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:
o Your manager or department head
o 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
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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 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.
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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.
Associates may not subscribe to ANY initial public offering (IPO).
Generally, this prohibition applies 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)
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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. Reporting forms will be supplied at
the appropriate times AND MUST BE SUBMITTED BY THE DATE INDICATED ON THE
FORM.
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 BE PLACED 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
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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 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.
