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Exhibit (p)(1)
PIMCO FUNDS: MULTI-MANAGER SERIES
CODE OF ETHICS
Effective June 12, 2000
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INTRODUCTION
Fiduciary Duty
This Code of Ethics is based on the principle that you, as a trustee or
officer of PIMCO Funds: Multi-Manager Series (the Trust), owe a fiduciary duty
to the shareholders (the Shareholders) of the funds of the Trust (the Funds).
Accordingly, you must avoid activities, interests and relationships that might
interfere or appear to interfere with making decisions in the best interests of
our Shareholders.
At all times, you must:
1. Place the interests of our Shareholders first. In other words, as a
fiduciary you must scrupulously avoid serving your own personal
interests ahead of the interests of our Shareholders. You may not
cause a Fund to take action, or not to take action, for your personal
benefit rather than the benefit of the Shareholders. For example, you
would violate this Code if you caused a Fund to purchase a Security
you owned for the purpose of increasing the price of that Security.
You would also violate this Code if you made a personal investment in
a Security that might be an appropriate investment for a Fund without
first considering the Security as an investment for the Fund.
2. Conduct all of your personal Securities transactions in full
compliance with this Code. The Trust encourages you and your family
to develop personal investment programs. However, you must not take
any action in connection with your personal investments that could
cause even the appearance of unfairness or impropriety. Accordingly,
you must comply with the policies and procedures set forth in this
Code under the heading Personal Securities Transactions. In addition,
you must comply with all other applicable laws and regulations
including those concerning insider trading. Doubtful situations
should be resolved against your personal trading.
3. Avoid taking inappropriate advantage of your position. The receipt of
investment opportunities, gifts or gratuities from persons seeking
business with the Trust directly or on behalf of a Fund, Shareholder
or affiliate could call into question the independence of your
business judgment. Accordingly, you must comply with the policies and
procedures set forth in this Code under the heading Fiduciary Duties.
Doubtful situations should be resolved against your personal interest.
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PFMMS Code of Ethics
Page 2
Application
Certain of the officers and Trustees of the Trust are officers of PIMCO
Advisors L.P. (PIMCO Advisors) and/or officers of PIMCO Funds Distributors LLC
(PFD), the distributor of the Funds. PIMCO Advisors or one of its affiliated
subpartnerships (the Subpartnerships) reviews and determines investment policies
for each Fund and manages the day-to-day investment affairs of the Funds,
including selecting securities to be purchased, held and sold, and placing
orders for portfolio transactions, except for the International Fund for which
Blairlogie Capital Management (Blairlogie) provides the investment advisory and
portfolio management services. PIMCO Advisors, PFD, the Subpartnerships and
Blairlogie each has its own Code of Ethics pursuant to Rule 17j-1 under the
Investment Company Act of 1940, as amended (the "Act"). Each of those Codes of
Ethics has been or will be approved by the Trustees of the Trust, including a
majority of the independent Trustees. Any Trustee or officer of the Trust or
any person who would otherwise be subject to this Code, who is subject to the
Code of Ethics of PIMCO Advisors, PFD, a Subpartnership or Blairlogie and who
complies with such Code, shall not be subject to the provisions of this Code.
Appendices
The following appendices are attached to this Code and are a part of this
Code:
I. Form for Preclearance of Securities transactions.
II. Form for Initial and Annual Report of Personal Securities
holdings.
III. Form for report of Personal Securities Transactions/Brokerage
Accounts Report.
IV. Form for Acknowledgment of Receipt of this Code.
V. Form for Annual Certification of Compliance with this Code.
VI. Definitions.
Questions
Questions regarding this Code should be addressed to a Compliance Officer. As
of the effective date of this Code, the Compliance Officers are Jeffrey M.
Sargent, Deborah P. Brennan and Newton B. Schott, Jr. The Compliance Committee
is comprised of the Compliance Officers and Stephen J. Treadway.
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PFMMS Code of Ethics
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PERSONAL SECURITIES TRANSACTIONS
Trading in General
You may not engage, and you may not permit any other person or entity to
engage, in any purchase or sale of a Security (other than an Exempt Security) in
which you have, or by reason of the transaction will acquire, Beneficial
Ownership, unless (i) the transaction is an Exempt Transaction or (ii) you have
complied with the procedures set forth under Preclearance Procedures.
Securities
The following are Securities:
Any note, stock, treasury stock, bond, debenture, evidence of indebtedness,
certificate of interest or participation in any profit-sharing agreement,
collateral-trust certificate, preorganization certificate or subscription,
transferable share, investment contract, voting-trust certificate, certificate
of deposit for a security, fractional undivided interest in oil, gas, or other
mineral rights, any put, call, straddle, option or privilege on any security
(including a certificate of deposit) or on any group or index of securities
(including any interest therein or based on the value thereof), or any put,
call, straddle, option or privilege entered into on a national securities
exchange relating to foreign currency, or, in general, any interest or
instrument commonly known as a security, or any certificate of interest or
participation in, temporary or interim certificate for, receipt for, guarantee
of, or warrant or right to subscribe to or purchase, any security.
The following are not Securities:
Commodities, futures and options traded on a commodities exchange, including
currency futures. However, futures and options on any group or index of
Securities are Securities.
Purchase or Sale of a Security
The purchase or sale of a Security includes, among other things, the writing of
an option to purchase or sell a Security.
Exempt Securities
The following are Exempt Securities:
1. Direct obligations of the Government of the United States.
2. Bankers' acceptances, bank certificates of deposit, commercial paper,
and high quality short-term debt instruments (defined as 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), including
repurchase agreements.
3. Shares of registered open-end investment companies.
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PFMMS Code of Ethics
Page 4
Beneficial Ownership
The following section is designed to give you a practical guide with respect
to Beneficial Ownership. However, for purposes of this Code, Beneficial
Ownership shall be interpreted in the same manner as it would be under Rule 16a-
1(a)(2) under the Securities Exchange Act of 1934 (the "Exchange Act") in
determining whether a person is the beneficial owner of a security for purposes
of Section 16 of the Exchange Act and the rules and regulations thereunder.
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 beneficial interest in a trust.
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PFMMS Code of Ethics
Page 5
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.
Exempt Transactions
The following are Exempt Transactions:
1. Any transaction in Securities in an account over which you do not have
any direct or indirect influence or control. There is a presumption
that you can exert some measure of influence or control over accounts
held by members of your immediate family sharing the same household,
but this presumption may be rebutted by convincing evidence.
2. Purchases of Securities under dividend reinvestment plans.
3. Purchases of Securities by exercise of rights issued to the holders of
a class of Securities pro rata, to the extent they are issued with
respect to Securities of which you have Beneficial Ownership.
4. Acquisitions or dispositions of Securities as the result of a stock
dividend, stock split, reverse stock split, merger, consolidation,
spin-off or other similar corporate distribution or reorganization
applicable to all holders of a class of Securities of which you have
Beneficial Ownership.
5. Subject to the restrictions on participation in private placements set
forth below under Private Placements, acquisitions or dispositions of
Securities of a private issuer. A private issuer is an issuer which
has no outstanding publicly traded Securities, and no outstanding
Securities which are convertible into or exchangeable for, or
represent the right to purchase or otherwise acquire, publicly traded
Securities. However, you will have Beneficial Ownership of Securities
held by a private issuer whose equity Securities you hold, unless you
are not a controlling equityholder and do not have or share investment
control over the Securities held by the entity.
6. Any transaction in Securities (other than Exempt Securities) by a
Trustee of the Trust who is not an "interested person" (see Appendix
VI) of the Trust within the meaning of Section 2(a)19 of the Act, so
long as the Trustee did not know and, in the ordinary course of
fulfilling his or her official duties as a Trustee, should not have
known, that during the 15-day period immediately preceding or after
the date of the transaction, such Securities were purchased or sold,
or considered for purchase or sale, on behalf of a Fund.
7. Transactions in Securities traded within the preceding fifteen days
for a Fund provided that (i) the trading for the Fund has been
completed and (ii) the trade in which the Trustee or officer has or
acquires Beneficial Ownership is not contrary to the trade done for
the Fund.
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PFMMS Code of Ethics
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8. Such other classes of transactions as may be exempted from time to
time by the Compliance Committee based upon a determination that the
transactions do not involve any realistic possibility of a violation
of Rule 17j-1 under the Investment Company Act of 1940, as amended.
The Compliance Committee may exempt designated classes of transactions
from any of the provisions of this Code except the provisions set
forth below under Reporting.
9. Such other specific transactions as may be exempted from time to time
by a Compliance Officer. On a case-by-case basis when no abuse is
involved, a Compliance Officer may exempt a specific transaction from
any of the provisions of this Code except the provisions set forth
below under Reporting.
Additional Exempt Transactions
The following classes of transactions have been designated as Exempt
Transactions by the Compliance Committee:
10. Purchases or sales of up to $100,000 per calendar month per issuer of
fixed-income Securities.
11. Any purchase or sale of fixed-income Securities issued by agencies or
instrumentalities of, or unconditionally guaranteed by, the Government
of the United States.
12. Purchases or sales of up to $1,000,000 per calendar month per issuer
of fixed-income Securities issued by qualified foreign governments.
A qualified foreign government is a national government of a developed
foreign country with outstanding fixed-income securities in excess of
$50 billion.
13. Purchases or sales of up to 2,000 shares per day, per issuer, of
large-cap issuers.
A large-cap issuer is an issuer with a total market capitalization in
excess of $1 billion and an average daily trading volume during the
preceding three calendar months, on the principal securities exchange
(including NASDAQ) on which its shares are traded, in excess of
100,000 shares.
Information concerning large-cap issuers is available on the Internet.
If you are unsure whether a security was issued by a large-cap issuer,
contact a Compliance Officer.
14. Purchases or sales of up to the lesser of 1,000 shares or $10,000 per
calendar week, per issuer, of stock of issuers other than large-cap
issuers.
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PFMMS Code of Ethics
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15. Purchases or sales of exchange-traded options on broadly based indices
and units and/or exchange-traded trusts representing a group, or a
basket, of Securities (e.g., HHH, QQQ, SPY).
16. Any purchase or sales of shares of registered closed-end investment
companies other than Municipal Advantage Fund and PIMCO Commercial
Mortgage Trust Inc.
17. If you are not an "Investment Person", as defined in Appendix VI,
short sales of any Securities otherwise permitted hereunder or puts,
calls, or options where the underlying amount of Securities controlled
is an amount otherwise permitted hereunder.
CAUTION
The qualified foreign governments, large-cap issuers and broadly-based
indices that are exempt may change from time to time. Accordingly, you may
purchase Securities in an Exempt Transaction, only to find that you cannot sell
them later in an Exempt Transaction. In that case, you will be able to sell
them only if you preclear the sale in compliance with the procedures set forth
in the Code.
Circumstances Requiring Preclearance
If you have (or wish to acquire) Beneficial Ownership of Securities which are
not Exempt Securities and which cannot be sold in Exempt Transactions, such
Securities may be sold (or acquired) in compliance with the procedures set forth
below under Preclearance Procedures.
The Compliance Committee may designate as Exempt Transactions purchases and
sales of Securities which are purchased or sold in compliance with the
procedures set forth below under Preclearance Procedures.
Preclearance Procedures
If a Securities transaction requires preclearance:
1. The Securities may not be purchased or sold if at the time of
preclearance there is a pending buy or sell order on behalf of a Fund
in the same Security of an equivalent Security of if you knew or
should have known that a Fund would be trading in that security or an
equivalent Security on the same day.
An equivalent Security of a given Security is: (i) a Security issuable
upon exercise, conversion or exchange of the given Security, or (ii) a
Security exercisable to purchase, convertible into or exchangeable for
the given Security, or (iii) a Security otherwise representing an
interest in or based on the value of the given Security.
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PFMMS Code of Ethics
Page 8
2. The Securities may not be purchased or sold during the period which
begins seven days before and ends seven days after the day on which a
Fund trades in the same Security, or an equivalent Security; except
that you may, if you preclear the transaction, (i) trade same way to a
Fund after its trading is completed or (ii) trade opposite way to a
Fund before its trading is commenced.
If you preclear a Securities transaction and trade same way to a Fund
before its trading is commenced, the transaction is not a violation of
this Code unless you knew or should have known that the Fund would be
trading in that Security or an equivalent Security within seven days
after your trade.
3. The Securities may be purchased or sold only if you have asked a
Compliance Officer to preclear the purchase or sale, the Compliance
Officer has given you preclearance in writing, and the purchase or
sale is executed by the close of business on the day preclearance is
given. Preclearance will not be given unless a determination is made
that the purchase or sale complies with this Code and the foregoing
restrictions. The form for requesting preclearance is attached to
this Code as Appendix I.
Initial Public Offerings
If you are an Investment Person of the Trust, its investment adviser or any
sub-adviser, you may not acquire Beneficial Ownership of any Securities in an
Initial Public Offering, unless you have received the prior written approval of
a Compliance Officer.
For the purposes hereof, "Initial Public Offering" means an offering of
securities registered under the Securities Act of 1933 (the "Securities Act"),
the issuer of which, immediately before the registration, was not subject to the
reporting requirements of Sections 13 or 15(d) of the Exchange Act.
Private Placements
If you are an Investment Person of the Trust, you may not acquire Beneficial
Ownership of any Securities in a Private Placement, unless you have received the
prior written approval of the Compliance Committee. Approval will be not be
given unless a determination is made that the investment opportunity should not
be reserved for one or more Funds, and that the opportunity to invest has not
been offered to you by virtue of your position.
For the purposes hereof, "Private Placement" means an offering that is
exempted from registration under the Securities Act pursuant to Section 4(2) or
Section 4(6) or pursuant to Rule 504, 505 or 506 under the Securities Act.
If you have acquired Beneficial Ownership of Securities in a Private
Placement, you must disclose your investment when you play a part in any
consideration of an investment by a Fund in the
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PFMMS Code of Ethics
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issuer of the Securities, and any decision to make such an investment must be
independently reviewed by a portfolio manager who does not have Beneficial
Ownership of any Securities of the issuer.
Short-Term Trading Profits
If you are an Investment Person of the Trust, you may not profit from the
purchase and sale, or sale and purchase, within 60 calendar days, of the same
(or equivalent) Securities (other than Exempt Securities) of which you have
Beneficial Ownership. You are prohibited from transactions involving puts,
calls, straddles, options and/or short sales except for Exempt Transactions,
transactions in Exempt Securities or transactions approved by a Compliance
Officer. Any such short-term trade must be unwound, or, if that is not
practical, the profits must be contributed to a charitable organization.
You are considered to profit from a short-term trade if Securities of which
you have Beneficial Ownership are sold for more than their purchase price, even
though the Securities purchased and the Securities sold are held of record or
beneficially by different persons or entities.
Reporting
Use of Broker-Dealers
Unless you are an independent Trustee, you may not engage, and you may not
permit any other person or entity to engage, in any purchase or sale of publicly
traded Securities (other than Exempt Securities) of which you have, or by reason
of the transaction will acquire, Beneficial Ownership, except through a
registered broker-dealer.
Reporting of Transactions and Brokerage Accounts
Unless you are an independent Trustee, you must report your brokerage accounts
and all Securities transactions that are not Exempt Transactions or transactions
in Exempt Securities. To satisfy these requirements, (i) you must cause each
registered broker-dealer who maintains an account for Securities of which you
have Beneficial Ownership to provide to a Compliance Officer hereunder, within
10 days of the end of each calendar quarter, duplicate copies of: (a)
confirmations of all transactions in the account and (b) periodic statements for
the account and (ii) you must report (on the form attached as Appendix III) to a
Compliance Officer hereunder, within 10 days of the occurrence, the opening of
any brokerage account and all transactions effected without the use of a
registered broker-dealer in Securities (other than Exempt Securities) of which
you have Beneficial Ownership.
The confirmations and statements required by (i)(a) and (i)(b) above must in
the aggregate provide all of the information required by the Personal Securities
Transactions/Brokerage Account Report attached to this Code as Appendix III. If
they do not, you must complete and submit a Personal Securities
Transactions/Brokerage Accounts Report within 10 days of the end of each
calendar quarter.
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PFMMS Code of Ethics
Page 10
Initial and Annual Reports
Unless you are an independent Trustee, the Trust, the investment adviser, any
sub-adviser or the principal underwriter of the Trust, you must disclose your
holdings of all Securities (other than Exempt Securities) of which you have
Beneficial Ownership no later than 10 days after becoming an Access Person, and
annually thereafter. The form for this purpose is attached to this Code as
Appendix II.
Independent Trustees
If you are an independent Trustee (as defined in Appendix VI), you do not need
to provide the initial, periodic and annual reports described above but you must
provide a quarterly report of any transaction in Securities (other than Exempt
Securities) of which you had, or by reason of the transaction acquired,
Beneficial Ownership, and as to which you knew, or in the ordinary course of
fulfilling your official duties as a Trustee should have known, that during the
15-day period immediately preceding or after the date of the transaction, such
Securities were purchased or sold, or considered for purchase or sale, on behalf
of a Fund. The report must be provided to a Compliance Officer hereunder within
10 days after the end of each calendar quarter. The form for this purpose is
attached to this Code as Appendix III.
As of the effective date of this Code, the independent Trustees are E. Philip
Cannon, Donald P. Carter, Gary A. Childress, Richard L. Nelson, Lyman W. Porter,
Alan Richards, W. Bryant Stooks and Gerald M. Thorne.
Disclaimer
Anyone filing a report required hereunder may disclaim Beneficial Ownership of
any Security listed thereon.
FIDUCIARY DUTIES
Gifts
You may not accept any investment opportunity, gift, gratuity or other thing
of more than nominal value, from any person or entity that does business, or
desires to do business, with the Trust directly or on behalf of a Fund or any
affiliate thereof. You may accept gifts from a single giver so long as their
aggregate annual value does not exceed $100, and you may attend business meals,
sporting events and other entertainment events at the expense of a giver, so
long as the expense is reasonable and both you and the giver are present.
Service as a Director
Unless you are an independent Trustee, you may not serve on the board of
directors or other governing board of a publicly traded company, unless you have
received the prior written approval of the Compliance Committee. Approval will
be not be given unless a determination is made that your service on the board
would be consistent with the interests of our Funds. If you are permitted to
serve on the board of a publicly traded entity, you will be isolated from those
portfolio employees who make
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PFMMS Code of Ethics
Page 11
investment decisions with respect to the securities of that entity, through a
"Chinese Wall" or other procedures.
COMPLIANCE
Certificate of Receipt
You are required to acknowledge receipt of your copy of this Code. A form for
this purpose is attached to this Code as Appendix IV.
Certificate of Compliance
Unless you are an independent Trustee, you are required to certify upon
commencement of your election as an officer and/or Trustee or the effective date
of this Code, whichever occurs later, and annually thereafter, that you have
read and understand this Code and recognize that you are subject to this Code.
Each annual certificate will also state that you have complied with the
requirements of this Code during the prior year, and that you have disclosed,
reported, or caused to be reported all holdings required hereunder and all
transactions during the prior year in Securities of which you had or acquired
Beneficial Ownership. A form for this purpose is attached to this Code as
Appendix V.
Remedial Actions
If you violate this Code, you are subject to remedial actions, which may
include, but are not limited to, disgorgement of profits, imposition of a
substantial fine, demotion, suspension or termination.
Reports to Trustees
Reports of Material Remedial Action
The Trustees of the Trust will be informed on a timely basis of each material
remedial action taken in response to a violation of this Code. For this
purpose, a material remedial action will include any action that has a
significant financial effect on the violator, such as disgorgement of profits,
imposition of a substantial fine, demotion, suspension or termination.
Annual Reports
Management of the Trust, the investment adviser, each sub-adviser, and the
principal underwriter of the Trust will report in writing annually to the
Trustees of the Trust with regard to efforts to ensure compliance by the
officers and employees of PIMCO Advisors with their fiduciary obligations to
PIMCO Advisors advisory clients.
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PFMMS Code of Ethics
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The annual report will, at a minimum:
1. Describe any issues arising under the Code of Ethics or procedures
since the last report to the Board, including, but not limited to,
information about material violations of the Code or procedures and
sanctions imposed in response to the material violations; and
2. Certify that the Trust, investment adviser, each sub-adviser, or
principal underwriter, as the case may be, has adopted procedures
reasonably necessary to prevent Access Persons from violating the
Code.
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Appendix I
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PIMCO FUNDS: MULTI-MANAGER SERIES
PRECLEARANCE OF SECURITIES TRANSACTION FORM
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(1) Name of employee requesting authorization: ____________________
(2) If different from #1, name of the account
where the trade will occur: ____________________
(3) Relationship of (2) to (1): ____________________
(4) Name of firm at which the account is held: ____________________
(5) Name of Security and call symbol: ____________________
(6) Maximum number of shares or units to be
purchased or sold or amount of bond: ____________________
(7) Check those that are applicable:
___ Purchase ___ Sale ___ Market Order ___ Limit Order
(Price of Limit Order: _____)
If the answer to any of the following questions is made by checking the answer
in Column I, the Compliance Officer may have to reject the proposed transaction:
Column I Column II
-------- ---------
(8) Do you possess material nonpublic
information regarding the security
or the issuer of the security?/1/
___ Yes ___ No
(9) To your knowledge, are the securities or
"equivalent securities" subject to a
pending buy or sell order by any Fund? ___ Yes ___ No
(10) To your knowledge, are there any
outstanding purchase or sell orders for
this security or any equivalent security
by any Fund? ___ Yes ___ No
(11) To your knowledge, are the securities or
equivalent securities being considered for
purchase or sale by one or more Funds? ___ Yes ___ No
----------
1 Please note that employees and Trustees generally are not permitted to
acquire or sell securities when they possess material nonpublic information
regarding the security or the issuers of the security.
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PFMMS
Preclearance Securities
Transaction Form
Page 2
Column I Column II
-------- ---------
(12) If you are an investment person, are the
securities being acquired in an initial
public offering?/2/ ___ Yes ___ No
(13) If you are an investment person, are the
securities being acquired in a private
placement?/2/ ___ Yes ___ No
(14) Has any Fund you manage purchased or
sold these securities or equivalent
securities within the past seven calendar
days or do you expect the Fund to purchase
or sell these securities or equivalent
securities within seven calendar days of
your purchase or sale? ___ Yes ___No
I have read the Code of Ethics for the Trust dated June 12, 2000, within the
prior 12 months and believe that the proposed trade fully complies with the
requirements of the Code.
_________________________________
Employee Signature
_________________________________
Print Name
_________________________________
Date Submitted
Authorized by: ___________________
Date: ___________________
----------
2 Please see a Compliance Officer if you are not sure whether you are an
Investment Person.
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Appendix II
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PIMCO FUNDS: MULTI-MANAGER SERIES
INITIAL AND ANNUAL REPORT OF
PERSONAL SECURITIES HOLDINGS
In accordance with the Code of Ethics, please provide a list of all Securities
(other than Exempt Securities) of which you or any account in which you have a
Pecuniary Interest has Beneficial Ownership and all Securities (other than
Exempt Securities) in non-client accounts for which you make investment
decisions. This includes not only securities held by brokers, but also
Securities held at home, in safe deposit boxes, or by an issuer.
(1) Name of employee: ____________________
(2) If different than #1, name of the person
in whose name the account is held: ____________________
(3) Relationship of (2) to (1): ____________________
(4) Broker(s) at which Account is Maintained: ____________________
____________________
____________________
____________________
(5) Account Number(s): ____________________
____________________
____________________
____________________
(6) Telephone number(s) of Broker: ____________________
____________________
____________________
____________________
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PFMMS
Initial and Annual Report
Personal Securities Holdings
Page 2
(7) For each account, attach your most recent account statement listing
Securities in that account. This information must be current as of a date
no more than 30 days before this report is submitted. If you own
Securities that are not listed in an attached account statement, list them
below:
Name of Security Quantity Value Custodian
1. ________________ ________ _____ ______________
2. ________________ ________ _____ ______________
3. ________________ ________ _____ ______________
4. ________________ ________ _____ ______________
5. ________________ ________ _____ ______________
(Attach separate sheet if necessary.)
I certify that this form and the attached statements (if any) constitute
all of the Securities of which I have Beneficial Ownership as defined in the
Code.
______________________________
Employee Signature
______________________________
Print Name
Dated: _________________
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Appendix IV
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PIMCO FUNDS: MULTI-MANAGER SERIES
ACKNOWLEDGMENT CERTIFICATION
I hereby certify that I have read and understand the PIMCO Funds:
Multi-Manager Series Code of Ethics dated June 12, 2000. Pursuant to such Code,
I recognize that I must disclose or report all personal securities holdings and
transactions required to be disclosed or reported thereunder and comply in all
other respects with the requirements of such Code. I also agree to cooperate
fully with any investigation or inquiry as to whether a possible violation of
the foregoing Code has occurred.
Date: __________________________ ______________________________
Signature
______________________________
Print Name
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Appendix V
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PIMCO FUNDS: MULTI-MANAGER SERIES
ANNUAL CERTIFICATION OF COMPLIANCE
I hereby certify that I have complied with the requirements of the Code of
Ethics for the year ended December 31, 2000. Pursuant to such Code, I have
disclosed or reported all holdings and personal securities transactions required
to be disclosed or reported thereunder and complied in all other respects with
the requirements of such Code. I also agree to cooperate fully with any
investigation or inquiry as to whether a possible violation of the foregoing
Code has occurred.
Date: _________________________ _____________________________
Signature
_____________________________
Print Name
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Appendix VI
Definitions
Page 2
Appendix VI
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DEFINITIONS
1. For the purposes hereof, "Investment Person" means:
(i) any employee of the Trust or an investment adviser or sub-adviser
(or of any company in a control (as defined in Section 2(a)(9) of the
Act) relationship to the Trust or investment adviser or sub-adviser)
who, in connection with his or her regular functions or duties, makes
or participates in making recommendations regarding the purchase or
sale of securities by any Fund of the Trust, including any portfolio
manager and any employee who helps execute decisions of any portfolio
manager; or
(ii) any natural person who controls (as defined in Section 2(a)(9) of
the Act) the Trust or investment adviser or sub-adviser and who
obtains information concerning recommendations made to any Fund of the
Trust regarding the purchase or sale of securities by any Fund of the
Trust.
* * *
2. For the purposes hereof, "Disinterested Trustee" means a Trustee who is
not an "interested person" (as defined by Section 2(a)(19 of the Act, which
definition is set forth below) of the Trust and who would be required to provide
the initial, quarterly and annual reports described in the Code solely by reason
of being a Trustee of the Trust.
* * *
3. "Interested person" of another person means:
(A) when used with respect to an investment company -
(i) any affiliated person of such company;
(ii) any member of the immediate family of any natural person who is
an affiliated person of such company;
(iii) any interested person of any investment adviser of or principal
underwriter for such company;
(iv) any person or partner or employee of any person who at any time
since the beginning of the last two completed fiscal years of
such company has acted as legal counsel for such company;
(v) any broker or dealer registered under the Securities Exchange Act
of 1934 or any affiliated person of such a broker or dealer; and
<PAGE>
Appendix VI
Definitions
Page 3
(vi) any natural person whom the Securities and Exchange Commission
(the "Commission") by order shall have determined to be an
interested person by reason of having had, at any time since the
beginning of the last two completed fiscal years of such company,
a material business or professional relationship with such
company or with the principal executive officer of such company
or with any other investment company having the same investment
adviser or principal underwriter or with the principal executive
officer of such other investment company.
Provided, that no person shall be deemed to be an interested person of
an investment company solely by reason of (aa) his being a member of its board
of directors or advisory board or an owner of its securities, or (bb) his
membership in the immediate family of any person specified in clause (aa) of
this proviso; and
(B) when used with respect to an investment adviser of or principal
underwriter for any investment company -
(i) any affiliated person of such investment adviser or principal
underwriter;
(ii) any member of the immediate family of any natural person who is
an affiliated person of such investment adviser or principal
underwriter;
(iii) any person who knowingly has any direct or indirect beneficial
interest in, or who is designated as trustee, executor, or
guardian of any legal interest in, any security issued either by
such investment adviser or principal underwriter or by a
controlling person of such investment adviser or principal
underwriter;
(iv) any person or partner or employee of any person who at any time
since the beginning of the last two completed fiscal years of
such investment company has acted as legal counsel for such
investment adviser or principal underwriter;
(v) any broker or dealer registered under the Securities Exchange Act
of 1934 or any affiliated person of such a broker or dealer; and
(vi) any natural person whom the Commission by order shall have
determined to be an interested person by reason of having had at
any time since the beginning of the last two completed fiscal
years old such investment company a material business or
professional relationship with such investment adviser or
principal underwriter or with the principal executive officer or
any controlling person of such investment adviser or principal
underwriter.
For the purposes hereof, "member of the immediate family" means any
parent, spouse of a parent, child, spouse of a child, spouse, brother or sister,
and includes step and adoptive relationships. The Commission may modify or
revoke any order issued under clause (vi) of subparagraph (A) and (B) of this
paragraph whenever it finds that such order is no longer consistent with the
facts. No order issued pursuant to clause (vi) of subparagraph (A) or (B) of
this paragraph shall become effective until at least sixty days after the entry
thereof, and no such order shall affect the status of any person for the
purposes of this title or for any other purpose for any period prior to the
effective date of such order.
<PAGE>
PIMCO FUNDS: MULTI-MANAGER SERIES Appendix III
------------
Personal Securities Transactions/Brokerage Account Report
Quarter Ended: ______________
You must cause each broker-dealer who maintains an account for Securities of
which you have Beneficial Ownership to provide to a Compliance Officer, within
10 days of the end of each calendar quarter, duplicate copies of confirmations
of all transactions in the account and duplicate statements for the account and
you must report to the Compliance Officer, within 10 days of the occurrence, all
transactions effected without the use of a registered broker-dealer in
Securities (other than transactions in Exempt Securities).
If you have opened a new account with a broker-dealer since your last report,
please complete the following information for each such account:
<TABLE>
<CAPTION>
-----------------------------------------------------------------------------------------------
Name Broker Account Number Date Account Opened
-----------------------------------------------------------------------------------------------
<S> <C> <C> <C>
-----------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------
</TABLE>
Please provide information concerning non-Exempt Transactions not effected
through a registered broker-dealer (e.g., direct purchases of private placements
or limited partnerships).
<TABLE>
<CAPTION>
-------------------------------------------------------------------------------------------------------------------
Security's Name* Transaction Date Buy or Sell? No. of Shares Price Per Share Broker's Name
-------------------------------------------------------------------------------------------------------------------
<S> <C> <C> <C> <C> <C>
-------------------------------------------------------------------------------------------------------------------
-------------------------------------------------------------------------------------------------------------------
-------------------------------------------------------------------------------------------------------------------
-------------------------------------------------------------------------------------------------------------------
-------------------------------------------------------------------------------------------------------------------
</TABLE>
* Including interest rate, principal amount and maturity date, if applicable.
By signing this document, I am certifying that I have caused duplicate
confirmations and duplicate statements to be sent to the Compliance Officer for
every brokerage account that trades in Securities other than Exempt Securities
(as defined in the PFMMS Code of Ethics).
Print Name: ______________________ Signature: ___________________________
Date: _______________
Return to: N.B. Schott, Jr. - PIMCO Funds Distributors LLC, 2187 Atlantic
Street, Stamford, CT 06902
<PAGE>
Appendix III (cont'd.)
----------------------
Exempt Securities include:
1. Direct obligations issued by the Government of the United States.
2. Bankers' acceptances, bank certificates of deposit, commercial paper, and
high quality short-term debt instruments, including repurchase agreements.
3. Shares of registered open-end investment companies.
Exempt Transactions include:
1. Any transaction in Securities in an account over which you do not have any
direct or indirect influence or control.
2. Purchases of Securities under dividend reinvestment plans.
3. Purchases of Securities by exercise of rights issued to the holders of a
class of Securities pro rata.
4. Acquisition or dispositions of Securities as the result of a stock dividend,
stock split, reverse stock split, merger, consolidation or spin-off.
5. Subject to the restrictions on participation in private placements set forth
in the Code of Ethics under Private Placements, acquisitions or disposition
of Securities of a private issuer.
6. Subject to the provisions set forth in the Code of Ethics under Exempt
Transactions, any transaction in Securities (other than Exempt Securities) by
a Trustee of PIMCO Funds: Multi-Manager Series who is not an "interested
person" of the Trust.
7. Classes of transactions as may be exempted from time to time by the
Compliance Committee.
Please review the PIMCO Funds: Multi-Manager Series Code of Ethics for further
details on Beneficial Ownership of Securities and other exemptions. If you have
additional questions, please contact your Compliance Officer.
