MAHER & CO.
CODE OF ETHICS
This Code of Ethics (the "Code") establishes rules of conduct
for persons who are associated with Dalton, Greiner, Hartman, Maher & Co. (the
"Firm"). The Code governs their personal investment and other investment-related
activities.
The basic rule is very simple: put the client's interests
first. Officers, Directors and employees owe a fiduciary duty to, among others,
the Shareholders of the Funds, to conduct their personal Securities transactions
in a manner which does not interfere with client portfolio transactions or
otherwise take unfair advantage of their relationships with the Firm. Persons
covered by the Code must adhere to these general principles as well as comply
with the Code's specific provisions.
Some of the rules are imposed specifically by law. For
example, the laws that govern investment advisers specifically prohibit
fraudulent activity, making statements that are not true or that are misleading
or omit something that is significant in the context and engaging in
manipulative practices. These are general concepts, of course, and over the
years the courts, the regulators and investment advisers issued interpretations
and established codes of conduct for their employees and others who have access
to their investment decisions and trading activities. Indeed, the rules obligate
investment advisers to adopt written rules that are reasonably designed to
prevent the illegal activities described above and must follow procedures that
will enable them to prevent such activities.
This Code is intended to assist persons associated with the
Firm in fulfilling their obligations under the law. The first part lays out who
the Code applies to, the second part deals with personal investment activities,
the third part deals with other sensitive business practices, and subsequent
parts deal with reporting and administrative procedures.
The Code is very important to the Firm and persons associated
with the Firm. Violations not only cause persons associated with the Firm
embarrassment, loss of business, legal restrictions, fines and other punishments
but for employees lead to demotion, suspension, firing, ejection from the
securities business and very large fines.
I. APPLICABILITY
(A) The Code applies to each of the following:
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1. The Firm.
2. Any officer, director or employee of the Firm or
Affiliates of the Firm (as defined below) whose job
regularly involves him in the investment process.
This includes the formulation and making of
investment recommendations and decisions, the
purchase and sale of securities for clients of the
Firm and the utilization of information about
investment recommendations, decisions and trades. Due
to the manner in which the Firm and the Affiliates of
the Firm conduct their business, every employee
should assume that he is subject to the Code unless
the Compliance Officer specifies otherwise.
3. Any natural person who controls the Firm or
Affiliates of the Firm, and who obtains information
regarding the Firm's investment recommendations or
decisions. However, a person whose control arises
only as a result of his official position with such
entity is excluded.
4. Any director, officer, general partner or person
performing a similar function for the Firm or
Affiliates of the Firm even if he has no knowledge of
and is not involved in the investment process.
(B) DEFINITIONS
1. ACCESS PERSONS. The persons described in items (A)2
and (A)3 above.
2. ACCESS PERSON ACCOUNT. Includes all advisory,
brokerage, trust or other accounts or forms of direct
beneficial ownership in which one or more Access
Person and/or one or more members of an Access
Person's immediate family have a substantial
proportionate economic interest. Immediate family
includes an Access Person's spouse and minor children
living with the Access Person. A substantial
proportionate economic interest will generally be 10%
of the principal amount in the case of an account in
which only one Access Person has an interest and 25%
of the principal amount in the case of an account in
which more than one Access Person has an interest,
whichever is first applicable. Investment
partnerships and similar indirect means of ownership
are also included.
As an exception, accounts in which one or more Access
Persons and/or their immediate family have a
substantial proportionate interest which are
maintained with persons who have no affiliation with
the Firm or Affiliates of the Firm and with respect
to which no Access Person has, in the judgment of the
Compliance Officer after
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reviewing the terms and circumstances, any direct or
indirect influence or control over the investment or
portfolio execution process are not Access Person
Accounts.
3. AFFILIATES OF THE FUNDS. Any entity controlled by or
under common control with the Firm.
4. ASSOCIATE PORTFOLIO MANAGERS. Access Persons who are
engaged in securities research and analysis for the
Firm's clients or are responsible for investment
recommendations for the Firm's clients but who are
not particularly responsible for investment decisions
with respect to any client.
5. COMPLIANCE OFFICER. The compliance officer of the
Firm shall be an individual who is an employee of
Dalton, Greiner, Hartman, Maher & Co. At present
Kenneth Greiner has been appointed Compliance
Officer.
6. COVERED PERSONS. The Firm and the Access Persons.
7. PORTFOLIO MANAGERS. Access Persons who are
principally responsible for investment decisions with
respect to any of the Firm's clients.
8. SECURITY. Any financial instrument treated as a
security for investment purposes and any related
instrument such as futures, forward or swap contract
entered into with respect to one or more securities,
a basket of or an index of securities or components
of securities. However, the term security does not
include securities issued by the Government of the
United States, bankers' acceptances, bank
certificates of deposit, commercial paper and high
quality short-term debt instruments, including
repurchase agreements or shares of registered
open-end investment companies.
II. RESTRICTIONS ON PERSONAL INVESTING ACTIVITIES
(A) FRAUDULENT OR DECEPTIVE PRACTICES
No covered person shall, in connection with the purchase or
sale, directly or indirectly, by such person of a security
held or to be acquired by the Firm for Firm clients:
(1) employ any device, scheme or artifice to
defraud the Firm's clients;
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(2) make to any Firm client any untrue statement
of a material fact or omit to the Firm's
client a material fact necessary in order to
make the statement made, in light of the
circumstances under which they are made, not
misleading;
(3) engage in any act, practice or course of
business which would operate as a fraud or
deceit upon the Firm's clients;
(4) engage in any manipulative practice with
respect to the Firm's clients;
(5) trade while in possession of material
non-public information for personal or Firm
accounts, or disclosing such information to
others in or outside the Firm who have no
need for this information.
It is a violation of federal securities laws to buy or sell
securities while in possession of material non-public
information and illegal to communicate such information to a
third party who buys or sells.
(B) BASIC RESTRICTION ON INVESTING ACTIVITIES
If a purchase or sale order is pending or under active
consideration for any client, neither the same Security nor
any related Security (such as an option, warrant or
convertible security) may be bought or sold for any Access
Person Account.
(C) INITIAL PUBLIC OFFERINGS
No Security or related Security may be acquired in an initial
public offering for any Portfolio Manager or Associate
Portfolio Manager. Pooled accounts in which the Portfolio
Manager or Associate Portfolio Manager is an investor are not
considered to be a personal security account.
(D) BLACKOUT PERIOD
No Security or related Security may be bought or sold for the
account of any Portfolio Manager or Associate Portfolio
Manager during the period commencing seven (7) calendar days
prior to and ending seven (7) calendar days after the purchase
or sale (or entry of an order for the purchase or sale) of
that Security or any related Security for the account of any
client with respect to which such person has been designated a
Portfolio Manager or Associate Portfolio Manager. Pooled
accounts in
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which the Portfolio Manager or Associate Portfolio Manager is
an investor are not considered to be a personal security
account.
(E) EXEMPT TRANSACTIONS
Participation on an ongoing basis in an issuer's dividend
reinvestment or stock purchase plan, participation in any
transaction over which no Access Person had any direct or
indirect influence or control and involuntary transactions
(such as mergers, inheritances, gifts, etc.) are exempt from
the restrictions set forth in paragraphs (A) and (C) above
without case by case preclearance under paragraph (F) below.
(F) PERMITTED EXCEPTIONS
Purchases and sales of the following Securities are exempt
from the restrictions set forth in paragraphs B and D above if
such purchases and sales comply with the preclearance
requirements of paragraph (G) below (provided that purchases
and sales of municipal securities need not comply with the
preclearance requirement of paragraph (G) below:
1. Non-convertible fixed income Securities rated at
least "A"; and
2. Municipal Securities.
In addition, the exercise of rights that were received pro
rata with other security holders is exempt if the preclearance
procedures are satisfied.
(G) PRE-CLEARANCE OF PERSONAL SECURITIES
TRANSACTIONS
No Security may be bought or sold for an Access Person Account
unless (i) the Access Person obtains prior approval from the
Compliance Officer or, in the absence of the Compliance
Officer, from a designee of the Compliance Officer; (ii) the
approved transaction is completed on the same day approval is
received; and (iii) the Compliance Officer does not rescind
such approval prior to execution of the transaction (See
paragraph I below for details of the Pre-Clearance Process.)
(H) PRIVATE PLACEMENTS
The Compliance Officer will not approve purchases or sale of
Securities that are not publicly traded, unless the Access
Person provides full details of the proposed transaction
(including written certification that the investment
opportunity did not arise by virtue of such person's
activities on
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behalf of any client) and the Compliance Officer concludes,
after consultation with one or more of the relevant Portfolio
Managers, that a Client would have no foreseeable interest in
investing in such Security.
(I) PRE-CLEARANCE PROCESS
1. No Securities may be purchased or sold for any Access
Person Account unless the particular transaction has
been approved in writing by the Compliance Officer.
The Compliance Officer shall review, not less
frequently than biweekly (once every two weeks),
reports from the trading desk (or, if applicable,
confirmations from brokers) to assure that all
transactions effected for Access Person Accounts are
effected in compliance with this Code.
2. No Securities may be purchased or sold for any Access
Person Account unless the third party broker supplies
the Compliance Officer, on a timely basis, duplicate
copies of confirmations of all personal Securities
transactions for such Access Person in the accounts
maintained with such third party broker and copies of
periodic statements for all such accounts.
3. A Trading Approval Form, attached as Exhibit B, must
be completed and submitted to the Compliance Officer
for approval prior to entry of an order.
4. After reviewing the proposed trade and the level of
potential investment interest on behalf of the Firm
in the Security in question and the Firm's restricted
lists, the Compliance Officer shall approve (or
disapprove) a trading order on behalf of an Access
Person as expeditiously as possible. The Compliance
Officer will generally approve transactions described
in paragraph (F) above unless the Security in
question or a related security is on the Restricted
List or the Compliance Officer believes for any other
reason that the Access Person Account should not
trade in such Security at such time.
5. Once an Access Person's Trading Approval Form is
approved, the execution must be on the same day. If
the Access Person's trading order request is not
approved, or is not executed on the same day it is
approved, the clearance lapses although such trading
order request may be resubmitted at a later date.
6. In the absence of the Compliance Officer, an Access
Person may submit his or her Trading Approval Form to
a designee of the Compliance Officer if the
Compliance Officer in its sole discretion
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wishes to appoint one. Trading Approval for the
Compliance Officer must be obtained from a designated
supervisory person of the Compliance Officer. In no
case will the Trading Desk accept an order for an
Access Person Account unless it is accompanied by a
signed Trading Approval Form.
7. The Compliance Officer shall review all Trading
Approval Forms, all initial, quarterly and annual
disclosure certifications and the trading activities
on behalf of the Firm with a view to ensuring that
all Covered Persons are complying with the spirit as
well as the detailed requirements of this Code.
III. OTHER INVESTMENT-RELATED RESTRICTIONS
(A) GIFTS
No Access Person shall accept any gift or other item of more
than $100 in value from any person or entity that does
business with or on behalf of the Firm.
(B) SERVICE AS A DIRECTOR
No Portfolio Manager or Assistant Portfolio Manager shall
commence service on the Board of Directors of a publicly
traded company or any company in which the Firm has an
interest without prior authorization from the Compliance
Officer based upon a determination that the Board service
would not be inconsistent with the interests of the Firm.
IV. REPORT AND ADDITIONAL COMPLIANCE PROCEDURES
(A) Every Covered Person must submit to the Compliance Officer
reports (forms of which are appended as Exhibit C) containing
the information set forth below with respect to transactions
in any Security in which such Covered Person has or by reason
of such transactions acquires, any direct or indirect
beneficial ownership (as defined in Exhibit D) in the
Security; provided, however, that:
1. a Covered Person need not make a report with respect
to any transaction effected for any account over
which such person does not have any direct or
indirect influence or control; and
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2. a Covered Person will be deemed to have complied with
the quarterly requirements of this Article IV insofar
as the Compliance Officer receives in a timely
fashion duplicate monthly or quarterly brokerage
statements on which all transactions required to be
reported hereunder are described.
(B) Initial Holdings Reports. No later than 10 calendar
days after the person becomes an Access Person, the
following information:
(i) The title, number of shares and principal amount
of each Covered Security in which the Access Person
had any direct or indirect beneficial ownership when
the person became an Access Person;
(ii) The name of any broker, dealer or bank with whom
the Access Person maintained an account in which any
securities were held for the direct or indirect
benefit of the Access Person as of the date the
person became an Access Person; and
(iii) The date that the report is submitted by the
Access Person
(C) Quarterly Transaction Reports. No later than 10
calendar days after the end of a calendar quarter,
the following information:
(1) With respect to any transaction during the
quarter in a Covered Security in which the Access
Person had any direct or indirect beneficial
ownership:
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(a) The date of the transaction, the
title and number of shares and the
principal amount of each Security
involved;
(b) The nature of the transaction
(i.e., purchase, sale or any other
type of acquisition or
disposition);
(c) The price at which the transaction
was effected;
(d) The name of the broker, dealer or
bank with or through whom the
transaction was effected; and
(e) The date that the report is
submitted by the Access Person.
(2) With respect to any account established by
the Access Person in which any securities
were held during the quarter for the direct
or indirect benefit of the Access Person:
(a) The name of the broker, dealer or
bank with whom the Access Person
established the account;
(b) The date the account was
established; and
(c) The date that the report is
submitted by the Access Person.
(D) Annual Holdings Reports. Annually, the following
information (which information must be current as of
a date no more than 30 calendar days before the
report is submitted):
(1) The title, number of shares and principal
amount of each Security in which the Access
Person had any direct or indirect beneficial
ownership;
(2) The name of any broker, dealer or bank with
whom the Access Person maintains an account
in which any securities are held for the
direct or indirect benefit of the Access
Person; and
(3) The date that the report is submitted by the
Access Person.
(E) Any report submitted to comply with the requirements of this
Article IV may contain a statement that the report shall not
be construed as
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admission by the person making such report that he has any
direct or indirect benefit ownership in the Security to which
the report relates.
(F) Upon commencement of employment with the Firm, each Access
Person shall be required to disclose all current personal
Securities holdings contained in any Access Person Account in
which such Access Person has an interest.
(G) Annually each Covered Person must certify on a report (the
form of which is appended as Exhibit E) that he has read and
understood the Code and recognizes that he is subject to such
Code. In addition, annually each Covered Person must certify
that he has disclosed or reported all personal Securities
transactions required to be disclosed or reported under the
Code and that he is not subject to any regulatory disability.
V. SANCTIONS
Upon discovering that a Covered Person has not complied with the
requirements of this Code, the Management Committee may impose whatever
sanctions within its power the Committee deems appropriate, including,
among other things, recommendations of disgorgement of profit, censure,
suspension or termination of employment. Material violations of
requirements of this Code by employees of Covered Persons and any
sanctions imposed in connection therewith shall be reported not less
frequently than quarterly to the Management Committee.
VI. EXCEPTIONS
The Compliance Committee of the Firm reserves the right to decide, on a
case-by-case basis, exceptions to any provisions under this Code. Any
exceptions made hereunder will be maintained in writing by the
Compliance Committee and presented to the Management Committee at its
next scheduled meeting.
VII. PRESERVATION OF DOCUMENTS
This Code, a copy of each report by a Covered Person, any written
report made hereunder by the Firm, Affiliates of the Firm or the
Compliance Officer, and lists of all persons required to make or review
reports, shall be preserved with the records of the Firm for a five
year period in an easily accessible place.
VIII. OTHER LAWS, RULES AND STATEMENTS OF POLICY
Nothing contained in this Code shall be interpreted as relieving any
Covered Person from acting in accordance with the provision of any
applicable law, rule or regulation or any other statement of policy or
procedure governing the conduct of such person adopted by Firm.
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IX. FURTHER INFORMATION
If any person has any question with regard to the applicability of the
provisions of this Code generally or with regard to any Securities
transaction or transactions, he should consult the Compliance Officer.
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Exhibit B
PRE-CLEARANCE TRADING APPROVAL FORM
I, ___________________________________________________ (name), am an Access
Person and seek pre-clearance to engage in the transaction described below:
Acquisition or Disposition (circle one)
Name of Account: ____________________________________________
Account Number: ____________________________________________
Date of Request: ____________________________________________
Security: ____________________________________________
Amount or # of Shares: ____________________________________________
Broker: ____________________________________________
If the transaction involves a Security that is not publicly traded, a
description of proposed transaction, source of investment opportunity and any
potential conflicts of interest:
I hereby certify that, to the best of my knowledge, the transaction described
herein is not prohibited by the Funds' Code of Ethics dated ___________ and that
the opportunity to engage in the transaction did not arise by virtue of my
activities on behalf of any Client.
Signature: ______________________________________
Print Name:
Approved or Disapproved (Circle One)
Date of Approval:
Signature: ______________________________________
Print Name:
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If approval is granted, please forward this form to the trading desk (or if a
third party broker is permitted, to the Compliance Officer) for immediate
execution.
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Exhibit C
QUARTERLY TRANSACTION REPORT
Report Submitted by: _____________________________________________________
Print Your Name
This transaction report (the "Report") is submitted pursuant
to Section IV(C) of the Code of Ethics of the Funds and supplies information
with respect to transactions in any Security in which you may be deemed to have,
or by reason of such transaction acquire, any direct or indirect beneficial
ownership interest for the period specified below. If you were not employed by
us during this entire period, amend the dates specified below to cover your
period of employment.
Unless the context otherwise requires, all terms used in the
Report shall have the same meaning as set forth in the Code of Ethics dated
_______________, ____.
If you have no reportable transactions, sign and return this
page only. If you have reportable transactions, complete, sign and return page 2
and any attachments.
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I HAD NO REPORTABLE SECURITIES TRANSACTIONS DURING THE PERIOD
__________, 199_ THROUGH _________, 199_. I CERTIFY THAT I AM FULLY FAMILIAR
WITH THE CODE OF ETHICS AND THAT TO THE BEST OF MY KNOWLEDGE THE INFORMATION
FURNISHED IN THIS REPORT IS TRUE AND CORRECT.
Signature
_________________________________
Position
_________________________________
Date
_________________________________
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Exhibit C
INITIAL TRANSACTION REPORT
Report Submitted by:__________________________________________________________
Print Your Name
The following table supplies the information required by
Section IV(B) of the Code of Ethics dated _____________ for the period specified
below.
<TABLE>
<CAPTION>
Name of the
Securities Whether Purchase, Broker/Dealer
(Name and Date of Sale, Short Sale, Quantity of Price Per Share with or through Nature of
Symbol) Transaction or Other Type of Securities or Other Unit whom the Ownership of
---------- ----------- Disposition or ----------- --------------- Transaction Securities
Acquisition was Effected -----------
----------- ------------
<S> <C> <C> <C> <C> <C> <C>
</TABLE>
To the extent specified above, I hereby disclaim beneficial
ownership of any security listed in this Report or in brokerage statements or
transaction confirmations provided by you.
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I CERTIFY THAT I AM FULLY FAMILIAR WITH THE CODE OF ETHICS AND
THAT TO THE BEST OF MY KNOWLEDGE THE INFORMATION FURNISHED IN THIS REPORT IS
TRUE AND CORRECT FOR THE PERIOD OF __________, ____ THROUGH ____, ___.
Signature _________________________ Date_______________________
Position _________________________
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Exhibit C
ANNUAL TRANSACTION REPORT
Report Submitted
by:__________________________________________________________
Print Your Name
The following table supplies the information required by
Section IV(D) of the Code of Ethics dated _____________ for the period specified
below.
<TABLE>
<CAPTION>
Name of the
Whether Purchase, Broker/Dealer
Securities Date of Sale, Short Sale, Quantity of Price Per Share with or through Nature of
(Name and Transaction or Other Type of Securities or Other Unit whom the Ownership of
Symbol) ----------- Disposition or ---------- ------------- Transaction Securities
------- Acquisition was Effected -----------
----------- ------------
<S> <C> <C> <C> <C> <C> <C>
</TABLE>
To the extent specified above, I hereby disclaim beneficial
ownership of any security listed in this Report or in brokerage statements or
transaction confirmations provided by you.
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I CERTIFY THAT I AM FULLY FAMILIAR WITH THE CODE OF ETHICS AND
THAT TO THE BEST OF MY KNOWLEDGE THE INFORMATION FURNISHED IN THIS REPORT IS
TRUE AND CORRECT FOR THE PERIOD OF __________, ____ THROUGH ____, ___.
Signature _________________________ Date_______________________
Position _________________________
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Exhibit D
BENEFICIAL OWNERSHIP
For purposes of the attached Code of Ethics, "beneficial
ownership" shall be interpreted in the same manner as it would be in determining
whether a person is subject to the provisions of Section 16 of the Securities
Exchange Act of 1934 and the rules and regulations thereunder, except the
determination of direct or indirect beneficial ownership shall apply to all
securities that a Covered Person has or acquires. The term "beneficial
ownership" of securities would include not only ownership of securities held by
a Covered Person for his own benefit, whether in bearer form or registered in
his name or otherwise, but also ownership of securities held for his benefit by
others (regardless of whether or how they are registered) such as custodians,
brokers, executors, administrators, or trustees (including trusts in which he
has only a remainder interest), and securities held for his account by pledges,
securities owned by a partnership in which he is a member if he may exercise a
controlling influence over the purchase, sale of voting of such securities, and
securities owned by any corporation or similar entry in which he owns securities
if the shareholder is a controlling shareholder of the entity and has or shares
investment control over the entity's portfolio.
Ordinarily, this term would not include securities held by
executors or administrators in estates in which a Covered Person is a legatee or
beneficiary unless there is a specified legacy to such person of such securities
or such person is the sole legatee or beneficiary and there are other assets in
the estate sufficient to pay debts ranking ahead of such legacy, or the
securities are held in the estate more than a year after the decedent's death.
Securities held in the name of another should be considered as
"beneficially" owned by a Covered Person where such person enjoys "financial
benefits substantially equivalent to ownership." The Securities and Exchange
Commission has said that although the final determination of beneficial
ownership is a question to be determined in the light of the facts of the
particular case, generally a person is regarded as the beneficial owner of
securities held in the name of his or her spouse and their minor children.
Absent special circumstances such relationship ordinarily results in such person
obtaining financial benefits substantially equivalent to ownership, e.g.,
application of the income derived from such securities to maintain a common
home, or to meet expenses that such person otherwise would meet from other
sources, or the ability to exercises a controlling influence over the purchase,
sale or voting of such securities.
A Covered Person also may be regarded as the beneficial owner
of securities held in the name of another person, if by reason of any contract,
understanding, relationship, agreement, or other agreement, he obtains therefrom
financial benefits substantially equivalent to those of ownership.
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A Covered Person also is regarded as the beneficial owner of
securities held in the name of a spouse, minor children or other person, even
though he does not obtain therefrom the aforementioned benefits of ownership, if
he can vest or revest title in himself at once or at some future time.
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Exhibit E
ANNUAL CERTIFICATION OF CODE OF ETHICS
A. I (a Covered Person) hereby certify that I have read and
understood the Code of Ethics dated _____________, and
recognize that I am subject to its provisions. In addition, I
hereby certify that I have complied with the requirements of
the Code of Ethics and that I have disclosed or reported all
personal Securities transactions required to be disclosed or
reported under the Code of Ethics;
B. Within the last ten years there have been no complaints or
disciplinary actions filled against me by any regulated
securities or commodities exchange, any self-regulatory
securities or commodities organization, any attorney general,
or any governmental office or agency regulating insurance
securities, commodities or financial transactions in the
United States, in any state of the United States, or in any
other country;
C. I have not within the last ten years been convicted of or
acknowledged commission of any felony or misdemeanor arising
out of my conduct as an employee, salesperson, officer,
director, insurance agent, broker, dealer, underwriter,
investment manager or investment advisor; and
D. I have not been denied permission or otherwise enjoined by
order, judgment or decree of any court of competent
jurisdiction, regulated securities or commodities exchange,
self-regulatory securities or commodities organization or
other federal or state regulatory authority from acting as an
investment advisor, securities or commodities broker or
dealer, commodity pool operator or trading advisor or as an
affiliated person or employee of any investment company, bank,
insurance company or commodity broker, dealer, pool operator
or trading advisor, or from engaging in or continuing any
conduct or practice in connection with any such activity or
the purchase or sale of any security.
Print Name: ________________________________________
Signature: ________________________________________
Date: ________________________________________
