Supplement - dated December 15, 2004 to Putnam Code of Ethics
The Putnam Code of Ethics Oversight Committee has approved the following
amendments to the August 2004 Code of Ethics.
Sanctions Guidelines
The Sanctions Guidelines in Section 1A of the Code (page 4 of August
Code) have been withdrawn and are replaced with the following new
Sanctions Guidelines effective with the first quarter of 2005:
"The Code of Ethics Oversight Committee is responsible for setting
sanctions policies for violating the Code. The Committee has adopted the
following minimum monetary sanctions for violations of the Code. These
sanctions apply even if the exception results from inadvertence rather
than intentional misbehavior. The Code of Ethics Officer is authorized
to impose the minimum sanction on employees without further Committee
action. However, the sanctions noted below are only minimums and the
Committee reserves the right to impose additional sanctions such as
higher monetary sanctions, trading bans, suspension or termination of
employment as it determines to be appropriate.
The minimum sanction for a violation of the following Rules is
disgorgement of any profits or payment of avoided losses and the
following payments:
Section IA, Rule 1 (Pre-clearance and Restricted List)
Section IB, Rule 1 (Short-selling)
Section IB, Rule 2 (IPOs)
Section IB, Rule 3 (Private Placements)
Section IB, Rule 4 (Trading with Inside Information)
Section IB, Rules 6-8 (Holding and trading of Putnam Funds)
Section II, Rule 2 (7-Day Rule)
Section II, Rule 3 (Black-out Rule)
Section II, Rule 4, (Contra-Trading Rule)
Section II, Rule 5 (Trading for personal benefit)
Officer Level SMD/MD SVP/VP AVP/non-officer
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1st violation $500 $250 $50
2nd $1,000 $500 $100
3rd Minimum monetary sanction as above with ban on all new
personal individual investments.
The minimum sanction for violations of all other rules in the Code is as
follows:
Officer Level SMD/MD SVP/VP AVP/non-officer
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1st violation $100 $50 $25
Subsequent $200 $100 $50
The reference period for determining whether a violation is initial or
subsequent will be five years.
Excessive Trading
Effective with the 2nd quarter of 2005, the maximum number of trades
permitted in individual securities per quarter is reduced from 25 to 10.
Section 1B, Rule 9 is effective April 1, 2005, will read as follows:
"Putnam employees are strongly discouraged from engaging in excessive
trading for their personal accounts. Beginning in the second quarter of
2005, employees will be prohibited from making more than 10 trades in
individual securities in any given quarter. Excessive trading within
Putnam open-end funds is prohibited."
Access Persons; Holding Period for Individual Securities
Effective with the 2nd quarter of 2005, the holding period rule for
Access Person investments in individual securities will increase from 60
to 90 days. Section II, Rule 1 will read, effective April 1, 2005 as
follows:
"No Access Person shall purchase and then sell at a profit, or sell and
then repurchase at a lower price, any security or related derivative
security with 90 calendar days."
Access Person Reporting
The deadline by which Access Persons are required to file quarterly
statements of all transactions has been increased from 10 to 15 calendar
days after the end of each quarter. This change will be effective in
the April, 2005 filing. Accordingly Section V, Rule 2, will now read as
follows:
"Every Access Person shall file a quarterly report within 15 calendar
days of the end of each quarter, recording all purchases and sales of
any securities for personal accounts as defined in the Definitions. (For
purposes of this Rule, securities shall include exchange traded funds
(ETFs), futures and any option on a security or securities index,
including broad based market indices excluded from the pre-clearance
requirement and also includes transactions in Putnam open-end funds if
the account for the Putnam funds is not held at Putnam Securities
Services or in a Putnam retirement plan and for transactions in US
mutual funds sub-advised by Putnam."
Access Person Definition
As required by new SEC rule 204A-1, the definition of Access Persons
under the Code has been amended, effective February 1, 2005 to include
Putnam employees with access to non public information about affiliated
mutual fund portfolio holdings. The definition of Access Person will
read as of February 1, 2005 as follows:
"Access Persons are:
(a) all employees in Putnam's Investment Division;
(b) all directors and officers of all Putnam entities which are SEC
registered investment advisers;
(c) all members of Putnam's Executive Board and all Managing Directors
in Putnam's marketing and sales organizations; and
(d) any other employee of Putnam who, in connection with regular duties,
has access to nonpublic information about any client's purchase or sale
of securities or to information regarding recommendations with respect
to such purchases or sales or who has access to nonpublic information
regarding the portfolio holdings of any Putnam advised or sub-advised
mutual fund.
Each employee will be informed if he or she is considered an Access
Person. The Code of Ethics Officer maintains a list of all Access
Persons."