© 2019 Altaba Terms and Privacy

RULE 17j-1 Code of Ethics

The Fund is required by Rule 17j-1 of the 1940 Act to have a written Code of Ethics that contains provisions reasonably necessary to prevent fraudulent, deceptive, or manipulative acts and requires reporting of personal securities transactions. The Rule 17j-1 Code of Ethics of the Fund (the “17j-1 Code of Ethics”) establishes standards and procedures for the detection and prevention of activities by which persons having knowledge of the investments and investment intentions of the Fund may abuse their fiduciary duties to the Fund and otherwise to deal with the types of conflict of interest situations to which Rule 17j-1 is addressed. The 17j-1 Code of Ethics is based on the principle that the Directors and officers of the Fund and the Fund’s investment adviser(s) owe a fiduciary duty to the Fund to conduct their personal securities transactions in a manner that does not interfere with the Fund’s transactions or otherwise take unfair advantage of their relationship with the Fund.

The Board must approve the 17j-1 Code of Ethics, as well as any material change to the 17j-1 Code of Ethics. In addition, the Board must review, at least annually, a written report describing any issues that arose since the last report and certifying that processes are in place to prevent future violations.

GENERAL

I. DEFINITIONS

II. OBJECTIVE AND GENERAL PROHIBITIONS

III. PROHIBITED TRANSACTIONS

IV. PRE-CLEARANCE PROCEDURES

V. CERTIFICATIONS AND REPORTS BY ACCESS PERSONS

VI. ADDITIONAL PROHIBITIONS

VII. CERTIFICATION BY ACCESS PERSONS

VIII. SANCTIONS

IX. ADMINISTRATION AND CONSTRUCTION


Download PDF  275.3 KB