<PAGE>
Exhibit p(2)
PERSONAL INVESTMENT POLICY
FOR
SALOMON SMITH BARNEY INC.
IN CONNECTION WITH ITS ACTIVITY
AS DISTRIBUTOR OF
CERTAIN REGISTERED INVESTMENT COMPANIES
Salomon Smith Barney Inc. ("SSB") has adopted this policy on securities
transactions in order to provide policies and procedures consistent with Rule
17j-1 under the Investment Company Act of 1940 to prevent fraudulent or
manipulative practices with respect to purchases or sales of securities held or
to be acquired by those U.S. registered investment companies ("Funds") advised
or managed by SSB Citi Asset Management Group ("SSB Citi")1 for which SSB acts
as distributor. ALL DIRECTORS AND OFFICERS OF SSB WHO, IN THE ORDINARY COURSE OF
BUSINESS, MAKE, PARTICIPATE IN OR OBTAIN INFORMATION REGARDING, THE PURCHASE OR
SALE OF SECURITIES BY THE FUNDS, OR WHOSE FUNCTIONS OR DUTIES IN THE ORDINARY
COURSE OF BUSINESS RELATE TO THE MAKING OF ANY RECOMMENDATION TO THE FUNDS
REGARDING THE PURCHASE OR SALE OF SECURITIES AND WHO ARE NOT SUBJECT TO THE SSB
CITI PERSONAL INVESTMENT POLICY ARE COVERED PERSONS UNDER THIS POLICY.
I. STATEMENT OF PRINCIPLES - The fundamental standard to be followed in
personal securities transactions is that Covered Persons may not take
inappropriate advantage of their positions. All personal securities
transactions by Covered Persons shall adhere to the requirements of this
policy and shall be conducted in such a manner as to avoid any actual or
potential conflict of interest, the appearance of such a conflict, or the
abuse of the person's position of trust and responsibility. While this
policy is designed to address both identified conflicts and potential
conflicts, it cannot possibly be written broadly enough to cover all
potential situations. In this regard, Covered Persons are expected to
adhere not only to the letter, but also the spirit of the policies
contained herein.
Covered Persons are reminded that they also are subject to other
Citigroup policies, including policies on insider trading, the purchase
and sale of securities listed on any applicable SSB restricted list, the
receipt of gifts and service as a director of a publicly traded company.
Covered Persons must never trade in a security or commodity while in
possession of material, non-public information about the issuer or the
market for those securities or commodities, even if the Covered Person
has satisfied all other requirements of this policy.
The reputation of SSB and its employees for straightforward practices and
integrity is a priceless asset, and all employees have the duty and
obligation to support and maintain it when conducting their personal
securities transactions.
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1 The investment advisory entities of SSB Citi covered by this policy include:
Salomon Brothers Asset Management Inc.; SSB Citi Fund Management LLC; Smith
Barney Asset Management Division of Salomon Smith Barney Inc.; Travelers
Investment Management Company; and the Citibank Global Asset Management
Division of Citibank, N.A. and Citicorp Trust, N.A.-California.
II. APPLICABILITY - Each Covered Person must comply with all of the
provisions of this policy. The personal investment policies, procedures
and restrictions referred to herein also apply to a Covered Person's
spouse and minor children. The policies also apply to any other account
over which the Covered Person is deemed to have beneficial ownership.
This includes: accounts of any immediate family members sharing the same
household as the Covered Person; accounts of persons or other third
parties for whom the Covered Person exercises investment discretion or
gives investment advice; a legal vehicle in which the Covered Person has
a direct or indirect beneficial interest and has power over investment
decisions; accounts for the benefit of a third party (e.g., a charity)
which may be directed by the Covered Person (other than in the capacity
of an employee); and any account over which the Covered Person may be
deemed to have control. For a more detailed description of beneficial
ownership, see Exhibit A attached hereto.
These policies place certain restrictions on the ability of a Covered
Person to purchase or sell securities that are being or have been
purchased or sold by the Funds. The restrictions also apply to securities
that are "related" to a security being purchased or sold by the Funds. A
"related security" is one whose value is derived from the value of
another security (e.g., a warrant, option or an indexed instrument).
SECURITIES are defined as stocks, notes, bonds, closed-end mutual funds,
debentures, and other evidences of indebtedness, including senior debt,
subordinated debt, investment contracts, commodity contracts, futures and
all derivative instruments such as options, warrants and indexed
instruments, or, in general, any interest or instrument commonly known as
a "security."
III. ENFORCEMENT - It is the responsibility of each Covered Person to act in
accordance with a high standard of conduct and to comply with the
policies and procedures set forth in this document. SSB takes seriously
its obligation to monitor the personal investment activities of its
employees. Any violation of this policy by Covered Persons will be
considered serious, and may result in disciplinary action, which may
include the unwinding of trades, disgorgement of profits, monetary fine
or censure, and suspension or termination of employment.
IV. OPENING AND MAINTAINING EMPLOYEE ACCOUNTS - All employee brokerage
accounts, including spouse accounts, accounts for which the Covered
Person is deemed to have beneficial ownership, and any other accounts
over which the Covered Person and/or spouse exercise control, must be
maintained either at SSB or at Citicorp Investment Services ("CIS").(2)
For spouses or other persons who, by reason of their employment, are
required to conduct their securities, commodities or other financial
transactions in a manner inconsistent with this policy, or in other
exceptional circumstances, Covered Persons may submit a written request
for an exemption to the Compliance Department. If approval is granted,
copies of trade confirmations and monthly statements must be sent to the
Compliance Department. In addition, all other provisions of this policy
will apply.
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2 This requirement will become effective as to all employees on a date to be
determined by the Compliance Department and may be subject to a phase-in
implementation process.
V. EXCLUDED ACCOUNTS AND TRANSACTIONS - The following types of
accounts/transactions need not be maintained at SSB or CIS, nor are they
subject to the other restrictions of this policy:
1. Accounts at outside mutual funds that hold only shares of
open-end funds purchased directly from that fund company. Note:
transactions relating to closed-end funds are subject to the
pre-clearance, blackout period and other restrictions of this
policy;
2. Estate or trust accounts in which a Covered Person or related
person has a beneficial interest, but no power to affect
investment decisions. There must be no communication between the
account(s) and the Covered Person with regard to investment
decisions prior to execution. The Covered Person must direct the
trustee/bank to furnish copies of confirmations and statements
to the Compliance Department;
3. Fully discretionary accounts managed by either an internal or
external registered investment adviser are permitted and may be
custodied away from SSB and CIS if (i) the Covered Person
receives permission from the Director of Compliance, and (ii)
there is no communication between the manager and the Covered
Person with regard to investment decisions prior to execution.
The Covered Person must designate that copies of trade
confirmations and monthly statements be sent to the Compliance
Department;
4. Covered Persons may participate in direct investment programs
which allow the purchase of securities directly from the issuer
without the intermediation of a broker/dealer provided that the
timing and size of the purchases are established by a
pre-arranged, regularized schedule (e.g., dividend reinvestment
plans). Covered Persons must pre-clear the transaction at the
time that the dividend reinvestment plan is being set up.
Covered Persons also must provide documentation of these
arrangements and direct periodic (monthly or quarterly)
statements to the Compliance Department; and
5. In addition to the foregoing, the following types of securities
are exempted from pre-clearance, blackout periods, reporting and
short-term trading requirements: open-ended mutual funds;
open-end unit investment trusts; U.S. Treasury bills, bonds and
notes; mortgage pass-throughs (e.g. Ginnie Maes) that are direct
obligations of the U.S. government; bankers acceptances; bank
certificates of deposit; commercial paper; and high quality
short-term debt instruments (meaning any instrument that has a
maturity at issuance of less than 366 days and that is rated in
one of the two highest rating categories by a nationally
recognized statistical rating organization, such as S&P or
Moody's), including repurchase agreements.
VI. SECURITIES HOLDING PERIOD/SHORT-TERM TRADING - Securities transactions
must be for investment purposes rather than for speculation.
Consequently, employees may not profit from the purchase and sale, or
sale and purchase, of the same or equivalent securities within sixty (60)
calendar days, calculated on a First In, First Out (FIFO) basis (i.e.,
the security may be sold on the 61st day). Citigroup securities received
as part of a Covered Person's compensation are not subject to the 60-day
holding period. All profits from short-term trades are subject to
disgorgement. However, with the prior written approval of the Director of
Compliance, and only in rare and/or unusual circumstances, a Covered
Person may execute a short-term trade that results in a significant loss
or in break-even status.
VII. PRE-CLEARANCE - Covered Persons must pre-clear all personal securities
transactions (see Section V for a listing of accounts, transactions and
securities that do not require pre-clearance). A copy of the
pre-clearance form is attached as Exhibit B. IN ADDITION, COVERED PERSONS
ARE PROHIBITED FROM ENGAGING IN MORE THAN TWENTY (20) TRANSACTIONS IN ANY
CALENDAR MONTH, EXCEPT WITH THE PRIOR WRITTEN APPROVAL FROM THE DIRECTOR
OF COMPLIANCE. A transaction must not be executed until the Covered
Person has received the necessary approval. Pre-clearance is valid only
on the day it is given. If a transaction is not executed on the day
pre-clearance is granted, it is required that pre-clearance be sought
again on a subsequent day (i.e., open orders, such as limit orders, good
until cancelled orders and stop-loss orders, must be pre-cleared each day
until the transaction is effected). In connection with obtaining approval
for any personal securities transaction, Covered Persons must describe in
detail any factors that might be relevant to an analysis of the
possibility of a conflict of interest. Any trade that violates the
pre-clearance process may be unwound at the Covered Person's expense, and
the Covered Person will be required to absorb any resulting loss and to
disgorge any resulting profit.
VIII. BLACKOUT PERIODS - No Covered Person shall purchase or sell, directly or
indirectly, any security in which he/she has, or by reason of the
transaction acquires, any direct or indirect beneficial ownership if
he/she has knowledge at the time of such transaction that the security is
being purchased or sold, or is being considered for purchase or sale, by
a Fund. In addition, a Covered Person may not buy or sell any securities
for personal accounts on the same day that a Fund about which the Covered
Person is likely to have trading or portfolio information (as determined
by the Compliance Department) trades in that security.
Any violation of the foregoing provision will require the Covered
Person's trade to be unwound, with the Covered Person absorbing any
resulting loss and disgorging any resulting profit. Please be reminded
that, regardless of the provisions set forth above, all employees are
always prohibited from effecting personal securities transactions based
on material, non-public information.
Blackout period requirements shall not apply to any purchase or sale, or
series of related transactions involving the same or related securities,
involving 500 or fewer shares in the aggregate if the issuer has a market
capitalization (outstanding shares multiplied by the current price per
share) greater than $10 billion and is listed on a U.S. Stock Exchange or
NASDAQ. Note: Pre-clearance is still required. Under certain
circumstances, the Compliance Department may determine that a Covered
Person may not rely upon this "Large Cap/De Minimis" exemption. In such a
case, the Covered Person will be notified prior to or at the time the
pre-clearance request is made.
IX. PROHIBITED TRANSACTIONS - The following transactions by Covered Persons
are prohibited without the prior written approval from the Compliance
Director:
1. The purchase of private placements; and
2. The acquisition of any securities in an initial public offering
(new issues of municipal debt securities may be acquired subject
to the other requirements of this policy (e.g., pre-clearance).)
X. TRANSACTIONS IN OPTIONS AND FUTURES - Covered Persons may buy or sell
derivative instruments such as individual stock options, options and
futures on indexes and options and futures on fixed-income securities,
and may buy or sell physical commodities and futures and forwards on such
commodities. These transactions must comply with all of the policies and
restrictions described in this policy, including pre-clearance, blackout
periods, transactions in Citigroup securities and the 60-day holding
period. However, the 60-day holding period does not apply to individual
stock options that are part of a hedged position where the underlying
stock has been held for more than 60 days and the entire position
(including the underlying security) is closed out.
XI. PROHIBITED RECOMMENDATIONS - No Covered Person shall recommend or execute
any securities transaction by any Fund without having disclosed, in
writing, to SSB Citi's Chief Investment Officer, or designee, any direct
or indirect interest in such securities or issuers, except for those
securities purchased pursuant to the "Large Cap/De Minimis" exemption
described in Section VIII above. Prior written approval of such
recommendation or execution also must be received from the Chief
Investment Officer, or designee. The interest in personal accounts could
be in the form of:
1. Any direct or indirect beneficial ownership of any securities of
such issuer;
2. Any contemplated transaction by the person in such securities;
3. Any position with such issuer or its affiliates; or
4. Any present or proposed business relationship between such
issuer or its affiliates and the person or any party in which
such person has a significant interest.
XII. TRANSACTIONS IN CITIGROUP SECURITIES - Unless a Covered Person is a
member of a designated group subject to more restrictive provisions, or
is otherwise notified to the contrary, the Covered Person may trade in
Citigroup securities without restriction (other than the pre-clearance
and other requirements of this policy), subject to the limitations set
forth below.
Covered Persons whose jobs are such that they know about Citigroup's
quarterly earnings prior to release may not engage in any transactions
in Citigroup securities during the "blackout periods" beginning on the
first day of a calendar quarter and ending on the second business day
following the release of earnings for the prior quarter.
Stock option exercises are permitted during a blackout period (but the
simultaneous exercise of an option and sale of the underlying stock is
prohibited). With regard to exchange traded options, no transactions
in Citigroup options are permitted except to close or roll an option
position that expires during a blackout period. Charitable
contributions of Citigroup securities may be made during the blackout
period, but an individual's private foundation may not sell donated
Citigroup common stock during the blackout period. "Good `til
cancelled" orders on Citigroup stock must be cancelled before entering
a blackout period and no such orders may be entered during a blackout
period.
No Covered Person may engage at any time in any personal transactions
in Citigroup securities while in possession of material non-public
information. Investments in Citigroup securities must be made with a
long-term orientation rather than for speculation or for the
generation of short-term trading profits. In addition, please note
that Covered Persons may not engage in the following transactions:
o Short sales of Citigroup securities;
o Purchasesor sales of options ("puts" or "calls") on Citigroup
securities, except writing a covered call at a time when the
securities could have been sold under this policy;
o Purchases or sales of futures on Citigroup securities; or
o Any transactions relating to Citigroup securities that might
reasonably appear speculative.
The number of Citigroup shares a Covered Person is entitled to in the
Citigroup Stock Purchase Plan is not treated as a long stock position
until such time as the Covered Person has given instructions to
purchase the shares of Citigroup. Thus, Covered Persons are not
permitted to use options to hedge their financial interest in the
Citigroup Stock Purchase Plan.
Contributions into the firm's 401(k) Plan are not subject to the
restrictions and prohibitions described in this policy.
XIII. ACKNOWLEDGEMENT AND REPORTING REQUIREMENTS - All new Covered Persons must
certify that they have received a copy of this policy, and have read and
understood its provisions. In addition, all Covered Persons must:
1. Acknowledge receipt of the policy and any modifications thereof,
in writing (see Exhibit C for the form of Acknowledgement);
2. Within 10 days of becoming a Covered Person, disclose in writing
all information with respect to all securities beneficially
owned and any existing personal brokerage relationships (Covered
Persons must also disclose any new brokerage relationships
whenever established). Such information should be provided on
the form attached as Exhibit D;
3. Direct their brokers to supply, on a timely basis, duplicate
copies of confirmations of all personal securities transactions
(Note: this requirement may be satisfied through the
transmission of automated feeds);
4. Within 10 days after the end of each calendar quarter, provide
information relating to securities transactions executed during
the previous quarter for all securities accounts (Note: this
requirement may be satisfied through the transmission of
automated feeds);
5. Submit an annual holdings report containing similar information
that must be current as of a date no more than 30 days before
the report is submitted, and confirm at least annually all
brokerage relationships and any and all outside business
affiliations (Note: this requirement may be satisfied through
the transmission of automated feeds or the regular receipt of
monthly brokerage statements); and
6. Certify on an annual basis that he/she has read and understood
the policy, complied with the requirements of the policy and
that he/she has pre-cleared and disclosed or reported all
personal securities transactions and securities accounts
required to be disclosed or reported pursuant to the
requirements of the policy.
DISCLAIMER OF BENEFICIAL OWNERSHIP - The reports described in Items 4 and
5 above may contain a statement that the reports shall not be construed
as an admission by the person making the reports that he/she has any
direct or indirect beneficial ownership in the securities to which the
reports relate.
XIV. HANDLING OF DISGORGED PROFITS - Any amounts that are paid/disgorged by a
Covered Person under this policy shall be donated by SSB to one or more
charities. Amounts donated may be aggregated by SSB and paid to such
charity or charities at the end of each year.
XV. CONFIDENTIALITY - All information obtained from any Covered Person
pursuant to this policy shall be kept in strict confidence, except that
such information will be made available to the Securities and Exchange
Commission or any other regulatory or self-regulatory organization or to
the Fund Boards of Directors to the extent required by law, regulation or
this policy.
XVI. OTHER LAWS, RULES AND STATEMENTS OF POLICY - Nothing contained in this
policy shall be interpreted as relieving any person subject to the policy
from acting in accordance with the provision of any applicable law, rule
or regulation or any statement of policy or procedure governing the
conduct of such person adopted by Citigroup, its affiliates and
subsidiaries.
XVII. RETENTION OF RECORDS - All records relating to personal securities
transactions hereunder and other records meeting the requirements of
applicable law, including a copy of this policy and any other policies
covering the subject matter hereof, shall be maintained in the manner and
to the extent required by applicable law, including Rule 17j-1 under the
1940 Act. The Compliance Department shall have the responsibility for
maintaining records created under this policy.
XVIII. MONITORING - SSB takes seriously its obligation to monitor the personal
investment activities of its employees and to review the periodic reports
of all Covered Persons. Employee personal investment transaction activity
will be monitored by the Compliance Department. All noted deviations from
the policy requirements will be referred back to the employee for
follow-up and resolution (with a copy to be supplied to the employee's
supervisor).
XIX. EXCEPTIONS TO THE POLICY - Any exceptions to this policy must have the
prior written approval of the Director of Compliance. Any questions about
this policy should be directed to the Compliance Department.
XX. BOARD REVIEW - Fund Management and SSB shall provide to the Board of
Directors of each Fund, on a quarterly basis, a written report of all
material violations of this policy, and at least annually, a written
report and certification meeting the requirements of Rule 17j-1 under the
1940 Act.
XXI. AMENDMENTS - Unless otherwise noted herein, this policy shall become
effective as to all Covered Persons on July 5, 2000. This policy may be
amended from time to time by the Compliance Department. Any material
amendment of this policy shall be submitted to the Board of Directors of
each Fund for approval in accordance with Rule 17j-1 under the 1940 Act.
July 5, 2000
<PAGE>
EXHIBIT A
EXPLANATION OF BENEFICIAL OWNERSHIP
You are considered to have "Beneficial Ownership" of Securities if you have or
share a direct or indirect "Pecuniary Interest" in the Securities.
You have a "Pecuniary Interest" in Securities if you have the opportunity,
directly or indirectly, to profit or share in any profit derived from a
transaction in the Securities.
The following are examples of an indirect Pecuniary Interest in Securities:
1. Securities held by members of your immediate family sharing the same
household; however, this presumption may be rebutted by convincing
evidence that profits derived from transactions in these Securities
will not provide you with any economic benefit.
"Immediate family" means any child, stepchild, grandchild, parent,
stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law,
son-in-law, daughter-in-law, brother-in-law, or sister-in-law, and
includes any adoptive relationship.
2. Your interest as a general partner in Securities held by a general or
limited partnership.
3. Your interest as a manager-member in the Securities held by a limited
liability company.
You do not have an indirect Pecuniary Interest in Securities held by a
corporation, partnership, limited liability company or other entity in which you
hold an equity interest, unless you are a controlling equityholder or you have
or share investment control over the Securities held by the entity.
The following circumstances constitute Beneficial Ownership by you of Securities
held by a trust:
1. Your ownership of Securities as a trustee where either you or members
of your immediate family have a vested interest in the principal or
income of the trust.
2. Your ownership of a vested interest in a trust.
3. Your status as a settlor of a trust, unless the consent of all of the
beneficiaries is required in order for you to revoke the trust.
The foregoing is a summary of the meaning of "beneficial ownership". For
purposes of the attached policy, "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
<PAGE>
<TABLE>
EXHIBIT B
SALOMON SMITH BARNEY INC. ("SSB")
COVERED PERSON TRADE PRE-APPROVAL FORM
(PAGE 1)
INSTRUCTIONS:
Covered Persons are required to submit this form to the Compliance Department of SSB Citi Asset Management Group ("SSB
Citi") prior to placing a trade. The Compliance Department will notify the Covered Person as to whether or not
pre-approval is granted. Pre-approval is effective only on the date granted.
I. COVERED PERSON INFORMATION
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Covered Person Name: Phone Number:
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Account Title:
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Account Number:
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Fund(s) for which employee is a Covered Person:
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II. SECURITY INFORMATION
IPO [ ] Yes [ ] No PRIVATE PLACEMENT [ ] Yes [ ] No
<CAPTION>
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Security Type-e.g., If Sale, Date First No. Large Cap
Security Name common stock, etc. Ticker Buy/Sell Acquired(1) Shares/Units Stock?2
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<S> <C> <C> <C> <C> <C>
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III. CERTIFICATION
I certify that I will not effect the transaction(s) described above unless and until pre-clearance approval is obtained
from the Compliance Department. I further certify that, except as described on an attached page, to the best of my
knowledge, the proposed transaction(s) will not result in a conflict of interest with any Fund managed by SSB Citi. I
further certify that, to the best of my knowledge, there are no pending orders for any security listed above or any
related security for any Funds for which I am considered a Covered Person. The proposed transaction(s) are consistent
with all firm policies regarding employee personal securities transactions.
SIGNATURE ----------------------------------- DATE --------------------------
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FOR USE BY THE COMPLIANCE DEPARTMENT
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[ ] Yes [ ] No [ ] Yes [ ] No Reason not granted:
ARE SECURITIES RESTRICTED? PRE-APPROVAL
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COMPLIANCE DEPARTMENT SIGNATURE: Date: Time:
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1. All securities sold must have been held for at least 60 days.
2. For purposes of SSB's personal trading policies, a Large Cap Exemption applies to transactions involving 500 or
fewer shares in aggregate and the stock is one that is listed on a U.S. stock exchange or NASDAQ and whose issuer
has a market capitalization (outstanding shares multiplied by current price) of more than $10 billion.
</TABLE>
<PAGE>
EXHIBIT C
PERSONAL INVESTMENT POLICY
FOR
SALOMON SMITH BARNEY INC.
IN CONNECTION WITH ITS ACTIVITY AS DISTRIBUTOR
OF
CERTAIN REGISTERED INVESTMENT COMPANIES
ACKNOWLEDGMENT
I acknowledge that I have received and read the Personal Investment Policy For
Salomon Smith Barney Inc. in connection with its activity as Distributor of
Certain Registered Investment Companies dated July 5, 2000. I understand the
provisions of the Personal Investment Policy as described therein and agree to
abide by them.
COVERED PERSON NAME (PRINT): ------------------------
SIGNATURE: --------------------
DATE: --------------------
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SOCIAL SECURITY DATE OF HIRE:
NUMBER:
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JOB FUNCTION & SUPERVISOR:
TITLE:
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LOCATION:
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FLOOR AND/OR ZONE: TELEPHONE
NUMBER:
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NASD REGISTERED EMPLOYEE (Please check one) [ ] Yes [ ] No
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If REGISTERED, list Registration \ License:
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This Acknowledgment form must be completed and returned to the Compliance
Department of Salomon Smith Barney Inc., 7 World Trade Center, 30th floor, New
York, NY 10048.
<PAGE>
EXHIBIT D
SALOMON SMITH BARNEY INC. PERSONAL INVESTMENT POLICY
FINANCIAL SERVICES FIRM DISCLOSURE AND INITIAL REPORT OF SECURITIES HOLDINGS
THIS REPORT MUST BE SIGNED, DATED AND RETURNED WITHIN 10 DAYS OF EMPLOYMENT
TO THE COMPLIANCE DEPARTMENT OF SALOMON SMITH BARNEY INC., 7 WORLD TRADE
CENTER, 30TH FLOOR
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COVERED PERSON NAME: ------------------- DATE OF EMPLOYMENT: --------------
-----------------------------------------------------------------------------
BROKERAGE ACCOUNTS:
[ ] I do not have a beneficial interest in any account(s) with any financial
services firm.
[ ] I maintain the following account(s) with the financial services firm(s)
listed below (attach additional information if necessary-e.g., a brokerage
statement). Please include the information required below for any broker,
dealer or bank where an account is maintained which holds securities for
your direct or indirect benefit as of the date you began your employment.
Name of Financial Service(s) Firm and Address Account Title Account Number
SECURITIES HOLDINGS:
Complete the following (or attach a copy of your most recent statement(s))
listing all of your securities holdings, with the exception of open-ended mutual
funds and U.S Government securities if:
o You own securities which are held by financial services firm(s) as described
above. If you submit a copy of a statement, it must include all of the
information set forth below. Please be sure to include any additional
securities purchased since the date of the brokerage statement which is
attached. Use additional sheets if necessary.
o Your securities are not held with a financial service(s) firm (e.g., dividend
reinvestment programs and private placements).
-------------------------------------------------------------------------------
Title of Ticker # of Principal Held Financial
Security Symbol Shares Amt. Since Services Firm
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
[ ] I have no securities holdings to report.
I certify that I have received the Salomon Smith Barney Inc. Personal Investment
Policy and have read it and understood its contents. I further certify that the
above represents a complete and accurate description of my brokerage account(s)
and securities holdings as of my date of employment.
Signature: ----------------------------- Date of Signature: -----------------
