EX-99.17.c
CODE OF ETHICS
Lincoln Financial Distributors, Inc.
CREDO
It is the duty of all Lincoln Financial Distributors, Inc. ("LFD") employees,
officers, and directors to conduct themselves with integrity and at all times.
In the interest of this Credo, all personal transactions will be conducted
consistent with this Code of Ethics ("Code") and in such a manner as to avoid
any actual or potential conflict of interest or any abuse of an individual's
position of trust and responsibility. The fundamental standard of this Code is
that personnel should not take any inappropriate advantage of their position.
A purpose of this Code, among others, is to comply, to the extent applicable to
LFD in its various roles, with Rule 17j-1 under the Investment Company Act of
1940 (the "Act"). Except as provided in this Code, all reports of securities
transactions and any other information filed with a party to whom such a report
or provision of information is required shall be treated as confidential.
Standards of Conduct and Compliance with Laws
Pursuant to Rule 204A-1 under the Advisers Act and pursuant to Rule 17j-1 under
the Act it is unlawful for any investment adviser or principal underwriter,
including any LFD employees, officers, directors or partners, thereof, to:
1. Employ any device, scheme or artifice to defraud the Delaware
Investments Family of Funds, the Optimum Funds or the Lincoln Variable
Insurance Products Trust or any other Investment Company, as that term
is defined in the Investment Company Act of 1940, as amended, (herein,
generally, the "Fund" or "Funds") or;
2. Make any untrue statement of a material fact or omit to state a material
fact necessary in order to make the statements made, in light of the
circumstances in which they are made, not misleading;
3. Engage in any act, practice or course of business that operates or would
operate as a fraud or deceit; or
4. Engage in any manipulative practice.
Prohibited Activities
The following restrictions apply to LFD employees, officers, directors and
partners:
o Insider Trading
Insider trading is a prohibited practice of trading in securities
based on material nonpublic information. All LFD employees, officers,
directors are prohibited from trading, either personally or on behalf
of others (including family), on material nonpublic information or
from communicating material nonpublic information to others. These
individuals are also prohibited from giving advice based on inside
information.
o Use of Unapproved Advertisements and Sales Materials
All advertisements and sales materials which will be used with a
prospect or client of the financial intermediaries must be approved by
Compliance prior to use.
o Mutual Fund Late Trading and Market Timing Abuses
o Late trading is illegal under SEC Rules because late trading would
permit a purchase or redemption order received after 4:00 p.m. to
receive the share price calculated as of 4:00 p.m. that same day.
o Market timing, while not illegal, harms fund investors; therefore,
market timing is strongly discouraged. If the Funds have rules
restricting market timing, those rules must be strictly followed and
enforced by LFD.
o The Board of Trustees/Directors of the Funds ("the Boards") have
adopted policies and procedures designed to detect, deter and prevent
trading activity detrimental to the Funds and their shareholders, such
as market timing. With respect to those Funds which discourage market
timing, purchase orders by shareholders identified as market timers
may be rejected. All mutual funds (as defined by the Act) that advised
or sub-advised by Delaware Investments, Inc. are subject to the 60-day
holding period before selling shares of the Funds at a profit. Note:
Closing positions at a loss is not prohibited.
o All LFD employees, officers, directors and partners are prohibited
from engaging in selective sharing or disclosure of any Fund portfolio
holdings information in a manner inconsistent with the written policy
regarding the dissemination of portfolio holdings information for the
Delaware Investments Family of Funds or the written policies of any
Funds having constraints.
o All LFD employees, officers, directors and partners are prohibited
from using Fund information for their own personal gain or for any
clients of the firm.
o Any LFD employees, officers, directors or partners who own any Funds
must hold them in-house directly with Delaware Investments, Inc.
o Selling Away
A registered representative must obtain written approval from LFD
Compliance prior to participating in any private securities
transaction; such activity may result in selling away which is
prohibited. A private securities transaction is any securities
transaction that is executed outside, or away from the supervision of
LFD. The definition includes money-raising activities, offerings
involving a limited number of purchases or sales, issuing promissory
notes, purchase of private placement and multi-level marketing
programs.
o Purchase of Initial Public Offerings
All LFD employees, officers, directors, partners or any other person
who receives material support from such employee, officer, director or
partner are prohibited from purchasing Initial Public Offerings.
o Engage In Prohibited Sales and Marketing Practices
Certain sales practices are specifically prohibited by various Federal
and State laws, and the NAIC Model Unfair Trade Practices Act, which
has been adopted by many states. Among such prohibited sales practices
are:
o Churning
o Twisting
o Switching
o Arranging for credit
o Bashing
o Deceptive Practices
o Fraud
o High Pressure Tactics
o Rebating
o Unfair Trade Practices
A comprehensive list of policies and procedures are included in the LFD
Compliance Manual.
o Sanctions for Violations of Prohibited Activities
Engaging in any of the Prohibited Activities may subject an individual
to sanction including a fine, suspension or termination.
Protection of Lincoln Client Nonpublic Information
LFD only allows access to Lincoln client non-public information to those
individuals who need to know it in order to provide products or services, or
perform services on LFD's behalf. Individuals who have access to Lincoln client
non-public information must keep such information strictly confidential.
Officers, directors, registered principals and registered representatives of LFD
and any associated persons, as defined below, must prevent disclosure of client
nonpublic information to individuals who do not need the information to perform
their duties.
Required Reports
The following reports are required to be made by all LFD associated persons.
"Associated persons" include any employees, officers, directors and partners of
LFD.
o At employment or engagement, disclose outside brokerage accounts, together
with the holdings therein, in which they have a direct or beneficial
ownership and thereafter disclose any new outside such brokerage accounts
and holdings in which they have a direct or beneficial ownership interest.
o Direct their brokers to supply to LFD Compliance, on a timely basis,
duplicate copies of all confirmations and statements for all securities
accounts.
o Annually certify that they have read the Code of Ethics and any amendments,
and fully comply with this Code of Ethics.
Records of the above disclosures shall be deemed to be "reports" and all
disclosures shall be made and reported in a manner consistent with the
requirements of Rule 17j-1.
Reporting Violations
The supervisory principals and managers shall report to the LFD Chief Compliance
Officer (the "CCO") any apparent violations of the prohibitions or reporting
requirements contained in this Code of Ethics. The CCO will review the reports
made and determine whether or not the Code
of Ethics has been violated and shall determine what sanctions, if any, should
be imposed in addition to any that may already have been imposed.
The CCO will advise the Boards of any issues arising under the Code of Ethics,
including, but not limited to, information about material violations of the Code
of Ethics and sanctions imposed in response to the material violations.
Recordkeeping
LFD must keep copies of:
o LFD's Code of Ethics
o Records of violations of the Code and actions taken as a result of the
violations
o Records acknowledging all associated persons' written acknowledgment of
LFD's Code of Ethics
o A list of all LFD associated persons who are, or within the previous five
year period have been, required to make reports to LFD pursuant to the
Required Reports section above.of all reports provided by all LFD
associated persons
Revised - 06/2007
