Code of Ethics for Principal Executives

Senior Financial

Officers

Procedures

Revised December 10, 2018

FRANKLIN
TEMPLETON
FUNDS

CODE OF ETHICS

FOR

PRINCIPAL

EXECUTIVES

AND

SENIOR FINANCIAL OFFICERS

I.

Covered
Officers and Purpose of the Code

This

code

ethics

(the

"Code")

applies

the

Principal

Executive

Officers,

Principal

Financial

Officer

and

Principal

Accounting

Officer

(the

"Covered

Officers,"

each

whom

set

forth in

Exhibit

each investment

company

advised by

Franklin

Resources

subsidiary

and

that

registered

with

the

United

States

Securities

Exchange

Commission

(“SEC”)

(collectively,

"FT

Funds")

for

the

purpose

promoting:

Honest

and

ethical

conduct,

including

the

ethical

resolution

actual

apparent

conflicts

interest

between

personal

and

professional

relationships;

Full,

fair,

accurate,

timely

and

understandable

disclosure

reports

and

documents

that

registrant

files

with,

submits

to,

the

SEC

and

other

public

communications

made

behalf

the

Funds;

Compliance

with

applicable

laws

and

governmental

rules

and

regulations;

The

prompt

internal

reporting

violations

the

Code

appropriate

person

persons

identified

the

Code;

and

Accountability

for

adherence

the

Code.

Each

Covered

Officer

will

expected

adhere

high

standard

business

ethics

and

must

sensitive

situations

that

may

give

rise

actual

well

apparent

conflicts

interest.

Rule 38a-1

under

the

Investment

Company

Act of 1940

(“1940

Act”)

and

Rule

206(4)-7

under

the

Investment

Advisers

Act

1940 (“Advisers Act”)

(together

the “Compliance Rule”)

require registered

investment

companies

and

registered

investment

advisers

to,

among other

things, adopt and implement

written

policies

and

procedures reasonably

designed to

prevent

violations

of the

federal

securities

laws

(“Compliance

Rule

Policies

and

Procedures”).

CONFIDENTIAL

INFORMATION.

This

document

the

proprietary

product

Franklin

Templeton

Investments.

may

NOT

distributed

outside

the

company

unless

it is

made subject to

non-disclosure agreement

and/or

such

release

receives

authorization

an FTI

Chief Compliance

Officer.

Any

unauthorized

use,

reproduction

transfer

of this

document

is strictly

prohibited.

Franklin

Templeton

Investments

2014.

All

Rights Reserved.

II.

Other Policies and Procedures

This

Code

shall

the

sole

code

ethics

adopted

the

Funds

for

purposes

Section

406

the

Sarbanes-Oxley

Act

and

the

rules

and

forms

applicable

registered

investment

companies

thereunder.

Franklin

Resources,

Inc.

has

separately

adopted

the

Code

Ethics

and

Business

Conduct

(“Business

Conduct”),

which

applicable

all

officers,

directors

and

employees

Franklin

Resources,

Inc.,

including

Covered

Officers.

summarizes

the

values,

principles

and

business

practices

that

guide

the

employee’s

business

conduct

and

also

provides a set of basic

principles

guide

officers,

directors

and

employees regarding the

minimum

ethical

requirements

expected

them.

supplements

the

values,

principles

and

business

conduct

identified

the

Code

and

other

existing

employee

policies.

Additionally,

the

Franklin

Templeton

Funds

have

separately

adopted

the

FTI

Personal

Investments

and

Insider

Trading

Policy

governing

personal

securities

trading

and

other

matters.

The

Code

for

Insider

Trading

provides

for

separate

requirements

that

apply

the

Covered

Officers

and

others,

and

therefore

not

part

this

Code.

Insofar

other

policies

procedures

Franklin

Resources,

Inc.,

the

Funds,

the

Funds’

adviser,

principal

underwriter,

other

service

providers

govern

purport

govern

the

behavior

activities

the

Covered Officers

who

are subject

to this Code, they are

superceded

this

Code

the

extent

that

they

overlap

conflict

with

the

provisions

this

Code.

Please

review these other documents or consult with

the

Legal

Department

if have questions regarding

the

applicability

these

policies

you.

III.

Covered Officers Should Handle
Ethically
Actual and
Apparent
Conflicts of
Interest

Overview.

"conflict

interest"

occurs

when

Covered

Officer's

private

interest

interferes

with

the

interests

of,

his

her

service

to,

the

Funds.

For

example,

conflict

interest

would

arise

Covered

Officer,

member

his

family,

receives

improper

personal

benefits

result

apposition

with

the

Funds.

Certain

conflicts

interest

arise

out

the

relationships

between

Covered

Officers

and

the

Funds

and

already

are

subject

conflict

interest

provisions

the

Investment

Company

Act

1940

("Investment

Company

Act")

and

the

Investment

Advisers

Act

1940

("Investment

Advisers

Act").

For

example,

Covered

Officers

may

not

individually

engage

certain

transactions

(such

the

purchase

sale

securities

other

property)

with

the

Funds

because

their

status

"affiliated

persons"

the

Funds.

The

Funds’

and

the

investment

advisers’

compliance

programs

and

procedures

are

designed

prevent,

identify

and

correct,

violations

these

provisions.

This

Code

does not,

and

is not

intended

to,

repeat

or replace

these

programs

and

procedures,

and

such

conflicts

fall

outside

the

parameters

this

Code.

Although

typically

not

presenting

opportunity

for

improper

personal

benefit,

conflicts

arise

from,

result

of,

the

contractual

relationship

between

the

Funds,

the

investment

advisers

and

the

fund

administrator

which

the

Covered

Officers

are

also

officers

employees.

result,

this

Code

recognizes

that

the

Covered

Officers

will,

the

normal

course

their

duties

(whether

formally

for

the

Funds,

for

the

adviser,

the

administrator,

for

all

three),

involved

establishing

policies

and

implementing

decisions

that

will

have

different

effects

the

adviser,

administrator

and

the

Funds.

The

participation

the

Covered

Officers

such

activities

inherent

the

contractual

relationship

between

the

Funds,

the

adviser,

and

the

administrator

and

consistent

with

the

performance

the

Covered

Officers

their

duties

officers

the

Funds.

Thus,

performed

conformity

with

the

provisions

the

Investment

Company

Act

and

the

Investment

Advisers

Act,

such

activities

will

deemed

have

been

handled

ethically.

addition,

recognized

the

Funds'

Boards

Directors

("Boards")

that

the

Covered

Officers

may

also

officers

employees

one

other

investment

companies

covered

this

other

codes.

Other

conflicts

interest

are

covered

the

Code,

even

such

conflicts

interest

are

not

subject

provisions

the

Investment

Company

Act

and

the

Investment

Advisers

Act.

The

following

list

provides

examples

conflicts

interest

under

the

Code,

but

Covered

Officers

should

keep

mind

that

these

examples

are

not

exhaustive.

The

overarching

principle

that

the

personal

interest

Covered

Officer

should

not

placed

improperly

before

the

interest

the

Funds.

Each

Covered

Officer

must:

Not

use

his

her

personal

influence

personal

relationships

improperly

influence

investment

decisions

financial

reporting

the

Funds

whereby

the

Covered

Officer

would

benefit

personally

the

detriment

the

Funds;

Not

cause

the

Funds

take

action,

fail

take

action,

for

the

individual

personal

benefit

the

Covered

Officer

rather

than

the

benefit

the

Funds;

Not

retaliate

against

any

other

Covered

Officer

any

employee

the

Funds

their

affiliated

persons

for

reports

potential

violations

that

are

made

good

faith;

Report

least

annually

the

following

affiliations

other

relationships:

all

directorships

for

public

companies

and

all

companies

that

are

required

file

reports

with

the

SEC;

any

direct

indirect

business

relationship

with

any

independent

directors

the

Funds;

any

direct

indirect

business

relationship

with

any

independent

public

accounting

firm

(which

are

not

the

routine

issues

the

firm’s

service

the

Covered

Persons

accountant);

and

any

direct

indirect

interest

any

transaction

with

any

Fund

that

will

benefit

the

officer

(not

including

benefits

derived

from

the

advisory,

sub-advisory,

distribution

service

agreements

with

affiliates

Franklin

Resources).

These

reports

will

reviewed

the

Legal

Department

for

compliance

with

the

Code.

There

are

some

conflict

interest

situations

that

should

always

approved

writing

Franklin

Resources

General

Counsel

Deputy

General

Counsel,

material.

Examples

these

include

Service

director

the

board

any

public

private

Company.

Reporting

these

affiliations

other

relationships

shall

made

completing

the

annual

Directors

and

Officers

Questionnaire

and

returning

the

questionnaire

Franklin

Resources

Inc,

General

Counsel

Deputy

General

Counsel.

Any

activity

relationship

that

would

present

conflict

for

Covered

Officer

may

also

present

conflict

for

the

Covered

Officer

member

the

Covered

Officer's

immediate

family

engages

such

activity

has

such

relationship.

The

Cover

Person

should

also

obtain

written

approval

FT’s

General

Counsel

such

situations.

The

receipt

any

gifts

excess

$100

from

any

person,

from

any

corporation

association.

The

receipt

any

entertainment

from

any

Company

with

which

the

Funds

has

current

prospective

business

dealings

unless

such

entertainment

business

related,

reasonable

cost,

appropriate

time

and

place,

and

not

frequent

raise

any

question

impropriety.

Notwithstanding

the

foregoing,

the

Covered

Officers

must

obtain

prior

approval

from

the

Franklin

Resources

General

Counsel

for

any

entertainment

with

value

excess

$1000.

Any

ownership

interest

in,

any

consulting

employment

relationship

with,

any

the

Fund’s

service

providers,

other

than

investment

adviser,

principal

underwriter,

administrator

any

affiliated

person

thereof.

direct

indirect

financial

interest

commissions,

transaction

charges

spreads

paid

the

Funds

for

effecting

portfolio

transactions

for

selling

redeeming

other

than

interest

arising

from

the

Covered

Officer's

employment,

such

compensation

equity

ownership.

Franklin

Resources

General

Counsel

Deputy

General

Counsel

will

provide

report

the

Funds

Audit

Committee

any

approvals

granted

the

regularly

scheduled

meeting.

IV.

Disclosure and Compliance

Each

Covered

Officer

should

familiarize

himself

with

the

disclosure

requirements

generally

applicable

the

Funds;

Each

Covered

Officer

should

not

knowingly

misrepresent,

cause

others

misrepresent,

facts

about

the

Funds

others,

whether

within

outside

the

Funds,

including

the

Funds’

directors

and

auditors,

and

governmental

regulators

and

self-regulatory

organizations;

Each

Covered

Officer

should,

the

extent

appropriate

within

his

her

area

responsibility,

consult

with

other

officers

and

employees

the

Funds,

the

Fund’s

adviser

and

the

administrator

with

the

goal

promoting

full,

fair,

accurate,

timely

and

understandable

disclosure

the

reports

and

documents

the

Funds

file

with,

submit

to,

the

SEC

and

other

public

communications

made

the

Funds;

and

the

responsibility

each

Covered

Officer

promote

compliance

with

the

standards

and

restrictions

imposed

applicable

laws,

rules

and

regulations.

V.

Reporting
and Accountability

Each

Covered

Officer

must:

Upon

becoming

covered

officer

affirm

writing

the

Board

that

she

has

received,

read,

and

understands

the

Code

(see

Exhibit

B);

Annually

thereafter

affirm

the

Board

that

has

complied

with

the

requirements

the

Code;

and

Notify

Franklin

Resources’

General

Counsel

Deputy

General

Counsel

promptly

she

knows

any

violation

this

Code.

Failure

itself

violation

this

Code.

Franklin

Resources’

General

Counsel

and

Deputy

General

Counsel

are

responsible

for

applying

this

Code

specific

situations

which

questions

are

presented

under

and

have

the

authority

interpret

this

Code

any

particular

situation.

However,

the

Independent

Directors

the

respective

Funds

will

consider

any

approvals

waivers

sought

any

Chief

Executive

Officers

the

Funds.

The

Funds

will

these

procedures

investigating

and

enforcing

this

Code:

Franklin

Resources

General

Counsel

Deputy

General

Counsel

will

take

all

appropriate

action

investigate

any

potential

violations

reported

the

Legal

Department;

If,

after

such

investigation,

the

General

Counsel

Deputy

General

Counsel

believes

that

violation

has

occurred,

The

General

Counsel

not

required

take

any

further

action;

Any

matter

that

the

General

Counsel

Deputy

General

Counsel

believes

violation

will

reported

the

Independent

Directors

the

appropriate

Fund;

the

Independent

Directors

concur

that

violation

has

occurred,

will

inform

and

make

recommendation

the

Board

the

appropriate

Fund

Funds,

which

will

consider

appropriate

action,

which

may

include

review

of,

and

appropriate

modifications

to, applicable

policies

and

procedures;

notification

appropriate

personnel

the

investment

adviser

its

board;

recommendation

dismiss

the

Covered

Officer;

The

Independent

Directors

will

responsible

for

granting

waivers,

appropriate;

and

Any

changes

waivers

this

Code

will,

the

extent

required,

are

disclosed

provided

SEC

rules.

VI.

Other Policies and Procedures

This

Code

shall

the

sole

code

ethics

adopted

the

Funds

for

purposes

Section

406

the

Sarbanes-Oxley

Act

and

the

rules

and

forms

applicable

registered

investment

companies

thereunder.

Insofar

other

policies

procedures

the

Funds,

the

Funds'

advisers,

principal

underwriter,

other

service

providers

govern

purport

govern

the

behavior

activities

the

Covered

Officers

who

are

subject

this

Code,

they

are

superseded

this

Code

the

extent

that

they

overlap

conflict

with

the

provisions

this

Code.

The

FTI

Personal

Investments

and

Insider

Trading

Policy,

adopted

the

Funds,

investment

advisers

and

Fund’s

principal

underwriter

pursuant

Rule

17j-1

under

the

Investment

Company

Act,

the

Code

Ethics

and

Business

Conduct

and

detailed

policies

and

procedures

set

forth

FT’s

Employee

Handbook

are

separate

requirements

applying

the

Covered

Officers

and

others,

and

are

not

part

this

Code.

Franklin

Resources

General

Counsel

and

Deputy

General

Counsel

are

authorized

consult,

appropriate,

with

members

the

Audit

Committee,

counsel

the

Funds

and

counsel

the

Independent

Directors,

and

are

encouraged

so.

Item

Form

N-CSR

defines

"waiver"

"the

approval

the

registrant

material

departure

from

provision

the

code

ethics"

and

"implicit

waiver,"

which

must

also

disclosed,

"the

registrant's

failure

take

action

within

reasonable

period

time

regarding

material

departure

from

provision

the

code

ethics

that

has

been

made

known

executive

officer"

the

registrant.

See

Part

See

Part

VII.

Amendments

Any

amendments

this

Code,

other

than

amendments

Exhibit

must

approved

ratified

majority

vote

the

Funds’

Board

including

majority

independent

directors.

VIII.

Confidentiality

All

reports

and

records

prepared

maintained

pursuant

this

Code

will

considered

confidential

and

shall

maintained

and

protected

accordingly.

Except

otherwise

required

law or

this Code,

such matters

shall

not

be disclosed

to anyone

other than

the FT

Funds’ Board

and

their

counsel.

IX.

Internal Use

The

Code

intended

solely

for

the

internal

use

the

Funds

and

does

not

constitute

admission,

behalf

any

Funds,

any

fact,

circumstance,

legal

conclusion.

Disclosure

Form

N-CSR

Item

Form

N-CSR

requires

registered

management

investment

company

disclose

annually

whether,

the

end

the

period

covered

the

report,

has

adopted

code

ethics

that

applies

the

registrant's

principal

executive

officer,

principal

financial

officer,

principal

accounting

officer

controller,

persons

performing

similar

functions,

regardless

whether

these

officers

are

employed

the

registrant

third

party.

the

registrant

has

not

adopted

such

code

ethics,

must

explain

why

has

not

done

so.

The

registrant

must

also:

(1)

file

with

the

SEC

copy

the

code

exhibit

its

annual

report;

(2)

post

the

text

the

code

its

Internet

website

and

disclose,

its

most

recent

report

Form

N-CSR,

its

Internet

address

and

the

fact

that

has

posted

the

code

its

Internet

website;

(3)

undertake

its

most

recent

report

Form

N-CSR

provide

any

person

without

charge,

upon

request,

copy

the

code

and

explain

the

manner

which

such

request

may

made.

Disclosure

also

required

amendments

to,

waivers

(including

implicit

waivers)

from,

provision

the

code

the

registrant's

annual

report

Form

N-CSR

its

website.

the

registrant

intends

satisfy

the

requirement

disclose

amendments

and

waivers

posting

such

information

its

website,

will

required

disclose

its

Internet

address

and

this

intention.

The

Legal

Department

shall

responsible

for

ensuring

that:

copy

the

Code

filed

with

the

SEC

exhibit

each

Fund’s

annual

report;

and

any

amendments

to,

waivers

(including

implicit

waivers)

from,

provision

the

Code

disclosed

the

registrant's

annual

report

Form

N-CSR.

the

event

that

the

foregoing

disclosure

omitted

determined

incorrect,

the

Legal

Department

shall

promptly

file

such

information

with

the

SEC

amendment

Form

N-CSR.

such

event,

the

Fund

Chief

Compliance

Officer

shall

review

the

Code

and

propose

such

changes

the

Code

are

necessary

appropriate

prevent

reoccurrences.

EXHIBIT
A

Persons

Covered

the

Franklin

Templeton

Funds

Code

Ethics

December

2018

FRANKLIN GROUP
OF FUNDS

Edward

Perks President

and

Chief Executive Officer

–

Investment

Management

Rupert H. Johnson, Jr. Chairman

of the Board and

Vice President– Investment

Management

Don

Taylor President

and

Chief Executive Officer

–

Investment

Management

Sonal

Desai) President

and

Chief

Executive

Officer

–

Investment

Management

Matthew Hinkle Chief Executive Officer

–

Finance

and Administration

FRANKLIN MUTUAL
SERIES FUNDS

Peter Langerman Chief Executive Officer

–

Investment Management

Matthew Hinkle Chief Executive Officer

–

Finance

and Administration

Robert G. Kubilis Chief Financial Officer and Chief Accounting Officer

FRANKLIN ALTERNATIVE STRATEGIES FUNDS

Mat S. Gulley Chief Executive Officer

–

Investment

Management

Matthew Hinkle Chief Executive

Officer

–

Finance

and Administration

Robert G. Kubilis Chief Financial Officer and Chief Accounting

Officer

TEMPLETON
GROUP
OF FUNDS

Manraj S. Sekhon President and

Chief Executive Officer

–

Investment

Management

Michael

Hasenstab,

Ph.D.

President and Chief Executive Officer

–

Investment

Management

Norman

Boersma President

and

Chief Executive Officer

–

Investment

Management

Matthew Hinkle Chief Executive Officer

–

Finance

and Administration

Robert G. Kubilis Chief Financial Officer, Chief Accounting Officer and Treasurer

Exhibit
B
ACKNOWLEDGMENT FORM