![]() That has the potential to cause harm to an FT Fund or Client Account. Regarding, or knowledge or even a presumed knowledge of, FT Fund or Client Account activity in such security, including proposed activityĮmployees generally are prohibited from engaging or participating Regardless of quantity, if the Covered Employee has access to information Officers), the Covered Employee must give preference to the FT Funds or Client Accounts. Sponsored conferences, or communications with company , internal or third party research, Franklin Templeton or company ![]() Opportunity because of his or her position with Franklin Templeton (e. That a Covered Employee learns of an investment To avoid actual or potential conflicts of interest with the FTįunds and Client Accounts. Investment activities of Covered Employees must be conducted in a manner Information concerning the securities 1 holdingsĪccounts, as well as the identity of certain ClientĮmployees are required to safeguard this information. Templeton's policy is that the interests of theĪccounts are paramount and come before the interests of any employee. Manner in their business practices and to maintain an environment thatįosters fairness, respect and integrity. Īll Covered Employees are required to conduct themselves in a lawful, Practices that guide Franklin Templeton's business conduct and to establish a set of principles to guide CoveredĮmployees regarding the conduct expected of them when managing their personal investments. Purpose of the Policy is to summarize the values, principles and business "FT Fund" includes all open-end and closed-end funds within the FranklinĪs well as any other fund that is advised or sub-advised by a Franklin Templeton investment adviser. Templeton provides services to the funds that are advised or sub-advised by aįranklin Templeton investment adviser (the "FT Funds") and other client accounts ("Client Accounts"). ("FRI")Īnd all of its subsidiaries (collectively, "Franklin Templeton " ). Templeton Personal Investments and Insider Trading Policy (the "Policy") applies to the personal investment activities Any unauthorized use, reproduction or transfer of thisĭocument is strictly prohibited. STATEMENT ON OTHER POLICIES AND REQUIREMENTSĪDMINISTRATION OF THE POLICY, WAIVERS & REPORTING VIOLATIONS MONITORING OF THE POLICY AND ADDITIONAL INFORMATIONĬATEGORIES OF PERSONS SUBJECT TO THE POLICYĪCCOUNTS AND TRANSACTIONS COVERED BY THE POLICYĪDDITIONAL PROHIBITIONS AND REQUIREMENTS FOR ACCESS PERSONS AND Investment Company Act of 1940 and Rule 204A-1 under the Investment Advisers Act of 1940)
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