Code of Conduct
All of us within the Capital organization are responsible for maintaining the
very highest ethical standards when conducting business. In keeping with these
standards, we must never allow our own interests to be placed ahead of our
shareholders' and clients' interests.
Over the years we have earned a reputation for the highest integrity. Regardless
of lesser standards that may be followed through business or community custom,
we must observe exemplary standards of honesty and integrity.
Reporting Violations
If you know of any violation of our Code of Conduct, you have a
responsibility to report it. Deviations from controls or procedures
that safeguard the company, including the assets of shareholders and
clients, should also be reported.
You can report confidentially to:
Your manager or department head
CGC Audit Committee:
Wally Stern -- Chairman
Donnalisa Barnum
David Beevers
Jim Brown
Larry P. Clemmensen
Roberta Conroy
Bill Hurt -- (emeritus)
Sonny Kamm
Mike Kerr
Victor Kohn
John McLaughlin
Don O'Neal
Tom Rowland
John Smet
Antonio Vegezzi
Shaw Wagener
Kelly Webb
o Mike Downer or any other lawyer in the CGC Legal Group
o Don Wolfe of Deloitte & Touche LLP (CGC's auditors).
CGC Gifts Policy -- Conflicts of Interest
A conflict of interest occurs when the private interests of associates
interfere or could potentially interfere with their responsibilities at
work. Associates must not place themselves or the company in a position
of actual or potential conflict. Associates may not accept gifts worth
more than $100, excessive business entertainment, loans, or anything
else involving personal gain from those who conduct business with the
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company. In addition, a business entertainment event exceeding $200 in
value should not be accepted unless the associate receives permission
from the Gifts Policy Committee.
Reporting -- Although the limitations on accepting gifts applies to all
associates as described above, some associates will be asked to fill
out quarterly reports. If you receive a reporting form, you must report
any gift exceeding $50 (although it is recommended that you report all
gifts received) and business entertainment in which an event exceeds
$75.
Gifts Policy Committee
The Gifts Policy Committee oversees administration of and compliance
with the Policy.
Insider Trading
Antifraud provisions of the federal securities laws generally prohibit
persons while in possession of material nonpublic information from
trading on or communicating the information to others. Sanctions for
violations can include civil injunctions, permanent bars from the
securities industry, civil penalties up to three times the profits made
or losses avoided, criminal fines and jail sentences.
While investment research analysts are most likely to come in contact
with material nonpublic information, the rules (and sanctions) in this
area apply to all CGC associates and extend to activities both within
and outside each associate's duties.
Personal Investing Policy
As an associate of the Capital Group companies, you may have access to
confidential information. This places you in a position of special
trust.
You are associated with a group of companies that is responsible for
the management of many billions of dollars belonging to mutual fund
shareholders and other clients. The law, ethics and our own policy
place a heavy burden on all of us to ensure that the highest standards
of honesty and integrity are maintained at all times.
There are several rules that must be followed to avoid possible
conflicts of interest in personal securities transactions.
All Associates
Information regarding proposed or partially completed plans by CGC
companies to buy or sell specific securities must not be divulged to
outsiders.
Favors or preferential treatment from stockbrokers may not be accepted.
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Associates may not subscribe to any initial public offering (IPO).
Generally, this prohibitionapplies to spouses of associates and any
family member residing in the same household. However, an associate may
request that the Personal Investing Committee consider granting an
exception under special circumstances.
Covered Persons
Associates who have access to investment information in connection with
their regular duties are generally considered "covered persons." If you
receive a quarterly personal securities transactions report form, you
are a covered person. You should take the time to review this policy,
as ongoing interpretations of the policy will be explained therein.
Covered persons must conduct their personal securities transactions in
such a way that they do not conflict with the interests of the funds
and client accounts. This policy also includes securities transactions
of family members living in the covered person's household and any
trust or custodianship for which the associate is trustee or custodian.
A conflict may occur if you, a family member in the same household, a
trust or custodianship for which you are trustee or custodian have a
transaction in a security when the funds or client accounts are
considering or concluding a transaction in the same security.
Additional rules apply to "investment personnel" including portfolio
counselors/managers, research analysts, traders, portfolio control
associates, and investment administration personnel (see below).
Pre-clearance of Securities Transactions
Before buying or selling securities, covered persons must check with
the CGC Legal Group based in LAO. (You will generally receive a
response within one business day.) Unless a shorter period is
specified, clearance is good for two trading days (including the day
you check). If you have not executed your transaction within this
period, you must again pre-clear your transaction.
Covered persons must promptly submit quarterly reports of certain
transactions. Transactions of securities (including fixed-income
securities) or options (see below) must be pre-cleared as described
above and reported except for: open-end investment companies (mutual
funds); money market instruments with maturities of one year or less;
direct obligations of the U.S. Government, bankers' acceptances, CDs or
other commercial paper; commodities; and options or futures on
broad-based indices. Covered persons must also report transactions made
by family members in their household and by those for which they are a
trustee or custodian.. Note that investments in private placements and
venture capital partnerships are also subject to preclearance and
reporting. Reporting forms will be supplied at the appropriate times
and must be submitted by the date indicated on the form
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In addition, the following transactions must be reported but need not
have been pre- cleared: gifts or bequests (either receiving or giving)
of securities must be reported (sales of securities received as a gift
must be both precleared and reported); transactions in debt instruments
rated "A" or above by at least one national rating service; sales
pursuant to tender offers; and dividend reinvestment plan purchases
(provided the purchase pursuant to such plan is made with dividend
proceeds only).
Personal investing should be viewed as a privilege, not a right. As
such, limitations may beplaced on the number of pre-clearances and/or
transactions as deemed appropriate by the Personal Investing Committee.
Brokerage Accounts
Covered persons should inform their stockbrokers that they are employed
by an investment adviser, trust company or affiliate of either. U.S.
brokers are subject to certain rules designed to prevent favoritism
toward such accounts. Associates may not accept negotiated commission
rates which they believe may be more favorable than the broker grants
to accounts with similar characteristics. In addition, covered persons
must direct their brokers to send duplicate confirmations and copies of
all periodic statements on a timely basis to The Legal Group of The
Capital Group Companies, Inc. All documents received are kept strictly
confidential.
[If extraneous information is included on an associate's statements
(e.g., checking account information or other information that is not
subject to the policy), the associate might want to establish a
separate account solely for transactions subject to the policy.]
Annual disclosure of personal securities holdings
Covered persons will be required to disclose all personal securities
holdings upon commencement of employment (or upon becoming a covered
person) and thereafter on an annual basis. Reporting forms will be
supplied for this purpose.
Annual Recertification
All access persons will be required to certify annually that they have
read and understood the Personal Investing Policy and recognize that
they are subject thereto.
Additional Rules for Investment Personnel
Disclosure of ownership of recommended securities -- Ownership of
securities that are held professionally as well as personally will be
reviewed on a periodic basis by the Legal Group and may also be
reviewed by the applicable Management Committee and/or Investment
Committee or Subcommittee. In addition, to the extent that disclosure
has not already been made by the Legal Group to the applicable
Management Committee and/or Investment Committee or Subcommittee, any
associate who is in a position to recommend the purchase or sale of
securities by the fund or client accounts that s/he personally owns
should first disclose such ownership either in writing (in a
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company write-up) or orally (when discussing the company at investment
meetings) prior to making a recommendation.1
Blackout period - Investment personnel may not buy or sell a security
within at least seven calendar days before and after a fund or client
account that his or her company manages transacts in that security.
Profits resulting from transactions occurring within this time period
are subject to special review and may be subject to disgorgement.
Ban on short-term trading profits -- Investment personnel are
prohibited from profiting from the purchase and sale or sale and
purchase of the same (or equivalent) securities within 60 days. This
restriction applies to the purchase of an option and the exercise of
the option within 60 days.
Service as a director -- Investment personnel must obtain prior
authorization of the investment committee of the appropriate management
company or CGC Management Committee before serving on the board of
directors of publicly traded companies. This can be arranged by calling
the LAO Legal Group.
Personal Investing Committee
Any questions or hardships that result from these policies or requests
for exceptions should be referred to CGC's Personal Investing Committee
by calling the LAO Legal Group.
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1 Note that this disclosure requirement is consistent with both AIMR
standards as well as the ICI Advisory Group Guidelines.
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