Pioneer ILS Bridge Fund NCSR Certified annual shareholder report (management investment company)

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM N-CSR

CERTIFIED SHAREHOLDER REPORT OF REGISTERED

MANAGEMENT INVESTMENT COMPANIES

Investment Company Act file number 811-23172

Pioneer ILS Bridge Fund

(Exact name of registrant as specified in charter)

60 State Street, Boston, MA 02109

(Address of principal executive offices) (ZIP code)

Terrence J. Cullen, Amundi Pioneer Asset Management, Inc.,

60 State Street, Boston, MA 02109

(Name and address of agent for service)

Registrant’s telephone number, including area code: (617) 742-7825

Date of fiscal year end: October 31, 2020

Date of reporting period: November 1, 2019 through October 31, 2020

Form N-CSR is to be used by management investment companies to file reports with the Commission not later than 10 days after the transmission to stockholders of any report that is required to be transmitted to stockholders under Rule 30e-1 under the Investment Company Act of 1940 (17 CFR 270.30e-1). The Commission may use the information provided on Form N-CSR in its regulatory, disclosure review, inspection, and policymaking roles.

A registrant is required to disclose the information specified by Form N-CSR, and the Commission will make this information public. A registrant is not required to respond to the collection of information contained in Form N-CSR unless the Form displays a currently valid Office of Management and Budget (“OMB”) control number. Please direct comments concerning the accuracy of the information collection burden estimate and any suggestions for reducing the burden to Secretary, Securities and Exchange Commission, 450 Fifth Street, NW, Washington, DC 20549-0609. The OMB has reviewed this collection of information under the clearance requirements of 44 U.S.C. ss. 3507.



		Pioneer ILS Bridge Fund








		Annual Report \| October 31, 2020

Table of Contents

Financial Statements	3

Notes to Financial Statements	6

Report of Independent Registered Public Accounting Firm	8

Approval of Investment Management Agreement	9

Trustees, Officers and Service Providers	11

The accompanying notes are an integral part of these financial statements.

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Statement of Assets and Liabilities │ 10/31/20

ASSETS:
Cash	$	115,507
Due from the Adviser		163
Total assets	$	115,670

LIABILITIES:
Payables -
Administrative fees	$	2,280
Professional fees		11,597
Transfer agent fees		493
Printing expense		977
Accrued expenses		323
Total liabilities	$	15,670

NET ASSETS:
Paid-in capital	$	100,000
Net assets	$	100,000

NET ASSET VALUE PER SHARE:
No par value
Based on $100,000/10,000 shares	$	10.00

The accompanying notes are an integral part of these financial statements.

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Statement of Operations
FOR THE YEAR ENDED 10/31/20

INVESTMENT INCOME:
Total investment income			$	–

EXPENSES:
Administrative expense	$	12,078
Transfer agent fees		1,750
Shareowner communications expense		875
Registration fees		26,008
Professional fees		13,438
Printing expense		9,880
Miscellaneous		764
Total expenses			$	64,793
Less fees waived and expenses reimbursed by the Adviser				(64,793	)
Net expenses			$	–
Net investment income			$	–

REALIZED AND UNREALIZED GAIN (LOSS) ON INVESTMENTS:
Net realized gain (loss) on:
Investments in unaffiliated issuers			$	–
Change in net unrealized appreciation (depreciation) on:
Investments in unaffiliated issuers			$	–
Net realized and unrealized gain (loss) on investments			$	–
Net increase in net assets resulting from operations			$	–

The accompanying notes are an integral part of these financial statements.

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Statements of Changes in Net Assets
	Year Ended 10/31/20		Year Ended 10/31/19
FROM OPERATIONS:
Net investment income (loss)	$	–	$	–
Net realized gain (loss) on investments		–		–
Change in net unrealized appreciation (depreciation) on investments		–		–
Net increase in net assets resulting from operations	$	–	$	–
DISTRIBUTIONS TO SHAREOWNERS:
Total distributions to shareowners	$	–	$	–
FROM FUND SHARE TRANSACTIONS:
Net proceeds from sales of shares	$	–	$	–
Net increase in net assets resulting from Fund share transactions	$	–	$	–
Net increase in net assets	$	–	$	–
NET ASSETS:
Beginning of year	$	100,000	$	100,000
End of year	$	100,000	$	100,000

Year
Ended
10/31/20

Amount

Year
Ended
10/31/19

Amount

FUND SHARE TRANSACTIONS

Shares sold

Reinvestment of distributions

Less shares repurchased

Net increase

As the Fund has not yet commenced capital raising or investment activity, there are no financial highlights to report.

The accompanying notes are an integral part of these financial statements.

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Notes to Financial Statements | 10/31/20

1. Organization

Pioneer ILS Bridge Fund (the “Fund”) was organized under the laws of the State of Delaware on June 20, 2016 and was registered with the Securities and Exchange Commission under the Investment Company Act of 1940, as amended (the 1940 Act) as a non-diversified, closed-end management investment company. The Fund’s investment objective is total return.

The initial fund shares were issued on June 22, 2018 to Amundi Pioneer Asset Management, Inc. (the “Adviser”), an indirect, wholly owned subsidiary of Amundi Asset Management Co. and Amundi’s wholly owned subsidiary, Amundi USA, Inc. In addition, the Adviser has agreed to pay all organizational and offering costs of the Fund.

As of October 31, 2020, the Fund has not commenced operations and has not executed any transactions other than these relating to organizational matters and the issuance of initial shares to the Adviser as described above. As of October 31, the Fund has incurred Fund expenses, estimated at $64,793. As of October 31, 2020, the Adviser was the sole shareholder of the Fund.

The Fund’s financial statements have been prepared in conformity with U.S. generally accepted accounting principles (“U.S. GAAP”) that require the management of the Fund to make estimates and assumptions that affect the reported amounts of assets and liabilities, the disclosure of contingent assets and liabilities at the date of the financial statements, and the reported amounts of income, expenses and gains and losses on investments during the reporting period. Actual results could differ from those estimates.

2. Fund Shares

The Fund will offer shares through Amundi Pioneer Distributor, Inc., the principal underwriter for the Fund. Shares will be offered at the Fund’s current net asset value (“NAV”) per share. The Fund does not have an unlimited number of shares registered. Shares are not currently offered.

The Fund is an “interval” fund and will make periodic offers to repurchase shares. Except as permitted by the Fund’s structure, no shareholder will have the right to require the Fund to repurchase its shares. No public market for shares exists, and none is expected to develop in the future. Consequently, shareholders generally will not be able to liquidate their investment other than as a result of repurchases of their shares by the Fund.

The Fund will offer to repurchase at least 5% and up to 25% of its shares at NAV on a regular schedule. The Fund’s policy permits repurchases of between 5% and 25% of the Fund’s outstanding shares for each repurchase offer. The Fund will typically conduct quarterly repurchase offers for 10% of the Fund’s outstanding shares at their NAV per share, subject to applicable law and approval of the Board of Trustees.

The schedule requires the Fund to make repurchase offers every three months. Quarterly repurchase offers occur in the months of January, April, July and October. In the event a repurchase offer by the Fund is oversubscribed, the Fund may repurchase, but is not required to repurchase, additional shares up to a maximum amount of 2% of the outstanding shares of the Fund. If the Fund determines not to repurchase additional shares beyond the repurchase offer amount, or if shareholders submit for repurchase an amount of shares greater than that which the Fund is entitled to repurchase, the Fund will repurchase the shares submitted for repurchase on a pro rata basis. The Fund has no repurchases as of October 31, 2020.

3. Management Agreement

The Adviser manages the Fund’s portfolio. Management fees will be calculated daily at the annual rate of 1.75% on the Fund’s average daily net assets. In addition, under the management and administration agreements, certain other services and costs, including accounting, regulatory reporting and insurance premiums, will be paid by the Fund. The Fund did not incur or pay any management fees during the year ended October 31, 2020.

4. Transfer Agent

DST Systems, Inc., serves as the transfer agent to the Fund at negotiated rates and will provide substantially all transfer agent and shareowner services to the Fund at negotiated rates.

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5. Federal Income Taxes

The Fund intends to qualify as a ”regulated investment company” and to comply with the applicable provisions of the Internal Revenue Code, such that it will not be subject to federal income tax on taxable income (including realized capital gains) that is distributed to shareholders.

6. Expense Reimbursements

The Adviser has agreed to reimburse all fund expenses, estimated at approximately $64,793. This amount is disclosed in the Statement of Operations.

7. Risk

The respiratory illness COVID-19 caused by a novel coronavirus has resulted in a global pandemic and major disruption to economies and markets around the world, including the United States. Financial markets have experienced extreme volatility and severe losses, and trading in many instruments has been disrupted. Liquidity for many instruments has been greatly reduced for periods of time. Some interest rates are very low and in some cases yields are negative. Some sectors of the economy and individual issuers have experienced particularly large losses. These circumstances may continue for an extended period of time, and may continue to affect adversely the value and liquidity of the fund’s investments. The ultimate economic fallout from the pandemic, and the long-term impact on economies, markets, industries and individual issuers, are not known. Governments and central banks, including the Federal Reserve in the U.S., have taken extraordinary and unprecedented actions to support local and global economies and the financial markets. The impact of these measures, and whether they will be effective to mitigate the economic and market disruption, will not be known for some time.

8. Subsequent Event

On November 19, 2020, Amundi Pioneer Asset Management announced it will be rebranding the US business of Amundi as Amundi US effective January 1, 2021. The new brand identity will replace Amundi Pioneer, which was first adopted in July 2017 following the acquisition of Pioneer Investments by Amundi. In connection with these changes, Amundi Pioneer Asset Management. Inc., the investment adviser to the Pioneer funds, will change its name to Amundi Asset Management US, Inc. In addition, Amundi Pioneer Distributor, Inc., the Pioneer funds’ distributor, will change its name to Amundi Distributor US, Inc. The names of the Pioneer funds will not change in connection with this rebranding.

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Report of Independent Registered Public Accounting Firm

To the Board of Trustees and the Shareholders of

Pioneer ILS Bridge Fund:

Opinion on the Financial Statements

We have audited the accompanying statement of assets and liabilities of Pioneer ILS Bridge Fund (the “Fund”) as of October 31, 2020, and the related statement of operations for the year then ended, the statements of changes in net assets for each of the two years in the period then ended and the related notes (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Fund at October 31, 2020, the results of its operations for the year then ended, the changes in its net assets for each of the two years in the period then ended, in conformity with U.S. generally accepted accounting principles.

Basis for Opinion

These financial statements are the responsibility of the Fund’s management. Our responsibility is to express an opinion on the Fund’s financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (“PCAOB”) and are required to be independent with respect to the Fund in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. The Fund is not required to have, nor were we engaged to perform, an audit of the Fund’s internal control over financial reporting. As part of our audits, we are required to obtain an understanding of internal control over financial reporting, but not for the purpose of expressing an opinion on the effectiveness of the Fund’s internal control over financial reporting. Accordingly, we express no such opinion.

Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our procedures included confirmation of securities owned as of October 31, 2020, by correspondence with the custodian and brokers or by other appropriate auditing procedures where replies from brokers were not received. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.

We have served as the auditor of one or more Amundi Pioneer investment companies since 2017.

Boston, Massachusetts

December 18, 2020

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Approval of Investment Management Agreement

Amundi Pioneer Asset Management, Inc. (“APAM”) serves as the investment adviser to Pioneer ILS Bridge Fund (the “Fund”) pursuant to an investment management agreement between APAM and the Fund. In order for APAM to remain the investment adviser of the Fund, the Trustees of the Fund must determine annually whether to renew the investment management agreement for the Fund.

The contract review process began in January 2020 as the Trustees of the Fund agreed on, among other things, an overall approach and timeline for the process. Contract review materials were provided to the Trustees in March 2020, July 2020 and September 2020. In addition, the Trustees reviewed and discussed the Fund’s performance at regularly scheduled meetings throughout the year, and took into account other information related to the Fund provided to the Trustees at regularly scheduled meetings, in connection with the review of the Fund’s investment management agreement.

In March 2020, the Trustees, among other things, discussed the memorandum provided by Fund counsel that summarized the legal standards and other considerations that are relevant to the Trustees in their deliberations regarding the renewal of the investment management agreement, and reviewed and discussed the qualifications of the investment management teams for the Fund, as well as the level of investment by the Fund’s portfolio managers in the Fund. In July 2020, the Trustees, among other things, reviewed the Fund’s management fees and total expense ratios, the financial statements of APAM and its parent companies, profitability analyses provided by APAM, and analyses from APAM as to possible economies of scale. The Trustees also reviewed the profitability of the institutional business of APAM and APAM’s affiliate, Amundi Pioneer Institutional Asset Management, Inc. (“APIAM” and, together with APAM, “Amundi Pioneer”), as compared to that of APAM’s fund management business, and considered the differences between the fees and expenses of the Fund and the fees and expenses of APAM’s and APIAM’s institutional accounts, as well as the different services provided by APAM to the Fund and by APAM and APIAM to the institutional accounts. The Trustees further considered contract review materials, including additional materials received in response to the Trustees’ request, in September 2020.

At a meeting held on September 15, 2020, based on their evaluation of the information provided by APAM and third parties, the Trustees of the Fund, including the Independent Trustees voting separately, unanimously approved the renewal of the investment management agreement for another year. In approving the renewal of the investment management agreement, the Trustees considered various factors that they determined were relevant, including the factors described below. The Trustees did not identify any single factor as the controlling factor in determining to approve the renewal of the agreement.

Nature, Extent and Quality of Services

The Trustees noted that the Fund had not commenced operations. The Trustees considered the nature, extent and quality of the services that would be provided by APAM to the Fund under the management agreement, taking into account the investment objective and strategy of the Fund. The Trustees also reviewed APAM’s investment approach for the Fund and its research process. The Trustees considered the resources of APAM and the personnel of APAM who would provide investment management services to the Fund. The Trustees also considered that, as administrator, APAM would be responsible for the administration of the Fund’s business and other affairs. The Trustees considered the quality of such services provided by APAM to the other Pioneer Funds. The Trustees considered the fees to be paid to APAM for the provision of administration services. Based on these considerations, the Trustees concluded that the nature, extent and quality of services that APAM would provide to the Fund were satisfactory and consistent with the terms of the investment management agreement.

Performance of the Fund

The Trustees did not consider the Fund’s performance in approving the renewal of the investment management agreement because the Fund had not commenced operations and did not have a performance history.

Management Fee and Expenses

The Trustees noted that the Fund’s management fee and anticipated expense ratio were the same as the management fee and expense ratio charged by a fund managed by APAM that has an investment approach substantially similar to the Fund’s investment approach. The Trustees considered information showing the fees and expenses of the similar APAM-managed fund in comparison to the management fees of such fund’s peer group of funds as classified by Morningstar and also to the expense ratios of a peer group of funds selected on the basis of criteria determined by the Independent Trustees for this purpose using data provided by Strategic Insight Mutual Fund Research and Consulting, LLC (Strategic Insight), an independent third party. The peer group comparisons referred to below are organized in quintiles. Each quintile represents one-fifth of the peer group. In all peer group comparisons referred to below, first quintile is most favorable to the Fund’s shareowners.

The Trustees considered that the management fee for the most recent fiscal year charged by the fund managed by APAM that has an investment approach substantially similar to the Fund’s investment approach was in the fifth

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quintile relative to the management fees paid by other funds in such fund’s Strategic Insight peer group for the comparable period. The Trustees noted the investment management expertise and resources required to implement the complex investment strategy of the Fund and the similar APAM-managed fund. The Trustees also considered that the Fund and the similar APAM-managed fund did not have a clear cut peer group. The Trustees considered that the expense ratio for the most recent fiscal year charged by the fund managed by APAM that has an investment approach substantially similar to the Fund’s investment approach was in the fifth quintile relative to such fund’s Strategic Insight peer group for the comparable period.

The Trustees reviewed management fees charged by APAM and APIAM to institutional and other clients, including publicly offered European funds sponsored by APAM’s affiliates, unaffiliated U.S. registered investment companies (in a sub-advisory capacity), and unaffiliated foreign and domestic separate accounts. The Trustees also considered APAM’s costs in providing services to the Fund and APAM’s and APIAM’s costs in providing services to the other clients and considered the differences in management fees and profit margins for fund and non-fund services. In evaluating the fees associated with APAM’s and APIAM’s client accounts, the Trustees took into account the respective demands, resources and complexity associated with the Fund and other client accounts. The Trustees noted that, in some instances, the fee rates for those clients were lower than the management fee for the Fund and considered that, under the investment management agreement with the Fund, APAM performs additional services for the Fund that it does not provide to those other clients or services that are broader in scope, including oversight of the Fund’s other service providers and activities related to compliance and the extensive regulatory and tax regimes to which the Fund is subject. The Trustees also considered the entrepreneurial risks associated with APAM’s management of the Fund.

The Trustees concluded that the management fee payable by the Fund to APAM was reasonable in relation to the nature and quality of the services to be provided by APAM.

Profitability

The Trustees did not consider APAM’s profitability with respect to the management of the Fund in approving the investment management agreement because the Fund had not commenced operations and profitability information was not available.

Economies of Scale

The Trustees considered APAM’s views relating to economies of scale in connection with the Pioneer Funds as fund assets grow and the extent to which any such economies of scale are shared with the Fund and Fund shareholders. The Trustees recognize that economies of scale are difficult to identify and quantify, and that, among other factors that may be relevant, are the following: fee levels, expense subsidization, investment by APAM in research and analytical capabilities and APAM’s commitment and resource allocation to the Fund. The Trustees noted that profitability also may be an indicator of the availability of any economies of scale, although profitability may vary for other reasons including due to reductions in expenses. The Trustees concluded that economies of scale, if any, would be appropriately shared with the Fund.

Other Benefits

The Trustees considered the other potential benefits to APAM from its relationship with the Fund, including the character and amount of fees that would be paid by the Fund, other than under the investment management agreement, for services that would be provided by APAM and its affiliates, and the revenues and profitability of APAM’s businesses other than the fund business. .

The Trustees considered that Amundi Pioneer is the principal U.S. asset management business of Amundi, which is one of the largest asset managers globally. Amundi’s worldwide asset management business manages over $1.7 trillion in assets (including the Pioneer Funds). The Trustees considered that APAM’s relationship with Amundi creates potential opportunities for APAM, APIAM and Amundi that derive from APAM’s relationships with the Fund, including Amundi’s ability to market the services of APAM globally. The Trustees noted that APAM has access to additional research and portfolio management capabilities as a result of its relationship with Amundi and Amundi’s enhanced global presence that may contribute to an increase in the resources available to APAM. The Trustees considered that APAM and the Fund receive reciprocal intangible benefits from the relationship, including mutual brand recognition and, for the Fund, direct and indirect access to the resources of a large global asset manager. The Trustees concluded that any such benefits received by APAM as a result of its relationship with the Fund were reasonable.

Conclusion

After consideration of the factors described above as well as other factors, the Trustees, including the Independent Trustees, concluded that the investment management agreement for the Fund, including the fees payable thereunder, was fair and reasonable and voted to approve the proposed renewal of the investment management agreement.

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Trustees, Officers and Service Providers

Trustees	Officers
Thomas J. Perna, Chairman	Lisa M. Jones, President and
David R. Bock	Chief Executive Officer
Benjamin M. Friedman	Mark E. Bradley, Treasurer and
Margaret B.W. Graham	Chief Financial and
Lisa M. Jones	Accounting Officer
Lorraine H. Monchak	Christopher J. Kelley, Secretary and
Marguerite A. Piret	Chief Legal Officer
Fred J. Ricciardi
Kenneth J. Taubes

Investment Adviser and Administrator

Amundi Pioneer Asset Management, Inc.

Custodian and Sub-Administrator

Brown Brothers Harriman & Co.

Principal Underwriter

Amundi Pioneer Distributor, Inc.

Legal Counsel

Morgan, Lewis & Bockius LLP

Transfer Agent

DST Asset Manager Solutions, Inc.

Proxy Voting Policies and Procedures of the Fund are available without charge, upon request, by calling our toll free number (1-800-225-6292). Information regarding how the Fund voted proxies relating to portfolio securities during the most recent 12-month period ended June 30 is publicly available to shareowners at www.amundipioneer.com/us. This information is also available on the Securities and Exchange Commission’s web site at www.sec.gov.

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Trustees and officers

The Fund’s Trustees and officers are listed below, together with their principal occupations and other directorships they have held during at least the past five years. Trustees who are interested persons of the Fund within the meaning of the 1940 Act are referred to as Interested Trustees. Trustees who are not interested persons of the Fund are referred to as Independent Trustees. Each of the Trustees serves as a Trustee of each of the 45 U.S. registered investment portfolios for which Amundi Pioneer serves as investment adviser (the “Pioneer Funds”). The address for all Trustees and all officers of the Fund is 60 State Street, Boston, Massachusetts 02109.

Name, Age and Position Held With the Fund	Term of Office and Length of Service	Principal Occupation	Other Directorships Held by Trustee
Independent Trustees:
Thomas J. Perna (70) Chairman of the Board and Trustee	Trustee since 2016. Serves until a successor trustee is elected or earlier retirement or removal.	Private investor (2004 – 2008 and 2013 – present); Chairman (2008 – 2013) and Chief Executive Officer (2008 – 2012), Quadriserv, Inc. (technology products for securities lending industry); and Senior Executive Vice President, The Bank of New York (financial and securities services) (1986 – 2004)	Director, Broadridge Financial Solutions, Inc. (investor communications and securities processing provider for financial services industry) (2009 – present); Director, Quadriserv, Inc. (2005 – 2013); and Commissioner, New Jersey State Civil Service Commission (2011 – 2015)
John E. Baumgardner, Jr. (69) Trustee	Trustee since 2019. Serves until a successor trustee is elected or earlier retirement or removal.	Of Counsel (2019 – present), Partner (1983-2018), Sullivan & Cromwell LLP (law firm).	Chairman, The Lakeville Journal Company, LLC, (privately-held community newspaper group) (2015-present)
Diane Durnin (63) Trustee	Trustee since 2019. Serves until a successor trustee is elected or earlier retirement or removal.	Managing Director - Head of Product Strategy and Development, BNY Mellon Investment Management (investment management firm) (2012-2018); Vice Chairman – The Dreyfus Corporation (2005 – 2018): Executive Vice President Head of Product, BNY Mellon Investment Management (2007-2012); Executive Director- Product Strategy, Mellon Asset Management (2005-2007); Executive Vice President Head of Products, Marketing and Client Service, Dreyfus Corporation (investment management firm) (2000-2005); and Senior Vice President Strategic Product and Business Development, Dreyfus Corporation (1994-2000)	None

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Name, Age and Position Held With the Fund	Term of Office and Length of Service	Principal Occupation	Other Directorships Held by Trustee
Benjamin M. Friedman (76) Trustee	Trustee since 2016. Serves until a successor trustee is elected or earlier retirement or removal.	William Joseph Maier Professor of Political Economy, Harvard University (1972 – present)	Trustee, Mellon Institutional Funds Investment Trust and Mellon Institutional Funds Master Portfolio (oversaw 17 portfolios in fund complex) (1989 - 2008)
Lorraine H. Monchak (64) Trustee	Trustee since 2017. (Advisory Trustee from 2014 - 2017). Serves until a successor trustee is elected or earlier retirement or removal.	Chief Investment Officer, 1199 SEIU Funds (healthcare workers union pension funds) (2001 – present); Vice President – International Investments Group, American International Group, Inc. (insurance company) (1993 – 2001); Vice President – Corporate Finance and Treasury Group, Citibank, N.A. (1980 – 1986 and 1990 – 1993); Vice President – Asset/Liability Management Group, Federal Farm Funding Corporation (government-sponsored issuer of debt securities) (1988 – 1990); Mortgage Strategies Group, Shearson Lehman Hutton, Inc. (investment bank) (1987 – 1988); and Mortgage Strategies Group, Drexel Burnham Lambert, Ltd. (investment bank) (1986 – 1987)	None
Marguerite A. Piret (72) Trustee	Trustee since 2016. Serves until a successor trustee is elected or earlier retirement or removal.	Chief Financial Officer, American Ag Energy, Inc. (controlled environment and agriculture company) (2016 – present); and President and Chief Executive Officer, Metric Financial Inc. (formerly known as Newbury Piret Company) (investment banking firm) (1981 – 2019)	Director of New America High Income Fund, Inc. (closed-end investment company) (2004 – present); and Member, Board of Governors, Investment Company Institute (2000 – 2006)

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Name, Age and Position Held With the Fund	Term of Office and Length of Service	Principal Occupation	Other Directorships Held by Trustee
Fred J. Ricciardi (73) Trustee	Trustee since 2016. Serves until a successor trustee is elected or earlier retirement or removal.	Private investor (2020 – present); Consultant (investment company services) (2012 – 2020); Executive Vice President, BNY Mellon (financial and investment company services) (1969 – 2012); Director, BNY International Financing Corp. (financial services) (2002 – 2012); Director, Mellon Overseas Investment Corp. (financial services) (2009 – 2012); Director, Financial Models (technology) (2005-2007); Director, BNY Hamilton Funds, Ireland (offshore investment companies) (2004-2007); Chairman/Director, AIB/BNY Securities Services, Ltd., Ireland (financial services) (1999-2006); and Chairman, BNY Alternative Investment Services, Inc. (financial services) (2005-2007)	None

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Name, Age and Position Held With the Fund	Term of Office and Length of Service	Principal Occupation	Other Directorships Held by Trustee
Interested Trustees:
Lisa M. Jones (58)* Trustee, President and Chief Executive Officer	Trustee since 2017. Serves until a successor trustee is elected or earlier retirement or removal	Director, CEO and President of Amundi Pioneer Asset Management USA, Inc. (investment management firm) (since September 2014); Director, CEO and President of Amundi Pioneer Asset Management, Inc. (since September 2014); Director, CEO and President of Amundi Pioneer Distributor, Inc. (since September 2014); Director, CEO and President of Amundi Pioneer Institutional AssetManagement, Inc. (since September 2014); Chair, Amundi Pioneer Asset Management USA, Inc., Amundi Pioneer Distributor, Inc. and Amundi Pioneer Institutional Asset Management, Inc. (September 2014 – 2018); Managing Director, Morgan Stanley Investment Management (investment management firm) (2010 – 2013); Director of Institutional Business, CEO of International, Eaton VanceManagement (investment management firm) (2005 – 2010); and Director of Amundi USA, Inc. (since 2017)	None
Kenneth J. Taubes (62)* Trustee	Trustee since 2016. Serves until a successor trustee is elected or earlier retirement or removal	Director and Executive VicePresident (since 2008) and Chief Investment Officer, U.S. (since 2010) of Amundi Pioneer Asset Management USA, Inc. (investment management firm); Director and Executive Vice President and Chief Investment Officer, U.S. of Amundi Pioneer (since 2008); Executive Vice President and Chief Investment Officer, U.S. of Amundi Pioneer Institutional Asset Management, Inc. (since 2009); Portfolio Manager of Amundi Pioneer (since 1999); and Director of Amundi USA, Inc. (since 2017)	None

*	Ms. Jones and Mr. Taubes are Interested Trustees because they are officers or directors of the Fund’s investment adviser and certain of its affiliates.

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Name, Age and Position Held With the Fund	Term of Office and Length of Service	Principal Occupation	Other Directorships Held by Officer
Fund Officers:
Christopher J. Kelley (55) Secretary and Chief Legal Officer	Since 2016. Serves at the discretion of the Board	Vice President and Associate General Counsel of Amundi Pioneer since January 2008; Secretary and Chief Legal Officer of all of the Pioneer Funds since June 2010; Assistant Secretary of all of the Pioneer Funds from September 2003 to May 2010; and Vice President and Senior Counsel of Amundi Pioneer from July 2002 to December 2007	None
Carol B. Hannigan (59) Assistant Secretary	Since 2016. Serves at the discretion of the Board	Fund Governance Director of Amundi Pioneer since December 2006 and Assistant Secretary of all the Pioneer Funds since June 2010; Manager – Fund Governance of Amundi Pioneer from December 2003 to November 2006; and Senior Paralegal of Amundi Pioneer from January 2000 to November 2003	None
Thomas Reyes (57) Assistant Secretary	Since 2016. Serves at the discretion of the Board	Assistant General Counsel of Amundi Pioneer since May 2013 and Assistant Secretary of all the Pioneer Funds since June 2010; and Counsel of Amundi Pioneer from June 2007 to May 2013	None
Mark E. Bradley (60) Treasurer and Chief Financial and Accounting Officer	Since 2016. Serves at the discretion of the Board	Vice President – Fund Treasury of Amundi Pioneer; Treasurer of all of the Pioneer Funds since March 2008; Deputy Treasurer of Amundi Pioneer from March 2004 to February 2008; and Assistant Treasurer of all of the Pioneer Funds from March 2004 to February 2008	None
Luis I. Presutti (55) Assistant Treasurer	Since 2016. Serves at the discretion of the Board	Director – Fund Treasury of Amundi Pioneer; and Assistant Treasurer of all of the Pioneer Funds	None
Gary Sullivan (62) Assistant Treasurer	Since 2016. Serves at the discretion of the Board	Senior Manager – Fund Treasury of Amundi Pioneer; and Assistant Treasurer of all of the Pioneer Funds	None
Antonio Furtado (38) Assistant Treasurer	Since 2020. Serves at the discretion of the Board	Fund Oversight Manager – Fund Treasury of Amundi Pioneer; and Assistant Treasurer of all of the Pioneer Funds	None

16 Pioneer ILS Bridge Fund | Annual Report | 10/31/20

Name, Age and Position Held With the Fund	Term of Office and Length of Service	Principal Occupation	Other Directorships Held by Officer
John Malone (48) Chief Compliance Officer	Since 2018. Serves at the discretion of the Board	Managing Director, Chief Compliance Officer of Amundi Pioneer Asset Management; Amundi Pioneer Institutional Asset Management, Inc.; and the Pioneer Funds since September 2018; and Chief Compliance Officer of Amundi Pioneer Distributor, Inc. since January 2014.	None
Kelly O’Donnell (49) Anti-Money Laundering Officer	Since 2016. Serves at the discretion of the Board	Vice President – Amundi Pioneer Asset Management; and Anti-Money Laundering Officer of all the Pioneer Funds since 2006	None

17 Pioneer ILS Bridge Fund | Annual Report | 10/31/20

ITEM 2. CODE OF ETHICS.

(a) Disclose whether, as of the end of the period covered by the report, the registrant has adopted a code of ethics that applies to the registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party. If the registrant has not adopted such a code of ethics, explain why it has not done so.

The registrant has adopted, as of the end of the period covered by this report, a code of ethics that applies to the registrant’s principal executive officer, principal financial officer, principal accounting officer and controller.

(b) For purposes of this Item, the term “code of ethics” means written standards that are reasonably designed to deter wrongdoing and to promote:

(1) Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;

(2) Full, fair, accurate, timely, and understandable disclosure in reports and documents that a registrant files with, or submits to, the Commission and in other public communications made by the registrant;

(3) Compliance with applicable governmental laws, rules, and regulations;

(4) The prompt internal reporting of violations of the code to an appropriate person or persons identified in the code; and

(5) Accountability for adherence to the code.

(c) The registrant must briefly describe the nature of any amendment, during the period covered by the report, to a provision of its code of ethics that applies to the registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party, and that relates to any element of the code of ethics definition enumerated in paragraph (b) of this Item. The registrant must file a copy of any such amendment as an exhibit pursuant to Item 10(a), unless the registrant has elected to satisfy paragraph (f) of this Item by posting its code of ethics on its website pursuant to paragraph (f)(2) of this Item, or by undertaking to provide its code of ethics to any person without charge, upon request, pursuant to paragraph (f)(3) of this Item.

The registrant has made no amendments to the code of ethics during the period covered by this report.

(d) If the registrant has, during the period covered by the report, granted a waiver, including an implicit waiver, from a provision of the code of ethics to the registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party, that relates to one or more of the items set forth in paragraph (b) of this Item, the registrant must briefly describe the nature of the waiver, the name of the person to whom the waiver was granted, and the date of the waiver.

Not applicable.

(e) If the registrant intends to satisfy the disclosure requirement under paragraph (c) or (d) of this Item regarding an amendment to, or a waiver from, a provision of its code of ethics that applies to the registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions and that relates to any element of the code of ethics definition

enumerated in paragraph (b) of this Item by posting such information on its Internet website, disclose the registrant’s Internet address and such intention.

Not applicable.

(f) The registrant must:

(1) File with the Commission, pursuant to Item 12(a)(1), a copy of its code of ethics that applies to the registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, as an exhibit to its annual report on this Form N-CSR (see attachment);

(2) Post the text of such code of ethics on its Internet website and disclose, in its most recent report on this Form N-CSR, its Internet address and the fact that it has posted such code of ethics on its Internet website; or

(3) Undertake in its most recent report on this Form N-CSR to provide to any person without charge, upon request, a copy of such code of ethics and explain the manner in which such request may be made. See Item 10(2)

ITEM 3. AUDIT COMMITTEE FINANCIAL EXPERT.

(a) (1) Disclose that the registrant’s board of trustees has determined that the registrant either:

(i) Has at least one audit committee financial expert serving on its audit committee; or

(ii) Does not have an audit committee financial expert serving on its audit committee.

The registrant’s Board of Trustees has determined that the registrant has at least one audit committee financial expert.

(2) If the registrant provides the disclosure required by paragraph (a)(1)(i) of this Item, it must disclose the name of the audit committee financial expert and whether that person is “independent.” In order to be considered “independent” for purposes of this Item, a member of an audit committee may not, other than in his or her capacity as a member of the audit committee, the board of trustees, or any other board committee:

(i) Accept directly or indirectly any consulting, advisory, or other compensatory fee from the issuer; or

(ii) Be an “interested person” of the investment company as defined in Section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19)).

Mr. Fred J. Ricciardi, an independent trustee, is such an audit committee financial expert.

(3) If the registrant provides the disclosure required by paragraph (a)(1) (ii) of this Item, it must explain why it does not have an audit committee financial expert.

Not applicable.

ITEM 4. PRINCIPAL ACCOUNTANT FEES AND SERVICES.

(a) Disclose, under the caption AUDIT FEES, the aggregate fees billed for each of the last two fiscal years for professional services rendered by the principal accountant for the audit of the registrant’s annual financial statements or services that are normally provided by the accountant in connection with statutory and regulatory filings or engagements for those fiscal years.

The audit fees for the Fund were $10,200 payable to Ernst & Young LLP for the year ended October 31, 2020 and $10,000 for the year ended October 31, 2019.

(b) Disclose, under the caption AUDIT-RELATED FEES, the aggregate fees billed in each of the last two fiscal years for assurance and related services by the principal accountant that are reasonably related to the performance of the audit of the registrant’s financial statements and are not reported under paragraph (a) of this Item. Registrants shall describe the nature of the services comprising the fees disclosed under this category.

There were no audit-related services in 2020 or 2019.

(c) Disclose, under the caption TAX FEES, the aggregate fees billed in each of the last two fiscal years for professional services rendered by the principal accountant for tax compliance, tax advice, and tax planning. Registrants shall describe the nature of the services comprising the fees disclosed under this category.

The Fund paid aggregate non-audit fees to Ernst & Young LLP for tax services of $0 and $0 during the fiscal years ended October 31, 2020 and 2019, respectively.

(d) Disclose, under the caption ALL OTHER FEES, the aggregate fees billed in each of the last two fiscal years for products and services provided by the principal accountant, other than the services reported in paragraphs (a) through (c) of this Item. Registrants shall describe the nature of the services comprising the fees disclosed under this category.

There were no other fees in 2020 or 2019.

(e) (1) Disclose the audit committee’s pre-approval policies and procedures described in paragraph (c)(7) of Rule 2-01 of Regulation S-X.

PIONEER FUNDS

APPROVAL OF AUDIT, AUDIT-RELATED, TAX AND OTHER SERVICES

PROVIDED BY THE INDEPENDENT AUDITOR

SECTION I - POLICY PURPOSE AND APPLICABILITY

The Pioneer Funds recognize the importance of maintaining the independence of their outside auditors. Maintaining independence is a shared responsibility involving Amundi Pioneer Asset Management, Inc, the audit committee and the independent auditors.

The Funds recognize that a Fund’s independent auditors: 1) possess knowledge of the Funds, 2) are able to incorporate certain services into the scope of the audit, thereby avoiding redundant work, cost and disruption of Fund personnel and processes, and 3) have expertise that has value to the Funds. As a result, there are situations where it is desirable to use the Fund’s independent auditors for services in addition to the annual audit and where the potential for conflicts of interests are minimal. Consequently, this policy, which is intended to comply with Rule 210.2-01(C)(7), sets forth guidelines and procedures to

be followed by the Funds when retaining the independent audit firm to perform audit, audit-related tax and other services under those circumstances, while also maintaining independence.

Approval of a service in accordance with this policy for a Fund shall also constitute approval for any other Fund whose pre-approval is required pursuant to Rule 210.2-01(c)(7)(ii).

In addition to the procedures set forth in this policy, any non-audit services that may be provided consistently with Rule 210.2-01 may be approved by the Audit Committee itself and any pre-approval that may be waived in accordance with Rule 210.2-01(c)(7)(i)(C) is hereby waived.

Selection of a Fund’s independent auditors and their compensation shall be determined by the Audit Committee and shall not be subject to this policy.


SECTION II - POLICY

SERVICE CATEGORY	SERVICE CATEGORY DESCRIPTION	SPECIFIC PRE-APPROVED SERVICE SUBCATEGORIES

I. AUDIT SERVICES	Services that are directly	o Accounting research assistance
	related to performing the	o SEC consultation, registration
	independent audit of the Funds	statements, and reporting
		o Tax accrual related matters
		o Implementation of new accounting standards
		o Compliance letters (e.g. rating agency letters)
		o Regulatory reviews and assistance
		regarding financial matters
		o Semi-annual reviews (if requested)
		o Comfort letters for closed end offerings
II. AUDIT-RELATED	Services which are not	o AICPA attest and agreed-upon procedures
SERVICES	prohibited under Rule	o Technology control assessments
	210.2-01(C)(4) (the “Rule”)	o Financial reporting control assessments
	and are related extensions of	o Enterprise security architecture
	the audit services support the	assessment
	audit, or use the knowledge/expertise
	gained from the audit procedures as a
	foundation to complete the project.
	In most cases, if the Audit-Related
	Services are not performed by the
	Audit firm, the scope of the Audit
	Services would likely increase.
	The Services are typically well-defined
	and governed by accounting
	professional standards (AICPA,
	SEC, etc.)

AUDIT COMMITTEE APPROVAL POLICY		AUDIT COMMITTEE REPORTING POLICY
o “One-time” pre-approval		o A summary of all such
for the audit period for all		services and related fees
pre-approved specific service		reported at each regularly
subcategories. Approval of the		scheduled Audit Committee
independent auditors as		meeting.
auditors for a Fund shall
constitute pre approval for
these services.

o “One-time” pre-approval		o A summary of all such
for the fund fiscal year within		services and related fees
a specified dollar limit		(including comparison to
for all pre-approved		specified dollar limits)
specific service subcategories		reported quarterly.

o Specific approval is
needed to exceed the
pre-approved dollar limit for
these services (see general
Audit Committee approval policy
below for details on obtaining
specific approvals)

o Specific approval is
needed to use the Fund’s
auditors for Audit-Related
Services not denoted as
“pre-approved”, or
to add a specific service
subcategory as “pre-approved”

SECTION III - POLICY DETAIL, CONTINUED


SERVICE CATEGORY	SERVICE CATEGORY DESCRIPTION	SPECIFIC PRE-APPROVED SERVICE
		SUBCATEGORIES
III. TAX SERVICES	Services which are not	o Tax planning and support
	prohibited by the Rule,	o Tax controversy assistance
	if an officer of the Fund	o Tax compliance, tax returns, excise
	determines that using the	tax returns and support
	Fund’s auditor to provide	o Tax opinions
	these services creates
	significant synergy in
	the form of efficiency,
	minimized disruption, or
	the ability to maintain a
	desired level of
	confidentiality.


AUDIT COMMITTEE APPROVAL POLICY	AUDIT COMMITTEE REPORTING POLICY
o “One-time” pre-approval	o A summary of
for the fund fiscal year	all such services and
within a specified dollar limit	related fees
	(including comparison
	to specified dollar
	limits) reported
	quarterly.

o Specific approval is
needed to exceed the
pre-approved dollar limits for
these services (see general
Audit Committee approval policy
below for details on obtaining
specific approvals)

o Specific approval is
needed to use the Fund’s
auditors for tax services not
denoted as pre-approved, or to
add a specific service subcategory as
“pre-approved”

SECTION III - POLICY DETAIL, CONTINUED


SERVICE CATEGORY	SERVICE CATEGORY DESCRIPTION	SPECIFIC PRE-APPROVED SERVICE
		SUBCATEGORIES
IV. OTHER SERVICES	Services which are not	o Business Risk Management support
	prohibited by the Rule,	o Other control and regulatory
A. SYNERGISTIC,	if an officer of the Fund	compliance projects
UNIQUE QUALIFICATIONS	determines that using the
	Fund’s auditor to provide
	these services creates
	significant synergy in
	the form of efficiency,
	minimized disruption,
	the ability to maintain a
	desired level of
	confidentiality, or where
	the Fund’s auditors
	posses unique or superior
	qualifications to provide
	these services, resulting
	in superior value and
	results for the Fund.


AUDIT COMMITTEE APPROVAL POLICY	AUDIT COMMITTEE REPORTING POLICY
o “One-time” pre-approval	o A summary of
for the fund fiscal year within	all such services and
a specified dollar limit	related fees
	(including comparison
	to specified dollar
	limits) reported
	quarterly.
o Specific approval is
needed to exceed the
pre-approved dollar limits for
these services (see general
Audit Committee approval policy
below for details on obtaining
specific approvals)

o Specific approval is
needed to use the Fund’s
auditors for “Synergistic” or
“Unique Qualifications” Other
Services not denoted as
pre-approved to the left, or to
add a specific service
subcategory as “pre-approved”

SECTION III - POLICY DETAIL, CONTINUED


SERVICE CATEGORY	SERVICE CATEGORY DESCRIPTION	SPECIFIC PROHIBITED SERVICE
		SUBCATEGORIES
PROHIBITED SERVICES	Services which result	1. Bookkeeping or other services
	in the auditors losing	related to the accounting records or
	independence status	financial statements of the audit
	under the Rule.	client*
		2. Financial information systems design
		and implementation*
		3. Appraisal or valuation services,
		fairness* opinions, or
		contribution-in-kind reports
		4. Actuarial services (i.e., setting
		actuarial reserves versus actuarial
		audit work)*
		5. Internal audit outsourcing services*
		6. Management functions or human
		resources
		7. Broker or dealer, investment
		advisor, or investment banking services
		8. Legal services and expert services
		unrelated to the audit
		9. Any other service that the Public
		Company Accounting Oversight Board
		determines, by regulation, is
		impermissible


AUDIT COMMITTEE APPROVAL POLICY	AUDIT COMMITTEE REPORTING POLICY
o These services are not to be	o A summary of all
performed with the exception of the(*)	services and related
services that may be permitted	fees reported at each
if they would not be subject to audit	regularly scheduled
procedures at the audit client (as	Audit Committee meeting
defined in rule 2-01(f)(4)) level	will serve as continual
the firm providing the service.	confirmation that has
	not provided any
	restricted services.

GENERAL AUDIT COMMITTEE APPROVAL POLICY:

o For all projects, the officers of the Funds and the Fund’s auditors will each make an assessment to determine that any proposed projects will not impair independence.

o Potential services will be classified into the four non-restricted service categories and the “Approval of Audit, Audit-Related, Tax and Other Services” Policy above will be applied. Any services outside the specific pre-approved service subcategories set forth above must be specifically approved by the Audit Committee.

o At least quarterly, the Audit Committee shall review a report summarizing the services by service category, including fees, provided by the Audit firm as set forth in the above policy.

(2) Disclose the percentage of services described in each of paragraphs (b) through (d) of this Item that were approved by the audit committee pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X.

Non-Audit Services

Beginning with non-audit service contracts entered into on or after May 6, 2003, the effective date of the new SEC pre-approval rules, the Trust’s audit committee is required to pre-approve services to affiliates defined by SEC rules to the extent that the services are determined to have a direct impact on the

operations or financial reporting of the Trust. For the years ended October 31, 2020 and 2019, there were no services provided to an affiliate that required the Trust’s audit committee pre-approval.

(f) If greater than 50 percent, disclose the percentage of hours expended on the principal accountants engagement to audit the registrant’s financial statements for the most recent fiscal year that were attributed to work performed by persons other than the principal accountant’s full-time, permanent employees.

N/A

(g) Disclose the aggregate non-audit fees billed by the registrants accountant for services rendered to the registrant, and rendered to the registrants investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the registrant for each of the last two fiscal years of the registrant.

The Fund paid aggregate non-audit fees to Ernst & Young LLP for tax services of $0 and $0 during the fiscal years ended October 31, 2020 and 2019, respectively.

(h) Disclose whether the registrants audit committee of the board of trustees has considered whether the provision of non-audit services that were rendered to the registrants investment adviser (not including any subadviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the investment adviser that provides ongoing services to the registrant that were not pre-approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X is compatible with maintaining the principal accountant’s independence.

The Fund’s audit committee of the Board of Trustees has considered whether the provision of non-audit services that were rendered to the Affiliates (as defined) that were not pre- approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X is compatible with maintaining the principal accountant’s independence.

ITEM 5. AUDIT COMMITTEE OF LISTED REGISTRANTS

(a) If the registrant is a listed issuer as defined in Rule 10A-3 under the Exchange Act (17 CFR 240.10A-3), state whether or not the registrant has a separately-designated standing audit committee established in accordance with Section 3(a)(58)(A) of the Exchange Act (15 U.S.C. 78c(a)(58)(A)). If the registrant has such a committee, however designated, identify each committee member. If the entire board of directors is acting as the registrant’s audit committee as specified in Section 3(a)(58)(B) of the Exchange Act (15 U.S.C. 78c(a)(58)(B)), so state.

N/A

(b) If applicable, provide the disclosure required by Rule 10A-3(d) under the Exchange Act (17 CFR 240.10A-3(d)) regarding an exemption from the listing standards for audit committees.

N/A

ITEM 6. SCHEDULE OF INVESTMENTS.

File Schedule of Investments in securities of unaffiliated issuers as of the close of the reporting period as set forth in 210.1212 of Regulation S-X [17 CFR 210.12-12], unless the schedule is included as part of the report to shareholders filed under Item 1 of this Form.

Included in Item 1

ITEM 7. DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

A closed-end management investment company that is filing an annual report on this Form N-CSR must, unless it invests exclusively in non-voting securities, describe the policies and procedures that it uses to determine how to vote proxies relating to portfolio securities, including the procedures that the company uses when a vote presents a conflict between the interests of its shareholders, on the one hand, and those of the company’s investment adviser; principal underwriter; or any affiliated person (as defined in Section 2(a)(3) of the Investment Company Act of 1940 (15 U.S.C. 80a-2(a)(3)) and the rules thereunder) of the company, its investment adviser, or its principal underwriter, on the other. Include any policies and procedures of the company’s investment adviser, or any other third party, that the company uses, or that are used on the company’s behalf, to determine how to vote proxies relating to portfolio securities.

Proxy Voting Policies and Procedures of

Pioneer Investment Management, Inc.

VERSION DATED July, 2004

Overview

Pioneer Investment Management, Inc. (“Pioneer”) is a fiduciary that owes

each of its client’s duties of care and loyalty with respect to all

services undertaken on the client’s behalf, including proxy voting. When

Pioneer has been delegated proxy-voting authority for a client, the duty of

care requires Pioneer to monitor corporate events and to vote the proxies.

To satisfy its duty of loyalty, Pioneer must place its client’s interests

ahead of its own and must cast proxy votes in a manner consistent with the

best interest of its clients. Pioneer will vote all proxies presented in a

timely manner.

The Proxy Voting Policies and Procedures are designed to complement

Pioneer’s investment policies and procedures regarding its general

responsibility to monitor the performance and/or corporate events of

companies that are issuers of securities held in accounts managed by

Pioneer. Pioneer’s Proxy Voting Policies summarize Pioneer’s position on a

number of issues solicited by companies held by Pioneer’s clients. The

policies are guidelines that provide a general indication on how Pioneer

would vote but do not include all potential voting scenarios.

Pioneer’s Proxy Voting Procedures detail monitoring of voting, exception

votes, and review of conflicts of interest and ensure that case-by-case

votes are handled within the context of the overall guidelines (i.e. best

interest of client). The overriding goal is that all proxies for US and

non-US companies that are received promptly will be voted in accordance

with Pioneer’s policies or specific client instructions. All shares in a

company held by Pioneer-managed accounts will be voted alike, unless a

client has given us specific voting instructions on an issue or has not

delegated authority to us or the Proxy Voting Oversight Group determines

that the circumstances justify a different approach.

Pioneer does not delegate the authority to vote proxies relating to its

clients to any of its affiliates, which include other subsidiaries of

UniCredito.

Any questions about these policies and procedures should be directed to the

Proxy Coordinator.

Proxy Voting Procedures

Proxy Voting Service

Pioneer has engaged an independent proxy voting service to assist in the

voting of proxies. The proxy voting service works with custodians to ensure

that all proxy materials are received by the custodians and are processed

in a timely fashion. To the extent applicable, the proxy voting service

votes all proxies in accordance with the proxy voting policies established

by Pioneer. The proxy voting service will refer proxy questions to the

Proxy Coordinator (described below) for instructions under circumstances

where: (1) the application of the proxy voting guidelines is unclear; (2) a

particular proxy question is not covered by the guidelines; or (3) the

guidelines call for specific instructions on a case-by-case basis. The

proxy voting service is also requested to call to the Proxy Coordinator’s

attention specific proxy questions that, while governed by a guideline,

appear to involve unusual or controversial issues. Pioneer reserves the

right to attend a meeting in person and may do so when it determines that

the company or the matters to be voted on at the meeting are strategically

important to its clients.

Proxy Coordinator

Pioneer’s Director of Investment Operations (the “Proxy Coordinator”)

coordinates the voting, procedures and reporting of proxies on behalf of

Pioneer’s clients. The Proxy Coordinator will deal directly with the proxy

voting service and, in the case of proxy questions referred by the proxy

voting service, will solicit voting recommendations and instructions from

the Director of Portfolio Management US or, to the extent applicable,

investment sub-advisers. The Proxy Coordinator is responsible for ensuring

that these questions and referrals are responded to in a timely fashion and

for transmitting appropriate voting instructions to the proxy voting

service. The Proxy Coordinator is responsible for verifying with the

Compliance Department whether Pioneer’s voting power is subject to any

limitations or guidelines issued by the client (or in the case of an

employee benefit plan, the plan’s trustee or other fiduciaries).

Referral Items

From time to time, the proxy voting service will refer proxy questions to

the Proxy Coordinator that are described by Pioneer’s policy as to be voted

on a case-by-case basis, that are not covered by Pioneer’s guidelines or

where Pioneer’s guidelines may be unclear with respect to the matter to be

voted on. Under such certain circumstances, the Proxy Coordinator will seek

a written voting recommendation from the Director of Portfolio Management

US. Any such recommendation will include: (i) the manner in which the

proxies should be voted; (ii) the rationale underlying any such decision;

and (iii) the disclosure of any contacts or communications made between

Pioneer and any outside parties concerning the proxy proposal prior to the

time that the voting instructions are provided. In addition, the Proxy

Coordinator will ask the Compliance Department to review the question for

any actual or apparent conflicts of interest as described below under

“Conflicts of

Interest.” The Compliance Department will provide a “Conflicts of Interest

Report,” applying the criteria set forth below under “Conflicts of

Interest,” to the Proxy Coordinator summarizing the results of its review.

In the absence of a conflict of interest, the Proxy Coordinator will vote

in accordance with the recommendation of the Director of Portfolio

Management US.

If the matter presents a conflict of interest for Pioneer, then the Proxy

Coordinator will refer the matter to the Proxy Voting Oversight Group for a

decision. In general, when a conflict of interest is present, Pioneer will

vote according to the recommendation of the Director of Portfolio

Management US where such recommendation would go against Pioneer’s interest

or where the conflict is deemed to be immaterial. Pioneer will vote

according to the recommendation of its proxy voting service when the

conflict is deemed to be material and the Pioneer’s internal vote

recommendation would favor Pioneer’s interest, unless a client specifically

requests Pioneer to do otherwise. When making the final determination as to

how to vote a proxy, the Proxy Voting Oversight Group will review the

report from the Director of Portfolio Management US and the Conflicts of

Interest Report issued by the Compliance Department.

Conflicts of Interest

A conflict of interest occurs when Pioneer’s interests interfere, or appear

to interfere with the interests of Pioneer’s clients. Occasionally, Pioneer

may have a conflict that can affect how its votes proxies. The conflict may

be actual or perceived and may exist when the matter to be voted on

concerns:

o An affiliate of Pioneer, such as another company belonging to

the UniCredito Italiano S.p.A. banking group (a “UniCredito

Affiliate”);

o An issuer of a security for which Pioneer acts as a sponsor,

advisor, manager, custodian, distributor, underwriter, broker, or

other similar capacity (including those securities specifically

declared by PGAM to present a conflict of interest for Pioneer);

o An issuer of a security for which UniCredito has informed Pioneer

that a UniCredito Affiliate acts as a sponsor, advisor, manager,

custodian, distributor, underwriter, broker, or other similar

capacity; or

o A person with whom Pioneer (or any of its affiliates) has an

existing, material contract or business relationship that was not

entered into in the ordinary course of Pioneer’s business.

o Pioneer will abstain from voting with respect to companies

directly or indirectly owned by UniCredito Italiano Group, unless

otherwise directed by a client. In addition, Pioneer will inform

PGAM Global Compliance and the PGAM Independent Directors before

exercising such rights.

Any associate involved in the proxy voting process with knowledge of any

apparent or actual conflict of interest must disclose such conflict to the

Proxy Coordinator and the Compliance Department. The Compliance Department

will review each item referred to Pioneer to determine whether an actual or

potential conflict of interest with Pioneer exists in connection with the

proposal(s) to be voted upon. The review will be conducted by comparing the

apparent parties affected by the proxy proposal being

voted upon against the Compliance Department’s internal list of interested

persons and, for any matches found, evaluating the anticipated magnitude

and possible probability of any conflict of interest being present. For

each referral item, the determination regarding the presence or absence of

any actual or potential conflict of interest will be documented in a

Conflicts of Interest Report to the Proxy Coordinator.

Securities Lending

In conjunction with industry standards Proxies are not available to be

voted when the shares are out on loan through either Pioneer’s lending

program or a client’s managed security lending program. However, Pioneer

will reserve the right to recall lent securities so that they may be voted

�� according to the Pioneer’s instructions. If a portfolio manager would like

to vote a block of previously lent shares, the Proxy Coordinator will work

with the portfolio manager and Investment Operations to recall the

security, to the extent possible, to facilitate the vote on the entire

block of shares.

Share-Blocking

“Share-blocking” is a market practice whereby shares are sent to a

custodian (which may be different than the account custodian) for record

keeping and voting at the general meeting. The shares are unavailable for

sale or delivery until the end of the blocking period (typically the day

after general meeting date).

Pioneer will vote in those countries with “share-blocking.” In the event a

manager would like to sell a security with “share-blocking”, the Proxy

Coordinator will work with the Portfolio Manager and Investment Operations

Department to recall the shares (as allowable within the market time-frame

and practices) and/or communicate with executing brokerage firm. A list of

countries with “share-blocking” is available from the Investment Operations

Department upon request.

Record Keeping

The Proxy Coordinator shall ensure that Pioneer’s proxy voting service:

o Retains a copy of the proxy statement received (unless the proxy

statement is available from the SEC’s Electronic Data Gathering,

Analysis, and Retrieval (EDGAR) system);

o Retains a record of the vote cast;

o Prepares Form N-PX for filing on behalf of each client that is a

registered investment company; and

o Is able to promptly provide Pioneer with a copy of the voting

record upon its request.

The Proxy Coordinator shall ensure that for those votes that may require

additional documentation (i.e. conflicts of interest, exception votes and

case-by-case votes) the following records are maintained:

o A record memorializing the basis for each referral vote cast;

o A copy of any document created by Pioneer that was material in

making the decision on how to vote the subject proxy; and

o A copy of any conflict notice, conflict consent or any other

written communication (including emails or other electronic

communications) to or from the client (or in the case of an

employee benefit plan, the plan’s trustee or other fiduciaries)

regarding the subject proxy vote cast by, or the vote

recommendation of, Pioneer.

o Pioneer shall maintain the above records in the client’s file for a

period not less than ten (10) years.

Disclosure

Pioneer shall take reasonable measures to inform its clients of the process

or procedures clients must follow to obtain information regarding how

Pioneer voted with respect to assets held in their accounts. In addition,

Pioneer shall describe to clients its proxy voting policies and procedures

and will furnish a copy of its proxy voting policies and procedures upon

request. This information may be provided to clients through Pioneer’s Form

ADV (Part II) disclosure, by separate notice to the client, or through

Pioneer’s website.

Proxy Voting Oversight Group

The members of the Proxy Voting Oversight Group are Pioneer’s: Director of

Portfolio Management US, Head of Investment Operations, and Director of

Compliance. Other members of Pioneer will be invited to attend meetings and

otherwise participate as necessary. The Head of Investment Operations will

chair the Proxy Voting Oversight Group.

The Proxy Voting Oversight Group is responsible for developing, evaluating,

and changing (when necessary) Pioneer’s Proxy Voting Policies and

Procedures. The group meets at least annually to evaluate and review these

policies and procedures and the services of its third-party proxy voting

service. In addition, the Proxy Voting Oversight Group will meet as

necessary to vote on referral items and address other business as

necessary.

Amendments

Pioneer may not amend its Proxy Voting Policies And Procedures without the

prior approval of the Proxy Voting Oversight Group and its corporate

parent, Pioneer Global Asset Management S.p.A

Proxy Voting Policies

Pioneer’s sole concern in voting proxies is the economic effect of the

proposal on the value of portfolio holdings, considering both the short-

and long-term impact. In many instances, Pioneer believes that supporting

the company’s strategy and voting “for” management’s proposals builds

portfolio value. In other cases, however, proposals set forth by management

may have a negative effect on that value, while some shareholder proposals

may hold the best prospects for enhancing it. Pioneer monitors developments

in the proxy-voting arena and will revise this policy as needed.

All proxies that are received promptly will be voted in accordance with the

specific policies listed below. All shares in a company held by

Pioneer-managed accounts will be voted alike, unless a client has given us

specific voting instructions on an issue or has not delegated authority to

us. Proxy voting issues will be reviewed by Pioneer’s Proxy Voting

Oversight Group, which consists of the Director of Portfolio Management US,

the Director of Investment Operations (the Proxy Coordinator), and the

Director of Compliance.

Pioneer has established Proxy Voting Procedures for identifying and

reviewing conflicts of interest that may arise in the voting of proxies.

Clients may request, at any time, a report on proxy votes for securities

held in their portfolios and Pioneer is happy to discuss our proxy votes

with company management. Pioneer retains a proxy voting service to provide

research on proxy issues and to process proxy votes.

Administrative

While administrative items appear infrequently in U.S. issuer proxies, they

are quite common in non-U.S. proxies.

We will generally support these and similar management proposals:

o Corporate name change.

o A change of corporate headquarters.

o Stock exchange listing.

o Establishment of time and place of annual meeting.

o Adjournment or postponement of annual meeting.

o Acceptance/approval of financial statements.

o Approval of dividend payments, dividend reinvestment plans and other

dividend-related proposals.

o Approval of minutes and other formalities.

o Authorization of the transferring of reserves and allocation of

income.

o Amendments to authorized signatories.

o Approval of accounting method changes or change in fiscal year-end.

o Acceptance of labor agreements.

o Appointment of internal auditors.

Pioneer will vote on a case-by-case basis on other routine business;

however, Pioneer will oppose any routine business proposal if insufficient

information is presented in advance to allow Pioneer to judge the merit of

the proposal. Pioneer has also instructed its proxy voting service to

inform Pioneer of its analysis of any administrative items inconsistent, in

its view, with supporting the value of Pioneer portfolio holdings so that

Pioneer may consider and vote on those items on a case-by-case basis.

Auditors

We normally vote for proposals to:

o Ratify the auditors. We will consider a vote against if we are

concerned about the auditors’ independence or their past work for

the company. Specifically, we will oppose the ratification of

auditors and withhold votes from audit committee members if

non-audit fees paid by the company to the auditing firm exceed the

sum of audit fees plus audit-related fees plus permissible tax

fees according to the disclosure categories proposed by the

Securities and Exchange Commission.

o Restore shareholder rights to ratify the auditors.

We will normally oppose proposals that require companies to:

o Seek bids from other auditors.

o Rotate auditing firms, except where the rotation is statutorily

required or where rotation would demonstrably strengthen financial

disclosure.

o Indemnify auditors.

o Prohibit auditors from engaging in non-audit services for the

company.

Board of Directors

On issues related to the board of directors, Pioneer normally supports

management. We will, however, consider a vote against management in

instances where corporate performance has been very poor or where the board

appears to lack independence.

General Board Issues

Pioneer will vote for:

o Audit, compensation and nominating committees composed of

independent directors exclusively.

o Indemnification for directors for actions taken in good faith in

accordance with the business judgment rule. We will vote against

proposals for broader indemnification.

o Changes in board size that appear to have a legitimate business

purpose and are not primarily for anti-takeover reasons.

o Election of an honorary director.

We will vote against:

o Minimum stock ownership by directors.

o Term limits for directors. Companies benefit from experienced

directors, and shareholder control is better achieved through

annual votes.

o Requirements for union or special interest representation on the

board.

o Requirements to provide two candidates for each board seat.

We will vote on a case-by case basis on these issues:

o Separate chairman and CEO positions. We will consider voting with

shareholders on these issues in cases of poor corporate

performance.

Elections of Directors

In uncontested elections of directors we will vote against:

o Individual directors with absenteeism above 25% without valid

reason. We support proposals that require disclosure of director

attendance.

o Insider directors and affiliated outsiders who sit on the audit,

compensation, stock option or nominating committees. For the

purposes of our policy, we accept the definition of affiliated

directors provided by our proxy voting service.

We will also vote against:

o Directors who have failed to act on a takeover offer where the

majority of shareholders have tendered their shares.

o Directors who appear to lack independence or are associated with

very poor corporate performance.

We will vote on a case-by case basis on these issues:

o Re-election of directors who have implemented or renewed a

dead-hand or modified dead-hand poison pill (a “dead-hand poison

pill” is a shareholder rights plan that may be altered only by

incumbent or “dead ” directors. These plans prevent a potential

acquirer from disabling a poison pill by obtaining control of the

board through a proxy vote).

o Contested election of directors.

o Prior to phase-in required by SEC, we would consider supporting

election of a majority of independent directors in cases of poor

performance.

o Mandatory retirement policies.

o Directors who have ignored a shareholder proposal that has been

approved by shareholders for two consecutive years.

Takeover-Related Measures

Pioneer is generally opposed to proposals that may discourage takeover

attempts. We believe that the potential for a takeover helps ensure that

corporate performance remains high.

Pioneer will vote for:

o Cumulative voting.

o Increase ability for shareholders to call special meetings.

o Increase ability for shareholders to act by written consent.

o Restrictions on the ability to make greenmail payments.

o Submitting rights plans to shareholder vote.

o Rescinding shareholder rights plans (“poison pills”).

o Opting out of the following state takeover statutes:

o Control share acquisition statutes, which deny large holders voting

rights on holdings over a specified threshold.

o Control share cash-out provisions, which require large holders to

acquire shares from other holders.

o Freeze-out provisions, which impose a waiting period on large

holders before they can attempt to gain control.

o Stakeholder laws, which permit directors to consider interests of

non-shareholder constituencies.

o Disgorgement provisions, which require acquirers to disgorge profits

on purchases made before gaining control.

o Fair price provisions.

o Authorization of shareholder rights plans.

o Labor protection provisions.

o Mandatory classified boards.

We will vote on a case-by-case basis on the following issues:

o Fair price provisions. We will vote against provisions requiring

supermajority votes to approve takeovers. We will also consider

voting against proposals that require a supermajority vote to

repeal or amend the provision. Finally, we will consider the

mechanism used to determine the fair price; we are generally

opposed to complicated formulas or requirements to pay a premium.

o Opting out of state takeover statutes regarding fair price

provisions. We will use the criteria used for fair price

provisions in general to determine our vote on this issue.

o Proposals that allow shareholders to nominate directors.

We will vote against:

o Classified boards, except in the case of closed-end mutual funds.

o Limiting shareholder ability to remove or appoint directors. We

will support proposals to restore shareholder authority in this

area. We will review on a case-by-case basis proposals that

authorize the board to make interim appointments.

o Classes of shares with unequal voting rights.

o Supermajority vote requirements.

o Severance packages (“golden” and “tin” parachutes). We will support

proposals to put these packages to shareholder vote.

o Reimbursement of dissident proxy solicitation expenses. While we

ordinarily support measures that encourage takeover bids, we

believe that management should have full control over corporate

funds.

o Extension of advance notice requirements for shareholder proposals.

o Granting board authority normally retained by shareholders (e.g.,

amend charter, set board size).

o Shareholder rights plans (“poison pills”). These plans generally

allow shareholders to buy additional shares at a below-market

price in the event of a change in control and may deter some bids.

Capital Structure

Managements need considerable flexibility in determining the company’s

financial structure, and Pioneer normally supports managements’ proposals

in this area. We will, however, reject proposals that impose high barriers

to potential takeovers.

Pioneer will vote for:

o Changes in par value.

o Reverse splits, if accompanied by a reduction in number of shares.

o Share repurchase programs, if all shareholders may participate on

equal terms.

o Bond issuance.

o Increases in “ordinary” preferred stock.

o Proposals to have blank-check common stock placements (other than

shares issued in the normal course of business) submitted for

shareholder approval.

o Cancellation of company treasury shares.

We will vote on a case-by-case basis on the following issues:

o Reverse splits not accompanied by a reduction in number of shares,

considering the risk of delisting.

o Increase in authorized common stock. We will make a determination

considering, among other factors:

o Number of shares currently available for issuance;

o Size of requested increase (we would normally approve increases of up to

100% of current authorization);

o Proposed use of the additional shares; and

o Potential consequences of a failure to increase the number of shares

outstanding (e.g., delisting or bankruptcy).

o Blank-check preferred. We will normally oppose issuance of a new

class of blank-check preferred, but may approve an increase in a

class already outstanding if the company has demonstrated that it

uses this flexibility appropriately.

o Proposals to submit private placements to shareholder vote.

o Other financing plans.

We will vote against preemptive rights that we believe limit a company’s

financing flexibility.

Compensation

Pioneer supports compensation plans that link pay to shareholder returns

and believes that management has the best understanding of the level of

compensation needed to attract and retain qualified people. At the same

time, stock-related compensation plans have a significant economic impact

and a direct effect on the balance sheet. Therefore, while we do not want

to micromanage a company’s compensation programs, we will place limits on

the potential dilution these plans may impose.

Pioneer will vote for:

o 401(k) benefit plans.

o Employee stock ownership plans (ESOPs), as long as shares

allocated to ESOPs are less than 5% of outstanding shares. Larger

blocks of stock in ESOPs can serve as a takeover defense. We will

support proposals to submit ESOPs to shareholder vote.

o Various issues related to the Omnibus Budget and Reconciliation Act

of 1993 (OBRA), including:

o Amendments to performance plans to conform with OBRA;

o Caps on annual grants or amendments of administrative features;

o Adding performance goals; and

o Cash or cash-and-stock bonus plans.

o Establish a process to link pay, including stock-option grants, to

performance, leaving specifics of implementation to the company.

o Require that option repricings be submitted to shareholders.

o Require the expensing of stock-option awards.

o Require reporting of executive retirement benefits (deferred

compensation, split-dollar life insurance, SERPs, and pension

benefits).

o Employee stock purchase plans where the purchase price is equal to

at least 85% of the market price, where the offering period is no

greater than 27 months and where potential dilution (as defined

below) is no greater than 10%.

We will vote on a case-by-case basis on the following issues:

o Executive and director stock-related compensation plans. We will

consider the following factors when reviewing these plans:

o The program must be of a reasonable size. We will approve plans

where the combined employee and director plans together would

generate less than 15% dilution. We will reject plans with 15% or

more potential dilution.

Dilution = (A + B + C) / (A + B + C + D), where

A = Shares reserved for plan/amendment,

B = Shares available under continuing plans,

C = Shares granted but unexercised and

D = Shares outstanding.

o The plan must not:

o Explicitly permit unlimited option repricing authority or that

have repriced in the past without shareholder approval.

o Be a self-replenishing “evergreen” plan, plans that grant

discount options and tax offset payments.

o We are generally in favor of proposals that increase participation beyond

executives.

o We generally support proposals asking companies to adopt rigorous

vesting provisions for stock option plans such as those that vest

incrementally over, at least, a three- or four-year period with a pro

rata portion of the shares becoming exercisable on an annual basis

following grant date.

o We generally support proposals asking companies to disclose their

window period policies for stock transactions. Window period policies

ensure that employees do not exercise options based on insider

information contemporaneous with quarterly earnings releases and other

material corporate announcements.

o We generally support proposals asking companies to adopt stock holding

periods for their executives.

o All other employee stock purchase plans.

o All other compensation-related proposals, including deferred

compensation plans, employment agreements, loan guarantee programs

and retirement plans.

o All other proposals regarding stock compensation plans, including

extending the life of a plan, changing vesting restrictions,

repricing options, lengthening exercise periods or accelerating

distribution of awards and pyramiding and cashless exercise

programs.

We will vote against:

o Pensions for non-employee directors. We believe these retirement

plans reduce director objectivity.

o Elimination of stock option plans.

We will vote on a case-by case basis on these issues:

o Limits on executive and director pay.

o Stock in lieu of cash compensation for directors.

Corporate Governance

Pioneer will vote for:

o Confidential Voting.

o Equal access provisions, which allow shareholders to contribute

their opinion to proxy materials.

o Proposals requiring directors to disclose their ownership of shares

in the company.

We will vote on a case-by-case basis on the following issues:

o Change in the state of incorporation. We will support

reincorporations supported by valid business reasons. We will

oppose those that appear to be solely for the purpose of

strengthening takeover defenses.

o Bundled proposals. We will evaluate the overall impact of the

proposal.

o Adopting or amending the charter, bylaws or articles of association.

o Shareholder appraisal rights, which allow shareholders to demand

judicial review of an acquisition price.

We will vote against:

o Shareholder advisory committees. While management should solicit

shareholder input, we prefer to leave the method of doing so to

management’s discretion.

o Limitations on stock ownership or voting rights.

o Reduction in share ownership disclosure guidelines.

Mergers and Restructurings

Pioneer will vote on the following and similar issues on a case-by-case

basis:

o Mergers and acquisitions.

o Corporate restructurings, including spin-offs, liquidations, asset

sales, joint ventures, conversions to holding company and

conversions to self-managed REIT structure.

o Debt restructurings.

o Conversion of securities.

o Issuance of shares to facilitate a merger.

o Private placements, warrants, convertible debentures.

o Proposals requiring management to inform shareholders of merger

opportunities.

We will normally vote against shareholder proposals requiring that the

company be put up for sale.

Mutual Funds

Many of our portfolios may invest in shares of closed-end mutual funds or

exchange-traded funds. The non-corporate structure of these investments

raises several unique proxy voting issues.

Pioneer will vote for:

o Establishment of new classes or series of shares.

o Establishment of a master-feeder structure.

Pioneer will vote on a case-by-case on:

o Changes in investment policy. We will normally support changes

that do not affect the investment objective or overall risk level

of the fund. We will examine more fundamental changes on a

case-by-case basis.

o Approval of new or amended advisory contracts.

o Changes from closed-end to open-end format.

o Authorization for, or increase in, preferred shares.

o Disposition of assets, termination, liquidation, or mergers.

o Classified boards of closed-end mutual funds, but will typically

support such proposals.

Social Issues

Pioneer will abstain on stockholder proposals calling for greater

disclosure of corporate activities with regard to social issues. “Social

Issues” may generally be described as shareholder proposals for a company

to:

o Conduct studies regarding certain issues of public concern and

interest;

o Study the feasibility of the company taking certain actions with

regard to such issues; or

o Take specific action, including ceasing certain behavior and

adopting company standards and principles, in relation to issues

of public concern and interest.

We believe these issues are important and should receive management

attention.

Pioneer will vote against proposals calling for substantial changes in the

company’s business or activities. We will also normally vote against

proposals with regard to contributions, believing that management should

control the routine disbursement of funds.

ITEM 8. PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

(a) If the registrant is a closed-end management investment company that is filing an annual report on this Form N-CSR, provide the following information:

(1) State the name, title, and length of service of the person or persons employed by or associated with the registrant or an investment adviser of the registrant who are primarily responsible for the day-to-day management of the registrant’s portfolio (“Portfolio Manager”). Also state each Portfolio Manager’s business experience during the past 5 years.

ADDITIONAL INFORMATION ABOUT THE PORTFOLIO MANAGERS

OTHER ACCOUNTS MANAGED BY THE PORTFOLIO MANAGERS

The table below indicates, for the portfolio managers of the fund, information

about the accounts other than the fund over which the portfolio manager has

day-to-day investment responsibility. All information on the number of accounts

and total assets in the table is as of October 31, 2020. For purposes of the

table, “Other Pooled Investment Vehicles” may include investment partnerships,

undertakings for collective investments in transferable securities (“UCITS”)

and other non-U.S. investment funds and group trusts, and “Other Accounts” may

include separate accounts for institutions or individuals, insurance company

general or separate accounts, pension funds and other similar institutional

accounts but generally do not include the portfolio manager’s personal

investment accounts or those which the manager may be deemed to own

beneficially under the code of ethics. Certain funds and other accounts managed

by the portfolio manager may have substantially similar investment strategies.

NAME OF PORTFOLIO MANAGER	TYPE OF ACCOUNT	NUMBER OF ACCOUNTS MANAGED	TOTAL ASSETS MANAGED (000’S)	NUMBER OF ACCOUNTS MANAGED FOR WHICH ADVISORY FEE IS PERFORMANCE-BASED	ASSETS MANAGED FOR WHICH ADVISORY FEE IS PERFORMANCE-BASED (000’S)
Chin Liu	Other Registered Investments Companies Other Pooled Investment Vehicles Other Accounts	2 1 0	$1,046,415 $ 79,898 $ 0	N/A N/A N/A	N/A N/A N/A
Campbell Brown	Other Registered Investments Companies Other Pooled Investment Vehicles Other Accounts	1 1 0	$ 874,460 $ 79,898 $ 0	N/A N/A N/A	N/A N/A N/A

POTENTIAL CONFLICTS OF INTEREST

When a portfolio manager is responsible for the management of more than one

account, the potential arises for the portfolio manager to favor one account

over another. The principal types of potential conflicts of interest that may

arise are discussed below. For the reasons outlined below, Amundi Pioneer does

not believe that any material conflicts are likely to arise out of a portfolio

manager’s responsibility for the management of the fund as well as one or more

other accounts. Although Amundi Pioneer has adopted procedures that it believes

are reasonably designed to detect and prevent violations of the federal

securities laws and to mitigate the potential for conflicts of interest to

affect its portfolio management decisions, there can be no assurance that all

conflicts will be identified or that all procedures will be effective in

mitigating the potential for such risks. Generally, the risks of such conflicts

of interest are increased to the extent that a portfolio manager has a

financial incentive to favor one account over another. Amundi Pioneer has

structured its compensation arrangements in a manner that is intended to limit

such potential for conflicts of interest. See “Compensation of Portfolio

Manager” below.

o A portfolio manager could favor one account over another in allocating new

investment opportunities that have limited supply, such as initial public

offerings and private placements. If, for example, an initial public

offering that was expected to appreciate in value significantly shortly

after the offering was allocated to a single account, that account may be

expected to have better investment performance than other accounts that did

not receive an allocation of the initial public offering. Generally,

investments for which there is limited availability are allocated based upon

a range of factors including available cash and

consistency with the accounts’ investment objectives and policies. This

allocation methodology necessarily involves some subjective elements but is

intended over time to treat each client in an equitable and fair manner.

Generally, the investment opportunity is allocated among participating

accounts on a pro rata basis. Although Amundi Pioneer believes that its

practices are reasonably designed to treat each client in an equitable and

fair manner, there may be instances where a fund may not participate, or may

participate to a lesser degree than other clients, in the allocation of an

investment opportunity.

o A portfolio manager could favor one account over another in the order in

which trades for the accounts are placed. If a portfolio manager determines

to purchase a security for more than one account in an aggregate amount that

may influence the market price of the security, accounts that purchased or

sold the security first may receive a more favorable price than accounts

that made subsequent transactions. The less liquid the market for the

security or the greater the percentage that the proposed aggregate purchases

or sales represent of average daily trading volume, the greater the

potential for accounts that make subsequent purchases or sales to receive a

less favorable price. When a portfolio manager intends to trade the same

security on the same day for more than one account, the trades typically are

“bunched,” which means that the trades for the individual accounts are

aggregated and each account receives the same price. There are some types of

accounts as to which bunching may not be possible for contractual reasons

(such as directed brokerage arrangements). Circumstances may also arise

where the trader believes that bunching the orders may not result in the

best possible price. Where those accounts or circumstances are involved,

Amundi Pioneer will place the order in a manner intended to result in as

favorable a price as possible for such client.

o A portfolio manager could favor an account if the portfolio manager’s

compensation is tied to the performance of that account to a greater degree

than other accounts managed by the portfolio manager. If, for example, the

portfolio manager receives a bonus based upon the performance of certain

accounts relative to a benchmark while other accounts are disregarded for

this purpose, the portfolio manager will have a financial incentive to seek

to have the accounts that determine the portfolio manager’s bonus achieve

the best possible performance to the possible detriment of other accounts.

Similarly, if Amundi Pioneer receives a performance-based advisory fee, the

portfolio manager may favor that account, whether or not the performance of

that account directly determines the portfolio manager’s compensation.

o A portfolio manager could favor an account if the portfolio manager has a

beneficial interest in the account, in order to benefit a large client or to

compensate a client that had poor returns. For example, if the portfolio

manager held an interest in an investment partnership that was one of the

accounts managed by the portfolio manager, the portfolio manager would have

an economic incentive to favor the account in which the portfolio manager

held an interest.

o If the different accounts have materially and potentially conflicting

investment objectives or strategies, a conflict of interest could arise. For

example, if a portfolio manager purchases a security for one account and

sells the same security for another account, such trading pattern may

disadvantage either the account that is long or short. In making portfolio

manager assignments, Amundi Pioneer seeks to avoid such potentially

conflicting situations. However, where a portfolio manager is responsible

for accounts with differing investment objectives and policies, it is

possible that the portfolio manager will conclude that it is in the best

interest of one account to sell a portfolio security while another account

continues to hold or increase the holding in such security.

COMPENSATION OF PORTFOLIO MANAGERS

Amundi Pioneer has adopted a system of compensation for portfolio managers that

seeks to align the financial interests of the portfolio managers with those of

shareholders of the accounts (including Pioneer funds) the portfolio managers

manage, as well as with the financial performance of Amundi Pioneer. The

compensation program for all Amundi Pioneer portfolio managers includes a base

salary (determined by the rank and tenure of the employee) and an annual bonus

program, as well as customary benefits that are offered generally to all

full-time employees. Base compensation is fixed and normally reevaluated on an

annual basis. Amundi Pioneer seeks to set base compensation at market rates,

taking into account the

experience and responsibilities of the portfolio manager. The bonus plan is

intended to provide a competitive level of annual bonus compensation that is

tied to the portfolio manager achieving superior investment performance and

align the interests of the investment professional with those of shareholders,

as well as with the financial performance of Amundi Pioneer. Any bonus under

the plan is completely discretionary, with a maximum annual bonus that may be

in excess of base salary. The annual bonus is based upon a combination of the

following factors:

o QUANTITATIVE INVESTMENT PERFORMANCE. The quantitative investment performance

calculation is based on pre-tax investment performance of all of the

accounts managed by the portfolio manager (which includes the fund and any

other accounts managed by the portfolio manager) over a one-year period (20%

weighting) and four-year period (80% weighting), measured for periods ending

on December 31. The accounts, which include the fund, are ranked against a

group of mutual funds with similar investment objectives and investment

focus (60%) and a broad-based securities market index measuring the

performance of the same type of securities in which the accounts invest

(40%), which, in the case of the fund, is the Bank of America Merrill Lynch

(BofA ML) 3-month U.S. Treasury Bill Index . As a result of these two

benchmarks, the performance of the portfolio manager for compensation

purposes is measured against the criteria that are relevant to the portfolio

manager’s competitive universe.

o QUALITATIVE PERFORMANCE. The qualitative performance component with respect

to all of the accounts managed by the portfolio manager includes objectives,

such as effectiveness in the areas of teamwork, leadership, communications

and marketing, that are mutually established and evaluated by each portfolio

manager and management.

o AMUNDI PIONEER RESULTS AND BUSINESS LINE RESULTS. Amundi Pioneer’s financial

performance, as well as the investment performance of its investment

management group, affect a portfolio manager’s actual bonus by a leverage

factor of plus or minus (+/-) a predetermined percentage.

The quantitative and qualitative performance components comprise 80% and 20%,

respectively, of the overall bonus calculation (on a pre-adjustment basis). A

portion of the annual bonus is deferred for a specified period and may be

invested in one or more Pioneer funds.

Certain portfolio managers participate in other programs designed to reward and

retain key contributors. Portfolio managers also may participate in a deferred

compensation program, whereby deferred amounts are invested in one or more

Pioneer funds or collective investment trusts or other unregistered funds with

similar investment objectives, strategies and policies.

SHARE OWNERSHIP BY PORTFOLIO MANAGERS

The following table indicates as of October 31, 2020 the value, within the

indicated range, of shares beneficially owned by the portfolio managers of the

fund.

NAME OF PORTFOLIO MANAGER	BENEFICIAL OWNERSHIP OF THE FUND*
Chin Liu	A
Campbell Brown	A

* Key to Dollar Ranges

A.	None
B.	$1 - $10,000
C.	$10,001 - $50,000
D.	$50,001 - $100,000
E.	$100,001 - $500,000
F.	$500,001 - $1,000,000
G.	Over $1,000,000

ITEM 9. PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND AFFILIATED PURCHASERS.

(a)

If the registrant is a closed-end management investment company, in the following tabular format, provide the information specified in paragraph (b) of this Item with respect to any purchase made by or on behalf of the registrant or any affiliated purchaser, as defined in Rule 10b-18(a)(3) under the Exchange Act (17 CFR 240.10b-18(a)(3)), of shares or other units of any class of the registrant’s equity securities that is registered by the registrant pursuant to Section 12 of the Exchange Act (15 U.S.C. 781).

During the period covered by this report, there were no purchases made by or on behalf of the registrant or any affiliated purchaser as defined in Rule 10b-18(a)(3) under the Securities Exchange Act of 1934 (the Exchange Act), of shares of the registrants equity securities that are registered by the registrant pursuant to Section 12 of the Exchange Act.

ITEM 10. SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS.

Describe any material changes to the procedures by which shareholders may recommend nominees to the registrant’s board of directors, where those changes were implemented after the registrant last provided disclosure in response to the requirements of Item 407(c)(2)(iv) of Regulation S-R(17 CFR 229.407)(as required by Item 22(b)(15)) of Schedule 14A (17 CFR 240.14a-101), or this Item.

There have been no material changes to the procedures by which the shareholders may recommend nominees to the registrant’s board of directors since the registrant last provided disclosure in response to the requirements of Item 407(c)(2)(iv) of Regulation S-R of Schedule 14(A) in its definitive proxy statement, or this item.

ITEM 11. CONTROLS AND PROCEDURES.

(a) Disclose the conclusions of the registrant’s principal executive and principal financials officers, or persons performing similar functions, regarding the effectiveness of the registrant’s disclosure controls and procedures (as defined in Rule 30a-3(c) under the Act (17 CFR 270.30a-3(c))) as of a date within 90 days of the filing date of the report that includes the disclosure required by this paragraph, based on the evaluation of these controls and procedures required by Rule 30a-3(b) under the Act (17 CFR 270.30(a)-3(b) and Rules 13a-15(b) or 15d-15(b) under the Exchange Act (17 CFR 240.13a-15(b) or 240.15d-15(b)).

The registrant’s principal executive officer and principal financial officer have concluded that the registrant’s disclosure controls and procedures are effective based on the evaluation of these controls and procedures as of a date within 90 days of the filing date of this report.

(b) Disclose any change in the registrant’s internal control over financial reporting (as defined in Rule 30a-3(d) under the Act (17CFR 270.30a-3(d)) that occured during the second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting.

There were no significant changes in the registrant’s internal control over financial reporting that occurred during the second fiscal quarter of the period covered by this report that have materially affected, or are reasonably likely to materially affect, the registrant’s internal control over financial reporting.

Item 12. Disclosure of Securities Lending Activities for Closed-End Management Investment Companies.

(a) If the registrant is a closed-end management investment company, provide the following dollar amounts of income and compensation related to the securities lending activities of the registrant during its most recent fiscal year:

N/A

(1) Gross income from securities lending activities;

N/A

(2) All fees and/or compensation for each of the following securities lending activities and related services: any share of revenue generated by the securities lending program paid to the securities lending agent(s) (revenue split); fees paid for cash collateral management services (including fees deducted from a pooled cash collateral reinvestment vehicle) that are not included in the revenue split; administrative fees that are not included in the revenue split; fees for indemnification that are not included in the revenue split; rebates paid to borrowers; and any other fees relating to the securities lending program that are not included in the revenue split, including a description of those other fees;

N/A

(3) The aggregate fees/compensation disclosed pursuant to paragraph (2); and

N/A

(4) Net income from securities lending activities (i.e., the dollar amount in paragraph (1) minus the dollar amount in paragraph (3)).

If a fee for a service is included in the revenue split, state that the fee is included in the revenue split.

N/A

(b) If the registrant is a closed-end management investment company, describe the services provided to the registrant by the securities lending agent in the registrants most recent fiscal year.

N/A

ITEM 13. EXHIBITS.

(a) File the exhibits listed below as part of this Form. Letter or number the exhibits in the sequence indicated.

(1) Any code of ethics, or amendment thereto, that is the subject of the disclosure required by Item 2, to the extent that the registrant intends to satisfy the Item 2 requirements through filing of an exhibit.

(2) A separate certification for each principal executive officer and principal financial officer of the registrant as required by Rule 30a-2(a) under the Act (17 CFR 270.30a-2(a)) , exactly as set forth below:

Filed herewith.

SIGNATURES

[See General Instruction F]

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

(Registrant) Pioneer ILS Bridge Fund

By (Signature and Title)* /s/ Lisa M. Jones

Lisa M. Jones, President & Chief Executive Officer

Date December 30, 2020

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

By (Signature and Title)* /s/ Lisa M. Jones

Lisa M. Jones, President & Chief Executive Officer

Date December 30, 2020

By (Signature and Title)* /s/ Mark E. Bradley

Mark E. Bradley, Treasurer & Chief Accounting & Financial Officer

Date December 30, 2020

* Print the name and title of each signing officer under his or her signature.

Pioneer ILS Bridge Fund (XILBX) N-CSRCertified annual shareholder report (management investment company)