Exhibit 23(p)(8)
TURNER INVESTMENT PARTNERS, INC.
PERSONAL TRADING POLICY/CODE OF ETHICS
February 17, 2000
A. Personal investments: An employee should consider himself the
beneficial owner of those securities held by him, his spouse, his minor
children, a relative who shares his house, or persons by reason of any
contract, arrangement, understanding or relationship that provides him
with sole or shared voting or investment power.
B. Employees are barred from purchasing any securities (to include Common
Stock and related Options, Convertible securities, Options, or Futures
on Indexes) in which the firm has either a long or short position. If
an employee owns a position in any security, he must get written
pre-clearance from the Chairman or President to add to or sell the
position. ALL SECURITY TRANSACTIONS (BUY OR SELL) REQUIRE WRITTEN
CLEARANCE IN ADVANCE. Approval is good for 48 hours; if a trade has not
been executed, subsequent approvals are necessary until the trade is
executed. The Exception Committee (the Chairman, Vice Chairman,
President, and Director of Compliance) must approve any exceptions to
this rule.
C. Employees may not purchase initial public offerings. Private
placements/Limited partnerships require written pre-clearance. Mutual
Fund holdings are excluded from pre-clearance and reporting. IRA's, and
Rollover IRA's that are self-directed (i.e. stocks or bonds, not mutual
funds), and ESOP's (Employee stock ownership plans) require
pre-clearance.
D. Blackout Restrictions: Employees are subject to the following
restrictions when their purchases and sales of securities coincide
with trades of Turner Clients (including investment companies):
1. Purchases and sales within three days following a client trade.
Employees are prohibited from purchasing or selling any security
within three calendar days after a client transaction in the same
(or a related) security. The Exception Committee must approve
exceptions. If an employee makes a prohibited transaction without
an exception the employee must unwind the transaction and
relinquish any gain from the transaction to charity.
2. Purchases within seven days before a client purchase. An employee
who purchases a security within seven calendar days before a
client purchases the same (or a related) security is prohibited
from selling the security of a period of six months following the
client's trade. The Exception Committee must approve exceptions.
If an employee
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makes a prohibited sale without an exception within the six month
period, the employee must relinquish any gain from the transaction
to charity.
PERSONAL TRADING POLICY/CODE OF ETHICS
February 17, 2000
Page 2
3. Sales within seven days before a client sale. An employee who
sells a security within seven days before a client sells the same
(or a related) security must relinquish to charity the difference
between the employee's sale price and the client's sale price
(assuming the employee's sale price is higher).
4. These restrictions do not apply to proprietary investment
partnerships for which the firm acts as an adviser in which the
officers and employees of the adviser have an equity interest of
less than 50%. These accounts may purchase the same or similar
securities within the black out period, if the partnership trades
with the block or after other clients. Where it is beneficial to
client accounts and it is possible to do so, they should be
blocked with the partnership account.
E. Short Term Trading Rule - Employees may not take profits in any
security in less than 60 days (includes Options, Convertibles and
Futures). If an individual must trade with in this period, the
Exception Committee must grant approval or the employee must relinquish
such profits to charity. The closing of positions at a loss is not
prohibited. Options that are out of the money may be exercised in less
than 60 days. The proprietary partnerships may take profits in less
than 60 days.
F. Reporting: Consistent with the requirements of the Investment Advisers
Act of 1940 Rule 204-2 (a)(2) and (a)(3) and with the provisions of
Rule 17j-1 of the Investment Company Act of 1940 all employees must
submit duplicate statements/disclosures/holdings within 10 days
following the calendar quarter. Statements are reviewed by one of the
firms Series 24 principals. Brokerage, IRA's, Rollover IRA's (which are
self-directed), ESOP's, private placement and limited partnerships must
all be reported as personal trading. New employees are required to file
initial holdings within 10 days of hire.
G. Violation of the Personal Investments/Code of Ethics policy may result
in disciplinary action, up to and including termination of employment.
