THE PUTNAM FUNDS
Code of Ethics
Each of The Putnam Funds (the "Funds") has determined to adopt this Code of
Ethics with respect to certain types of personal securities transactions by
officers and Trustees of the Funds which might be deemed to create possible
conflicts of interest and to establish reporting requirements and
enforcement procedures with respect to such transactions.
I. Rules Applicable to Officers and Trustees
Affiliated with Putnam Investments, Inc.
A. Incorporation of Adviser's Code of Ethics. The provisions of the Code
of Ethics for employees of Putnam Investments, Inc. and its Subsidiaries
(the "Putnam Investments Code of Ethics"), which is attached as Appendix A
hereto, are hereby incorporated herein as the Funds' Code of Ethics
applicable to officers and Trustees of the Funds who are employees of the
Funds or officers, directors or employees of Putnam Investments, Inc. or
its subsidiaries. A violation of the Putnam Investments Code of Ethics
shall constitute a violation of the Funds' Code.
B. Reports. Officers and Trustees of each of the Funds who are made
subject to the Putnam Investments Code of Ethics pursuant to the preceding
paragraph shall file the reports required by the Putnam Investments Code of
Ethics with the Compliance Director designated therein. A report filed
with the Compliance Director shall be deemed to be filed with each of the
Funds of which the reporting individual is an officer or Trustee.
C. Review. (1) The Compliance Director shall compare the reported
personal securities transactions with completed and contemplated portfolio
transactions of each of the Funds to determine whether a violation of this
Code may have occurred. Before making any determination that a violation
has been committed by any person, the Compliance Director shall give such
person an opportunity to supply additional explanatory material.
(2) If the Compliance Director determines that a violation of this Code has
or may have occurred, he shall submit his written determination, together
with the confidential quarterly report and any additional explanatory
material provided by the individual, to the Chairman of the Funds, who
shall make an independent determination of whether a violation has
occurred.
D. Sanctions. If the Chairman of the Funds finds that a violation has
occurred, he shall report the violation and any sanction imposed under the
Putnam Code of Ethics to the Trustees of the Funds who may impose such
additional sanctions as they deem appropriate. If a securities transaction
of the Chairman is under consideration, the Vice Chairman of the Funds
shall act in all respects in the manner prescribed herein for the Chairman.
II. Rules Applicable to Unaffiliated Trustees
A. Definitions.
(1) "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. Application of this definition is explained in
more detail in Exhibit A hereto.
(2) "Control" means the power to exercise a controlling influence over the
management or policies of a company, unless such power is solely the result
of an official position with such company.
(3) "Interested Trustee" means a Trustee of a Fund who is an "interested
person" of the Fund within the meaning of the Investment Company Act.
(4) "Purchase or sale of a security" includes, among other things, the
writing of an option to purchase or sell a security.
(5) "Security" shall have the same meaning as that set forth in Section
2(a)(36) of the Investment Company Act (in effect, all securities) except
that it shall not include securities issued by the Government of the United
States or an agency thereof, bankers' acceptances, bank certificates of
deposit, commercial paper and shares of registered open-end investment
companies.
(6) "Unaffiliated Trustee" means a Trustee who is not made subject to the
Putnam Investments Code of Ethics pursuant to Part I hereof.
B. Prohibited Purchases and Sales. No Unaffiliated Trustee of any of the
Funds shall purchase or sell, directly or indirectly, any security in which
he has or by reason of such transaction acquires, any direct or indirect
beneficial ownership and which to his actual knowledge at the time of such
purchase or sale:
(1) is being considered for purchase or sale by the Fund;
(2) is being purchased or sold by the Fund; or
(3) was purchased or sold by the Fund within the most recent five days if
such person participated in the recommendation to, or the decision by,
Putnam Management to purchase or sell such security for the Fund.
C. Exempted Transactions. The prohibitions of Section II-B of this Code
shall not apply to:
(1) purchases or sales effected in any account over which the Unaffiliated
Trustee has no direct or indirect influence or control;
(2) purchases or sales which are non-volitional on the part of either the
Unaffiliated Trustee or the Fund;
(3) purchases which are part of an automatic dividend reinvestment plan;
(4) purchases effected upon the exercise of rights issued by an issuer pro
rata to all holders of a class of its securities, to the extent such rights
were acquired from such issuer, and sales of such rights so acquired;
(5) purchases or sales other than those exempted in (1) through (4) above
which do not cause the Unaffiliated Trustee to gain improperly a personal
benefit through his relationship with the Fund and are only remotely
potentially harmful to a Fund because they would be very unlikely to affect
a highly institutional market, and are previously approved by the
Compliance Director under the Putnam Code of Ethics or the Chairman of the
Funds, which approval shall be confirmed in writing.
D. Reporting. (1) Whether or not one of the exemptions listed in Section
II-C applies, every Unaffiliated Trustee of a Fund shall file with the
Chairman of the Funds a report containing the information described in
Section II-D(2) of this Code with respect to transactions in any security
in which such Unaffiliated Trustee has, or by reason of such transaction
acquires, any direct or indirect beneficial ownership, if such Trustee, at
the time of that transaction, knew or, in the ordinary course of fulfilling
his official duties as a Trustee of the Fund, should have known that,
during the 15-day period immediately preceding or after the date of the
transaction by the Trustee:
(a) such security was or is to be purchased or sold by the Fund or
(b) such security was or is being considered for purchase or sale by the
Fund;
provided, however, that an Unaffiliated Trustee shall not be required to
make a report with respect to transactions effected for any account over
which such person does not have any direct or indirect influence or
control.
(2) Every report shall be made not later than 10 days after the end of the
calendar quarter in which the transaction to which the report relates was
effected, and shall contain the following information:
(a) The date of the transaction, the title and the 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; and
(d) The name of the broker, dealer or bank with or through whom the
transaction was effected.
(3) Every report concerning a purchase or sale prohibited under Section
II-B hereof with respect to which the reporting person relies upon one of
the exemptions provided in Section IIC shall contain a brief statement of
the exemption relied upon and the circumstances of the transaction.
(4) Any such report may contain a statement that the report shall not be
construed as an admission by the person making such report that he has any
direct or indirect beneficial ownership in the security to which the report
relates.
(5) Notwithstanding anything to the contrary contained herein, an
Unaffiliated Trustee who is an Interested Trustee shall also file the
reports required by Rule 17j-1(c)(1) under the Investment Company Act of
1940.
E. Review. (1) The Chairman of the Funds shall compare the reported
personal securities transactions with completed and contemplated portfolio
transactions of the Funds to determine whether any transaction ("Reviewable
Transactions") listed in Section II-B (disregarding exemptions provided by
Section II-C(1) through (5)) may have occurred.
(2) If the Chairman determines that a Reviewable Transaction may have
occurred, he shall then determine whether a violation of this Code may have
occurred, taking into account all the exemptions provided under Section
II-C. Before making any determination that a violation has occurred, the
Chairman shall give the person involved an opportunity to supply additional
information regarding the transaction in question.
F. Sanctions. If the Chairman determines that a violation of this Code
has occurred, he shall so advise a committee consisting of the Unaffiliated
Trustees, other than the person whose transaction is under consideration,
and shall provide the committee with a report of the matter, including any
additional information supplied by such person. The committee may impose
such sanction as it deems appropriate.
III. Miscellaneous.
A. Amendments to The Putnam Companies Code of Ethics. Any amendment to
the Putnam Companies Code of Ethics shall be deemed an amendment to Section
I-A of this Code effective 30 days after written notice of such amendment
shall have been received by the Chairman of the Funds, unless the Trustees
of the Funds expressly determine that such amendment shall become effective
at an earlier or later date or shall not be adopted.
B. Records. The Funds shall maintain records in the manner and to the
extent set forth below, which records may be maintained on microfilm under
the conditions described in Rule 31a-2(f)(1) under the Investment Company
Act and shall be available for examination by representatives of the
Securities and Exchange Commission.
(1) A copy of this Code and any other code which is, or at any time within
the past five years has been, in effect shall be preserved in an easily
accessible place;
(2) A record of any violation of this Code and of any action taken as a
result of such violation shall be preserved in an easily accessible place
for a period of not less than five years following the end of the fiscal
year in which the violation occurs;
(3) A copy of each report made by an officer or Trustee pursuant to this
Code shall be preserved for a period of not less than five years from the
end of the fiscal year in which it is made, the first two years in an
easily accessible place; and
(4) A list of all person who are, or within the past five years have been,
required to make reports pursuant to this Code shall be maintained in an
easily accessible place.
C. Confidentiality. All reports of securities transactions and any other
information filed with any Fund pursuant to this Code shall be treated as
confidential, but are subject to review as provided herein and by personnel
of the Securities and Exchange Commission.
D. Interpretation of Provisions. The Directors and Trustees may from time
to time adopt such interpretations of this Code as they deem appropriate.
E. Delegation by Chairman. The Chairman of the Funds may from time to
time delegate any or all of his responsibilities under this Code, either
generally or as to specific instances, to such officer or Trustee of the
Funds as he may designate.
As revised
July 8, 1994
