<PAGE>
HGK ASSET MANAGEMENT, INC.
CODE OF ETHICS
While affirming its confidence in the integrity and good faith of all of
its employees, officers and Directors, HGK Asset Management, Inc. (the
"Adviser") recognizes that certain of its personnel have or may have
knowledge of present or future portfolio transactions and, in certain
instances, the power to influence portfolio transactions made by or for its
Advisory Clients, and that if such individuals engage in personal
transactions in Securities that are eligible for investment by Advisory
Clients, these individuals could be in a position where their personal
interests may conflict with the interests of the Advisory Clients.
In view of the foregoing and of the provisions of Rule 17j-1 under the
Investment Company Act of 1940 ("1940 Act"), the Adviser has determined to
adopt this Code of Ethics ("Code") to specify and prohibit certain types of
transactions deemed to create actual conflicts of interest, the potential for
conflicts, or the appearance of conflicts, and to establish reporting
requirements and enforcement procedures.
I. STATEMENT OF GENERAL PRINCIPLES
In recognition of the trust and confidence placed in the Adviser by its
Advisory Clients and to give effect to the Adviser's belief that its
operations should be directed to the benefit of all of its Advisory Clients,
the Adviser hereby adopts the following general principles to guide the
actions of its employees, officers and Directors:
A. The interests of the Adviser's Advisory Clients are paramount. All
of the Adviser's personnel must conduct themselves and their
operations to give maximum effect to this tenet by assiduously
placing the Advisory Clients' interests before their own.
B. All personal securities transactions by the Adviser's personnel
must be accomplished so as to avoid the appearance of a conflict of
interest on the part of such personnel with the interests of any
Advisory Client.
C. All of the Adviser's personnel must avoid actions or activities
that allow (or appear to allow) a person to profit or benefit
from his or her position with respect to an Advisory Client, or
that otherwise bring into question the person's independence or
judgment.
II. DEFINITIONS
A. "Access Person" shall mean any director or officer of the Adviser.
"Access Person" also means any employee of the Adviser who: (i) in
connection with the management of any Advisory Client, recommends
investments to such Advisory Client, participates in the
determination of which recommendations are to be made,
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or whose principal functions or duties relate to such determinations;
or (ii) in connection with his or her duties, obtains any information
concerning securities recommendations being made by the Adviser to
an Advisory Client. The Review Officer may determine that
additional persons, including persons not employed by the Adviser,
are to be treated as Access Persons based on their access to
information concerning the Adviser's investment recommendations to
an Advisory Client.
B. "Advisory Client" means any individual, group of individuals,
partnership, trust or company, including, without limit, a Fund for
whom the Adviser acts as an adviser or sub-adviser.
C. "Beneficial Ownership" of a security is to be determined in the
same manner as it is for purposes of Section 16 of the Securities
Exchange Act of 1934 and Rule 16a-1(a)(2) thereunder. This means
that a person should generally consider himself or herself the
beneficial owner of any securities in which he or she has a direct
or indirect pecuniary interest. In addition, a person should
consider himself or herself the beneficial owner of securities held
by (i) his or her spouse or minor children, (ii) a relative who
shares his or her home, or (iii) other persons by reason of any
contract, arrangement, understanding, or relationship that provides
him or her with sole or shared voting or investment power over the
securities held by such person.
D. "Control" shall have the same meaning as that set forth in Section
2(a)(9) of the 1940 Act. Section 2(a)(9) provides that "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. Ownership of
25% or more of a company's outstanding voting securities is
presumed to give the holder of such Securities control over the
company. This is a rebuttable presumption, and it may be countered
by the facts and circumstances of a given situation.
E. "Fund" means any investment company registered under the 1940 Act
for which the Adviser acts as investment adviser or sub-adviser.
F. "High quality short-term debt instrument" means 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.
G. "Investment Personnel" means all Access Persons 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 an Advisory Client; and (ii) any natural person who
controls the Adviser and who obtains information concerning
recommendations made to an Advisory Client regarding the purchase
or sale of securities by the Advisory Client.
H. "IPO" (I.E., initial public offering) means an offering of
securities registered under the Securities Act of 1933, the issuer
of which, immediately before registration, was
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not subject to the reporting requirements of Section 13 or Section
15(d) of the Securities Exchange Act of 1934.
I. "Limited offering" means an offering that is exempt from
registration under the Securities Act of 1933 pursuant to Section
4(2), Section 4(6), Rule 504, Rule 505 or Rule 506 (E.G., private
placements).
J. A "personal securities account" means any account in which any
securities are held for the person's direct or indirect benefit.
K. "Purchase or sale of a Security" includes, among other things, the
writing of an option to purchase or sell a Security.
L. "Security" shall have the same meaning as that set forth in Section
2(a)(36) of the 1940 Act, except that it shall not include direct
obligations of the U.S. Government; bankers' acceptances, bank
certificates of deposit, commercial paper, high quality short-term
debt instruments, including repurchase agreements; and shares of
registered open-end mutual funds.
M. A "Security held or to be acquired" by a Fund means: (i) any
Security which, within the most recent 15 days, (a) is or has been
held by a Fund or (b) is being or has been considered by the
Adviser for purchase by a Fund; and (ii) any option to purchase or
sell, and any security convertible into or exchangeable for, a
Security described in (i) of this definition.
N. A security is "being considered for purchase" when [A
RESEARCH REPORT IS GENERATED REGARDING THE SECURITY]/
[THE INVESTMENT COMMITTEE HOLDS A MEETING REGARDING THE
SECURITY]/[THE SECURITY IS PLACED ON THE ___________
LIST].
O. A Security is "being purchased or sold" by a Fund from the time when
a recommendation has been communicated to the person who places the
buy and sell orders for an Advisory Client until the time when such
program has been fully completed or terminated.
P. The designated "Review Officer" is Jeffrey T. Harris, Managing
Director.
III. GENERAL PROHIBITION AGAINST FRAUD, DECEIT AND MANIPULATION
No Access Person shall, in connection with the purchase or sale,
directly or indirectly, by such person of a Security held or to be
acquired by any Advisory Client:
A. Employ any device, scheme, or artifice to defraud such Advisory
Client;
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B. Make to such Advisory Client any untrue statement of a material
fact or omit to state to such Advisory Client a material fact
necessary in order to make the statements made, in light of the
circumstances under which they are made, not misleading;
C. Engage in any act, practice or course of business that would operate
as a fraud or deceit upon such Advisory Client; or
D. Engage in any manipulative practice with respect to such Advisory
Client.
IV. PROHIBITED PURCHASES AND SALES
A. Subject to Sections IV(C) and IV(D) of this Code, no Access Person
may purchase or sell, directly or indirectly, any Security in which
he or she had or by reason of such transaction acquired any
Beneficial Ownership, within 24 hours (seven days, in the case of
Investment Personnel) before or after the time that the same (or a
related) Security is being purchased or sold by any Advisory
Client. Any profits realized on trades within these proscribed
periods will be disgorged.
B. No Investment Personnel may acquire Securities as part of an IPO.
C. No Access Person shall purchase a Security offered in a private
placement without the specific, prior written approval of the
Adviser's designated Review Officer.
V. PRE-CLEARANCE OF TRANSACTIONS
A. Except as provided in Section IV(C), each Access Person must
pre-clear each proposed transaction in Securities with the Review
Officer prior to proceeding with transaction. No transaction in
Securities shall be effected without the prior written approval of
the Review Officer. In determining whether to grant such clearance,
the Review Officer shall refer to Section IV(D) below. Pre-clearance
of a Securities transaction is valid for 48 hours.
B. In determining whether to grant approval for the purchase of a
Security offered in a private placement, the Review Officer shall
take into account, among other factors, whether the investment
opportunity should be reserved for an Advisory Client, and
whether the opportunity is being offered to the Access Person by
virtue of his or her position with the Adviser.
C. The pre-clearance requirements of Section V(A) shall not apply to
the following transactions:
1. Purchases or sales over which the Access Person has no direct
or indirect influence or control.
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2. Purchases or sales that are non-volitional on the part of the
Access Person, including purchases or sales upon exercise of
puts or calls written by the Access Person and sales from a
margin account pursuant to a BONA FIDE margin call.
3. Purchases that 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.
NOTE: THESE EXCEPTIONS TO THE PRE-APPROVAL REQUIREMENT OF SECTION
V(A) SHALL NOT APPLY TO REQUESTS FOR APPROVAL TO PURCHASE OR ACQUIRE
A SECURITY IN AN IPO OR A LIMITED OFFERING IN ACCORDANCE WITH
SECTION IV(B) OR (C) ABOVE.
D. The following transactions generally shall be approved by the Review
Officer:
1. Transactions which appear upon reasonable inquiry and
investigation to present no reasonable likelihood of harm to
any Advisory Client, and which are otherwise in accordance with
Rule 17j-1. Such transactions would normally include purchases
or sales of up to 1,000 shares of a Security that is being
considered for purchase or sale by an Advisory Client or other
client (but not then being purchased or sold) if the issuer has
a market capitalization of over $1 billion.
2. Purchases or sales of Securities that are not eligible for
purchase or sale by any Advisory Client, as determined by
reference to the 1940 Act, other applicable laws, rules or
regulations, the investment objectives and policies and
investment restrictions of the Advisory Client and any
undertakings made to regulatory authorities.
3. Transactions that the officers of the Adviser, as a group and
after consideration of all the facts and circumstances,
determine to be in accordance with Section III and to present
no reasonable likelihood of harm to an Advisory Client.
IV. ADDITIONAL RESTRICTIONS AND REQUIREMENTS
A. No Access Person shall accept or receive any gift of more than DE
MINIMUS value from any person or entity that does business with or
on behalf of the Adviser or an Advisory Client. All Access Persons
must record all gifts received or given on their respective
Departmental log.
B. No Investment Personnel shall accept a position as a director,
trustee or general partner of a publicly-traded company or
partnership unless the acceptance of such
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position has been approved by the Review Officer and consistent with
the interests of the Advisory Clients.
VII. REPORTING AND COMPLIANCE OBLIGATIONS
A. The Review Officer shall create and thereafter maintain a list of
all Access Persons.
B. Each Access Person must direct each brokerage firm or bank at which
the Access Person maintains a Securities account to promptly send
duplicate copies of such persons account statement and brokerage
confirmations promptly to the Review Officer. Compliance with this
provision can be effected by the Access Person providing duplicate
copies of all such statements and confirmations directly to the
Review Officer within two business days of the receipt by the Access
Person.
C. Each Access Person must provide to the Review Officer a complete
listing of all Securities owned by such person as of this date and
thereafter must submit a review list of such holdings to the Review
Officer as of December 31st of the subsequent year. The initial
listing must be submitted no later than ten days of the date upon
which such person first became an Access Person of the Adviser.
D. Every Access Person shall certify annually that he or she:
1. Has read and understands this Code;
2. recognizes that he or she is subject to the Code;
3. has complied with the Code; and
4. has disclosed and reported all personal Securities transactions
and personal securities accounts required to be disclosed or
reported.
E. Reports.
1. Initial Holdings Reports: Every Access Person must provide to
the Review Officer a complete listing of all Securities owned
by such person, as well as all personal securities accounts,
within ten days of becoming an Access Person. Such reports need
not show transactions effected for, or Securities held in,
personal securities accounts over which the person has no
direct or indirect influence or control.
2. Annual Holdings Reports: On an annual basis, each Access Person
must submit to the Review Officer a listing of all Securities
beneficially owned by such person, as well as all personal
securities accounts. The list must be current as of a date no
more than 30 days before the report is submitted and must be
received within 30 days of the end of the calendar year. Such
reports
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need not show transactions effected for, or Securities held in,
personal securities accounts over which the person has no direct
or indirect influence or control. An Annual Holdings Report is
attached at Appendix II.
3. Quarterly Reports:
a. Each Access Person shall report all transactions in
Securities in which the person has, or by reason of such
transaction acquires, any direct or indirect beneficial
ownership. Reports shall be filed with the Review Officer
quarterly. Each Access Person must also report any personal
securities accounts established during the quarter. The
Review Officer shall submit confidential quarterly reports
with respect to his or her own personal Securities
transactions and personal securities accounts established to
an officer designated to receive his or her reports, who
shall act in all respects in the manner prescribed herein
for the Review Officer. Such reports need not show
transactions effected for, or Securities held in, personal
securities accounts over which the person has no direct or
indirect influence or control.
b. Every report shall be made NO LATER THAN ten 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 Quarterly Report Form is included
as Appendix III):
(i) The date of the transaction, the title, the interest
rate and maturity (if applicable), the number of
shares and principal amount of each Security involved;
(ii) The nature of the transaction (I.E., purchase, sale or
any other type of acquisition or disposition);
(iii) The price of the Security at which the transaction was
effected;
(iv) The name of the broker, dealer or bank with or through
which the transaction was effected;
(v) The date the report is submitted by the Access
Person; and
(vi) With respect to any personal securities account
established during the quarter, the broker, dealer or
bank with whom the account was established, and the
date the account was established.
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c. In the event the Access Person has no reportable items
during the quarter, the report should be so noted and
returned signed and dated.
d. An Access Person need not submit a quarterly report if the
report would duplicate information in broker trade
confirmations or account statements received by the Advisory
Client, provided that all required information is contained
in the broker trade confirmations or account statements and
is received by the Review Officer NO LATER THAN ten days
after the end of the calendar quarter.
4. Any of these reports 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. Every Access Person shall report the name of any publicly-traded
company (or any company anticipating a public offering of its
equity Securities) and the total number of its shares
beneficially owned by him or her if such total ownership is more
than 1/2 of 1% of the companies outstanding shares.
6. Every Access Person who owns Securities acquired in a private
placement shall disclose such ownership to the Review Officer if
such person is involved in any subsequent consideration of an
investment in the issuer by an Advisory Client. The Adviser's
decision to recommend the purchase of such issuers Securities
to an Advisory Client will be subject to independent review by
Investment Personnel with no personal interest in the issuer.
VIII. REVIEW AND ENFORCEMENT
A. The Review Officer's Duties and Responsibilities. The Review Officer
shall notify each person who becomes an Access Person and who is
required under this Code of Ethics of his or her reporting
requirements NO LATER THAN ten days before the first quarter in
which such person is required to begin reporting.
B. The Review Officer will, on a quarterly basis, compare all
confirmations, account statements and other reports received with a
list of Securities being considered for purchase or sale on behalf
of any Advisory Client to determine whether a violation of this Code
may have occurred. Before determining that a person has violated the
Code, the Review Officer shall give such person an opportunity to
supply additional explanatory material.
C. If the Review Officer determines that a violation has occurred, or
believes that a Code violation may have occurred, the Review Officer
must submit a written report regarding the possible violation,
together with any confirmations, account statements or other reports
and any additional explanatory material provided by the Access
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Person, to the Access Person's primary supervisor, as indicated at
Section V(A) and legal counsel for the Adviser, who shall make an
independent determination as to whether a violation has occurred. If
the primary supervisor is unavailable or is unable to review the
transaction, the alternate supervisor shall act in all respects in
the manner prescribed herein for the primary supervisor.
D. If the primary or alternate supervisor finds that a violation has
occurred, the supervisor shall impose upon the individual such
sanctions as he deems appropriate.
IX. ANNUAL WRITTEN REPORTS TO THE BOARD
At least annually, the Adviser will provide written reports to the
Advisory Clients' Board of Directors as follows:
A. Issues Arising Under the Code. The reports must describe any
issue(s) that arose during the previous year under the codes or
procedures thereto, including any material code or procedural
violations, and any resulting sanction(s). The Adviser may report to
the Board more frequently as it deems necessary or appropriate and
shall do so as requested by the Board.
B. Certification. Each report must be accompanied by a certification to
the Board that the Adviser has adopted procedures reasonably
necessary to prevent its Access Persons from violating this Code of
Ethics.
X. RECORDKEEPING
The Adviser will maintain the records set forth below. These records
will be maintained in accordance with the 1940 Act and the following
requirements. They will be available for examination by representatives of
the Securities and Exchange Commission and other regulatory agencies.
A. A copy of this Code and any other code adopted by the Adviser under
Rule 17j-1, which is, or at any time within the past five years has
been, in effect will be preserved in an easily accessible place.
B. A record of any Code violation and of any sanctions taken will be
preserved in an easily accessible place for a period of at least
five years following the end of the fiscal year in which the
violation occurred.
C. A copy of each Quarterly Report, Initial Holdings Report, and Annual
Holdings Report submitted under this Code, including any information
provided in lieu of any such reports made under the Code, will be
preserved for a period of at least five years from the end of the
fiscal year on which it is made, for the first two years in an
easily accessible place.
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D. A record of all persons, currently or within the past five years,
who are or were required to submit reports under this Code, or who
are or were responsible for reviewing these reports, will be
maintained in an easily accessible place.
E. A copy of each annual report required by Section IX of this Code
must be maintained for at least five years from the end of the
fiscal year in which it is made, for the first two years in any
easily accessible place.
F. A record of any decision, and the reasons supporting the decision,
to approve the acquisition of securities acquired in an IPO or a
limited offering, for at least five years after the end of the
fiscal year in which the approval is granted.
XI. MISCELLANEOUS
A. Confidentiality. All reports and other confirmations and reports of
Securities transactions, and any other information filed with the
Adviser pursuant to this Code, shall be treated as confidential,
provided such reports and information may be produced to the
Securities and Exchange Commission and other regulatory agencies.
B. Interpretation of Provisions. The Adviser may from time to time
adopt such interpretations of this Code as it deems appropriate.
C. Compliance Certification. Within ten days of becoming an Access
Person of the Fund, and each year thereafter, each such person must
complete the Compliance Certification. A Compliance Certification
Form is attached as Appendix IV.
Adopted on May __, 2000
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APPENDIX I
INITIAL HOLDINGS REPORT
FOR HGK ASSET MANAGEMENT, INC.
Name of Reporting Person: _________________________________________
Date Person Became Subject to the
Code's Reporting Requirements: __________________________________
Information in Report Dated as of: ________________________________
Date Report Due: __________________________________________________
Date Report Submitted: _______ _________
[Note: Date person became subject
and as of date should be the same.]
<TABLE>
<CAPTION>
SECURITIES HOLDINGS
------------------------------------------------------------------------------------------------
Name of Issuer and No. of Shares Principal Amount, Maturity Date and Interest Rate
Title of Security (if applicable) (if applicable)
------------------------------------------------------------------------------------------------
<S> <C> <C>
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
</TABLE>
If you have no securities holdings to report, please check here. / /
If you do not want this report to be construed as an admission that you have
beneficial ownership of one or more securities reported above, please
describe below and indicate which securities are at issue.
SECURITIES ACCOUNTS
----------------------------------------------------------------------
Name of Broker, Dealer or Bank Name(s) on and Type of Account
----------------------------------------------------------------------
----------------------------------------------------------------------
----------------------------------------------------------------------
If you have no securities accounts to report, please check here. / /
I CERTIFY THAT I HAVE INCLUDED ON THIS REPORT ALL SECURITIES HOLDINGS AND
ACCOUNTS REQUIRED TO BE REPORTED PURSUANT TO THE CODE OF ETHICS.
--------------------------------------------------------------
Signature Date
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APPENDIX II
ANNUAL HOLDINGS REPORT
FOR HGK ASSET MANAGEMENT, INC.
Name of Reporting Person: _________________________________________
Information in Report Dated as of: ________________________________
Date Report Due: __________________________________________________
Date Report Submitted: ____________________________________________
Calendar Year Ended: December 31, ____
[Note: Information should be dated no
more than 30 days before report is submitted.]
<TABLE>
<CAPTION>
SECURITIES HOLDINGS
------------------------------------------------------------------------------------------------
Name of Issuer and No. of Shares Principal Amount, Maturity Date and Interest Rate (if
Title of Security (if applicable) applicable)
------------------------------------------------------------------------------------------------
<S> <C> <C>
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
</TABLE>
If you have no securities holdings to report for the year, please check
here. / /
If you do not want this report to be construed as an admission that you have
beneficial ownership of one or more securities reported above, please
describe below and indicate which securities are at issue.
<TABLE>
<CAPTION>
SECURITIES ACCOUNTS
------------------------------------------------------------------------------------------
Name of Broker, Dealer or Bank Date Account Was Name(s) on and Type of Account
Established
------------------------------------------------------------------------------------------
<S> <C> <C>
------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------
</TABLE>
If you have no securities accounts to report for the year, please check
here. / /
I CERTIFY THAT I HAVE INCLUDED ON THIS REPORT ALL SECURITIES TRANSACTIONS AND
ACCOUNTS REQUIRED TO BE REPORTED PURSUANT TO THE CODE OF ETHICS.
--------------------------------------------------------------
Signature Date
<PAGE>
APPENDIX III
QUARTERLY REPORT
FOR HGK ASSET MANAGEMENT, INC.
Name of Reporting Person: _________________________________________
Calendar Quarter Ended: ___________________________________________
Date Report Due: _______________________________________ 10, ______
Date Report Submitted: ____________________________________________
<TABLE>
<CAPTION>
SECURITIES TRANSACTIONS
------------------------------------------------------------------------------------------------
Principal Amount, Name of
Name of No. of Maturity Date Broker, Dealer
Issuer and Shares and or Bank
Date of Title of (if Interest Rate Type of Effecting
Transaction Security applicable) (if applicable) Transaction Price Transaction
------------------------------------------------------------------------------------------------
<S> <C> <C> <C> <C> <C> <C>
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
</TABLE>
If you have no securities transactions to report for the year, please check
here. / /
If you do not want this report to be construed as an admission that you have
beneficial ownership of one or more securities reported above, please
describe below and indicate which securities are at issue.
SECURITIES ACCOUNTS
If you established a securities account during the quarter, please provide
the following information:
<TABLE>
<CAPTION>
------------------------------------------------------------------------------------------
Name of Broker, Dealer or Bank Date Account Was Name(s) on and Type of Account
Established
------------------------------------------------------------------------------------------
<S> <C> <C>
------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------
</TABLE>
If you did not establish a securities account during the quarter, please
check here. / /
I CERTIFY THAT I HAVE INCLUDED ON THIS REPORT ALL SECURITIES TRANSACTIONS AND
ACCOUNTS REQUIRED TO BE REPORTED PURSUANT TO THE CODE OF ETHICS.
--------------------------------------------------------------
Signature Date
<PAGE>
APPENDIX IV
COMPLIANCE CERTIFICATION
FOR HGK ASSET MANAGEMENT, INC.
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INITIAL CERTIFICATION
I CERTIFY THAT I: (I) HAVE RECEIVED, READ AND REVIEWED THE CODE OF ETHICS;
(II) UNDERSTAND THE POLICIES AND PROCEDURES IN THE CODE;
(III) RECOGNIZE THAT I AM SUBJECT TO SUCH POLICIES AND
PROCEDURES;
(IV) UNDERSTAND THE PENALTIES FOR NON-COMPLIANCE;
(V) WILL FULLY COMPLY WITH THE CODE OF ETHICS;
(VI) HAVE FULLY AND ACCURATELY COMPLETED THIS
CERTIFICATE.
Signature:
Name: _____________________________ (Please print)
Date Submitted: ___________________
Date Due: _________________________
------------------------------------------------------------------------------
ANNUAL CERTIFICATION
I CERTIFY THAT I: (I) HAVE RECEIVED, READ AND REVIEWED THE CODE OF ETHICS;
(II) UNDERSTAND THE POLICIES AND PROCEDURES IN THE CODE;
(III) RECOGNIZE THAT I AM SUBJECT TO SUCH POLICIES AND
PROCEDURES;
(IV) UNDERSTAND THE PENALTIES FOR NON-COMPLIANCE;
(V) HAVE COMPLIED WITH THE CODE OF ETHICS AND ANY
APPLICABLE;
(VI) HAVE FULLY DISCLOSED ANY EXCEPTIONS TO MY COMPLIANCE
WITH THE CODE;
(VII) WILL FULLY COMPLY WITH THE CODE OF ETHICS; AND
(VI) HAVE FULLY AND ACCURATELY COMPLETED THIS
CERTIFICATE.
EXCEPTION(S):
Signature:
Name: _____________________________ (Please print)
Date Submitted: ___________________
Date Due: _________________________
