APPENDIX J
CODE OF ETHICS
I. INTRODUCTION.
The Board of Trustees (the "Board") of Global X Funds (the "Company"), in
accordance with Rule 17j-1 under the Investment Company Act of 1940, as amended
(the "1940 Act"), has approved and adopted this Code of Ethics (the "Code") and
has determined that this Code is reasonably designed to prevent Access Persons,
as defined herein, from engaging in conduct prohibited by Rule 17j-1. This Code
also sets forth the general fiduciary principles to which all of the Company's
Access Persons are subject and establishes reporting requirements for Access
Persons. Certain capitalized terms used in this Code and not defined in the text
herein, such as "Access Persons," are defined in Appendix A.
A. ABOUT THE COMPANY AND THE ADVISOR
The Company is a registered investment company that consists of multiple
investment portfolios of exchange-traded funds, each of which is hereinafter
referred to as a "Fund." Global X Management Company LLC (the "Advisor") is the
investment adviser for the Funds. In managing the Funds, the Advisor employs a
passive, or indexing, strategy which seeks to replicate, for each Fund's
investment portfolio, the composition of each Fund's benchmark index (the
"Underlying Index"). The composition of each Underlying Index is maintained by a
third party (the "Index Provider") that is unaffiliated with the Advisor or the
Company. The Index Provider alone decides the component securities in each
Underlying Index. SEI Investments Distribution Co. (the "Distributor") serves as
the distributor of creation units for each Fund on an agency basis. In adopting
this Code, the Board took into consideration all of these facts.
B. WHO IS COVERED BY THE CODE
This Code applies to all Access Persons of the Company, which includes all
Trustees of the Company (both Interested Trustees and Independent Trustees), and
all officers of the Company
II. STATEMENT OF GENERAL FIDUCIARY PRINCIPLES.
The Company requires that its Trustees, officers and Access Persons conduct
their personal investment activities in accordance with the following general
fiduciary principles:
o the duty at all times to place the interests of the Company's
shareholders first;
o the requirement that all personal securities transactions must be
conducted consistent with this 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; and
o the fundamental standard that Company personnel should not take
inappropriate advantage of their positions.
In view of the foregoing, the Company has determined to adopt this Code to
specify a code of conduct for certain types of personal securities transactions
which might involve conflicts of interest or an appearance of impropriety and to
establish reporting requirements and enforcement procedures.
III. RESTRICTIONS ON PERSONAL INVESTING ACTIVITIES.
A. GENERAL POLICY
No Access Person shall, in connection with the direct or indirect purchase
or sale of a Security "held or to be acquired" by a Fund:
o employ any device, scheme or artifice to defraud the Funds;
o make any untrue statement of a material fact or omit to state a
material fact necessary in order to make the statements, in light of
the circumstances under which they are made, not misleading;
o engage in any act, practice or course of business that operates or
would operate as a fraud or deceit upon the Funds; or
o engage in any manipulative practice with respect to the Funds.
B. PROHIBITION AGAINST INSIDER TRADING
Access Persons and the members of their Family/Household are prohibited
from engaging in, or helping others engage in, insider trading. Generally, the
"insider trading" doctrine under U.S. federal securities laws prohibits any
person (including investment advisers) from knowingly or recklessly breaching a
duty owed by that person by:
(1) trading while in possession of material, nonpublic information;
(2) communicating ("tipping") such information to others;
(3) recommending the purchase or sale of securities on the basis of such
information; or
(4) providing substantial assistance to someone who is engaged in any of
the above activities.
This means that Access Persons and members of their Family/Household may
not trade with respect to a particular security or issuer at a time when that
person knows or should know that he or she is in possession of material
nonpublic information about the issuer or security. Information is considered
"material" if there is a substantial likelihood that a reasonable investor would
consider it important in making his or her investment decisions, or if it could
reasonably be expected to affect the price of a company's securities, such as
information about a
drug trial or clinical testing results. Material information can also relate to
events or circumstances affecting the market for a company's securities such as
information about an expected government ruling or regulation that can affect
the business of a company in which a Fund invests. Information is considered
nonpublic until such time as it has been disseminated in a manner making it
available to investors generally (E.G., through national business and financial
news wire services).
C. PRE-CLEARANCE OF INVESTMENTS IN IPOS OR LIMITED OFFERINGS.
Access Persons who also meet the definition of Investment Personnel may not
directly or indirectly acquire Beneficial Ownership in any Securities in an IPO
or Limited Offering without obtaining, in advance of the transaction, clearance
from the Advisor's Chief Compliance Officer ("CCO"). In order to obtain
pre-clearance, a person meeting the definition of Investment Personnel must
complete and submit to the CCO a Personal Trade Request Form (a "PTR") which is
included as Appendix B. The CCO must review each request for approval and record
the decision regarding the request. The general standards for granting or
denying pre-clearance are discussed below, although the CCO retains authority to
grant pre-clearance in exceptional circumstances for good cause. If
pre-clearance is obtained, the approval is valid for the day on which it is
granted and the immediately following business day. The CCO may revoke a
pre-clearance any time after it is granted and before the transaction is
executed.
Pre-clearance will typically not be given to an Access Person to purchase
or sell any IPO or Limited Offering of an issuer (i) if such Security is a
component Security in an Underlying Index, on a day when the Security is "being
considered for purchase or sale" by a Fund or (ii) if such Security is not a
component Security in an Underlying Index but public notice has been given that
such Security will be added to, or removed from, an Underlying Index, until such
time as the applicable Fund completes the reconstitution of its portfolio to
replicate the Security's weighting in the Underlying Index.
D. RESTRICTIONS ON PERSONAL SECURITIES TRANSACTIONS FOR ACCESS PERSONS
OTHER THAN INDEPENDENT TRUSTEES AND DISTRIBUTOR ACCESS PERSONS
Each Access Person shall direct his or her broker to supply to the CCO,
on a timely basis, duplicate copies of confirmations of all Securities
transactions, other than for Exempt Securities, in which the person has, or by
reason of such transaction acquires, any direct or indirect Beneficial Ownership
and copies of periodic statements for all securities accounts
(1) Pre-clearance
Access Persons may not buy or sell Securities, other than Exempt
Securities, for any account in which he or she has any direct or indirect
Beneficial Ownership, unless such person obtains, in advance of the transaction,
clearance for that transaction from the Company's CCO or his designee. The CCO
has designated the Advisor's CCO as the person responsible for reviewing and
granting pre-clearance requests under the Code. The general standards for
granting or denying pre-clearance are discussed below, although the CCO retains
authority to grant pre-clearance in exceptional circumstances for good cause.
Pre-clearance must be obtained for all Securities, except
Exempt Securities, that either (i) are included as a component Security in an
Underlying Index or (ii) for which public notice has been given that such
Security will be added to, or deleted from, an Underlying Index.
In order to obtain pre-clearance, an Access Person must complete and
submit to the CCO a PTR. If the transaction is approved by the CCO, that
approval is valid for the day on which it is granted and the immediately
following business day. The CCO may revoke a pre-clearance any time after it is
granted and before the transaction is executed. Pre-clearance will typically not
be given to purchase or sell any Security of an issuer (i) if such Security is a
component Security in an Underlying Index, on a day when the Security is being
considered for purchase or sale by a Fund or (ii) if such Security is not a
component Security in an Underlying Index but public notice has been given that
such Security will be added to, or deleted from, an Underlying Index, until such
time as the applicable Fund completes the reconstitution of its portfolio to
replicate the Security's weighting in the Underlying Index.
(2) Prohibition on Short-Term Trading
Access Persons may not purchase or sell, or sell and purchase, within
any period of 30 calendar days, a Security, other than an Exempt Security, held
by a Fund. If any such transactions occur, the Company will require any profits
from the transactions to be disgorged for donation by the Company to charity. In
applying the 30 calendar day holding period, the Company will apply the
"last-in, first-out" methodology.
(3) Prohibition on Short Sales and Similar Transactions.
Access Persons may not purchase a put option or sell a call option,
sell short or otherwise take a short position, either directly or through any
Beneficial Ownership, in any Security held by any Fund.
E. RESTRICTIONS ON PERSONAL SECURITIES TRANSACTIONS BY ACCESS PERSONS
WHO ARE INDEPENDENT TRUSTEES.
The Company recognizes that Independent Trustees do not have on-going,
day-to-day involvement with the operations of the Company and are not involved
in decisions regarding Fund portfolio transactions. In addition, it is the
practice of the Company to give information about Securities purchased or sold
by each Fund, or considered for purchase and sale by each Fund, to Independent
Trustees in materials circulated more than 15 days after such Securities are
purchased or sold by a Fund or are considered for purchase or sale by a Fund.
Accordingly, the Company believes that less stringent controls are
appropriate for Independent Trustees, as follows:
1. The Securities pre-clearance requirement contained in paragraph
III.D.l. and the short-term trading and short sale restrictions
in paragraphs III.D.2 and III.D.3 above shall only apply to an
Independent Trustee if he or she knew or, in the ordinary course
of fulfilling his or her official duties as a director, should
have known, that at the time of his or her transaction in a
Security (other than an Exempt Security) or during the 15-day
period before that
transaction, that the Security was also purchased or sold by a
Fund or considered for the purchase or sale by a Fund.
2. If the pre-clearance provisions of the preceding paragraph apply,
no pre-clearance will be given to an Independent Trustee to
purchase or sell any Security of an issuer (i) if such Security
is a component Security in an Underlying Index, on a day when the
Security is being considered for purchase or sale by a Fund; (ii)
if such Security is not a component Security in an Underlying
Index but public notice has been given that such Security will be
added to, or deleted from, an Underlying Index, until such time
as the applicable Fund completes the reconstitution of its
portfolio to replicate the Security's weighting in the Underlying
Index; or (iii) when the CCO has been advised by the Advisor that
the same Security is being considered for purchase or sale for a
Fund.
IV. REPORTING REQUIREMENTS AND PROCEDURES.
In order to provide the Company with information to enable it to determine
with reasonable assurance whether the provisions of this Code are being observed
by its Access Persons, the following reporting requirements regarding personal
securities transactions apply.
A. REPORTING REQUIREMENTS FOR ACCESS PERSONS OTHER THAN INDEPENDENT
TRUSTEES AND DISTRIBUTOR ACCESS PERSONS
(1) INITIAL AND ANNUAL HOLDINGS REPORTS: Within ten days after a
person becomes an Access Person, and annually thereafter,
such person shall submit to the CCO a completed
Initial/Annual Holdings Report substantially in the form
attached hereto as Appendix C. Each holdings report must
contain, at a minimum, (a) the title and type of Security,
and, as applicable, the exchange ticker symbol or CUSIP
number, number of shares and principal amount of each
Security (other than an Exempt Security) in which the person
has any direct or indirect beneficial ownership; (b) the
name of any broker, dealer or bank with whom the person
maintains an account in which any Securities other than
Exempt Securities are held for the person's direct or
indirect benefit; and (c) the date the person submits the
report. The Initial Holdings Report must be current as of a
date no more than 45 days prior to the date the person
became an Access Person and the Annual Holdings Report shall
be submitted no later than January 31 and must be current as
of a date no more than 45 days prior to the date the report
is submitted.
(2) QUARTERLY REPORT: Each Access Person shall submit reports
substantially in the form attached hereto as Appendix D to
the CCO, showing all transactions in Securities (other than
Exempt Securities) in which the person has, or by reason of
such transaction acquires, any direct or indirect beneficial
ownership, as well as all accounts established with brokers,
dealers or banks during the quarter in which any Securities,
other than Exempt Securities, were held for the direct or
indirect beneficial interest of the person. Such reports
shall be filed no later than 30 days after the end of each
calendar
quarter. An Access Person need not make a quarterly
transaction report under this paragraph if all of the
information required by this paragraph is contained in the
brokerage confirmations or account statements required to be
submitted under III.D above. The Report must include the
date on which such report was submitted to the CCO.
B. REPORTING REQUIREMENTS FOR INDEPENDENT TRUSTEES
An Independent Trustee need not make an initial or annual holdings
report described in paragraph IV.A.1 above and shall only be required to submit
the quarterly report required under paragraph IV.A.2 for a transaction in a
Security (other than an Exempt Security) where he or she knew (or should have
known) at the time of the transaction or, in the ordinary course of fulfilling
his or her official duties as a director, should have known that during the
15-day period immediately preceding or after the date of the transaction, such
Security is or was purchased or sold, or considered for purchase or sale, by a
Fund.
V. ADMINISTRATION OF THE CODE.
A. The CCO's Duties and Responsibilities.
(1) The CCO shall promptly provide all persons covered by this
Code with a copy of the Code. In addition, all persons
covered by this Code must complete the Acknowledgment
included as Appendix E within ten days of becoming subject
to this Code and must submit an Acknowledgment to the CCO by
January 31 each year thereafter;
(2) The CCO shall identify all Access Persons and inform them of
their reporting obligations promptly.
(3) In determining whether to approve a PTR, the CCO will
determine, in good faith, whether the Access Person knew, or
should have known, that a Fund had engaged in a transaction
involving, or was contemplating a transaction involving,
such a Security with 15 days of the PTR. The CCO must
maintain a record of any decision relating to pre-clearance
requests, and the reasons supporting the decision, for at
least five years after the end of the fiscal year in which
the approval is granted;
(4) The CCO will, on a quarterly basis, compare all reported
personal securities transactions with the Funds' completed
portfolio transactions during the quarter to determine
whether a Code violation may have occurred. The CCO may
request additional information or take any other appropriate
measure that he or she decides is necessary to aid in this
determination;
(5) If the CCO finds that a Code violation may have occurred,
the CCO must report the possible violation to the Board;
(6) The CCO will submit his or her own reports (as required) to
an alternate compliance officer who will fulfill the duties
of the CCO with respect to such reports; and
(7) At least annually, the CCO must furnish to the Board, and
the Board must consider, a written report that describes any
issues arising under the Code since the previous report,
including, but not limited to, information about material
violations of the Code and sanctions imposed in response to
the material violations; and certifies that the Code
contains policies and procedures reasonably designed to
prevent Access Persons from violating the Code.
B. The Board's Duties and Responsibilities
(1) The Board must approve this Code before retaining the
Advisor's services;
(2) The Board must approve all material changes to this Code no
later than six months after adoption of the material change;
and
(3) The Board will determine, in its sole discretion, whether a
person has violated the Code. If it is determined that a
person violated the Code, the Board shall determine the
appropriate disciplinary action to be taken and sanctions to
be imposed.
C. The Advisor's Duties and Responsibilities
At least annually, the Advisor shall furnish to the Board, and
the Board shall consider, a written report that describes any
issues arising under this code of ethics since the previous
report, including, but not limited to, information about material
violations of the code of ethics or procedures and sanctions
imposed in response to the material violations; and certifies
that the Advisor has adopted procedures reasonably necessary to
prevent its Access Persons from violating the code of ethics.
VI. RECORDKEEPING.
The Company will maintain records as set forth below. These records will be
maintained in accordance with Rule 17j-1 under the 1940 Act and the following
requirements. They will be available for examination by representatives of the
Securities and Exchange Commission (the "SEC") and other regulatory agencies.
A. A copy of this Code and any other code adopted by the Company
which is, or at any time within the past five years has been, in
effect will be preserved in an easily accessible place.
B. A record of any Code violation and of any action taken as a
result of the violation will be preserved in an easily accessible
place for a period of at least five years following the end of
the fiscal year in which the violation occurred.
C. A copy of each report submitted by an Access Person under this
Code will be preserved for a period of at least five years from
the end of the fiscal year in which the report is made or the
information is provided, for the first two years in an easily
accessible place.
D. A record of all persons, currently or within the past five years,
who are or were required to submit reports under this Code, and a
list of those who are or were responsible for reviewing these
reports, will be maintained in an easily accessible place.
E. A copy of each annual issues report and accompanying
certification, as required by this Code, must be maintained for
at least five years from the end of the fiscal year in which it
is made, for the first two years in any easily accessible place.
VII. MISCELLANEOUS.
A. Confidentiality.
The Company will endeavor to maintain the confidentiality of all PTRs
and any other information filed pursuant to this Code. Such reports and related
information, however, may be produced to the SEC and other regulatory agencies.
B. The "should have known" standard. For purposes of this Code, the
"should have known" standard does not:
o imply a duty of inquiry;
o presume that the individual should have deduced or
extrapolated from discussions or memoranda dealing with a
Fund's investment strategies; or
o impute knowledge from the individual's awareness of a Fund's
portfolio holdings, market considerations, benchmark index,
or investment policies, objectives and restrictions.
APPENDIX A
DEFINITIONS
The definitions and terms used in this Code are intended to mean the same
as they do under the 1940 Act and the other federal securities laws. If a
definition hereunder conflicts with the definition in the 1940 Act or other
federal securities laws, or if a term used in this Code is not defined, the
definitions and meanings in the 1940 Act or other federal securities laws, as
applicable, should be followed.
ACCESS PERSON means: (i) the Company's directors and officers; (ii) any
Advisor Access Person; (iii) any other any employee of the Company who, in
connection with his or her regular functions or duties, makes, participates in,
or obtains information regarding, the purchase or sale of a Security by the
Company, or whose functions relate to the making of any recommendations with
respect to such purchases or sales; (iv) any natural person in a control
relationship to the Company who obtains information concerning recommendations
made to the Company with regard to the purchase or sale of Securities; and (v)
any director, officer or general partner of the principal underwriter who, in
the ordinary course of business, makes, participates in or obtains information
regarding, the purchase or sale of Securities by the Company, or whose functions
or duties in the ordinary course of business relate to the making of any
recommendation to the Company regarding the purchase or sale of Securities.
Access Persons include:
(a) a member of an Access Person's immediate family (spouse, domestic
partner, child or parents) who lives in an Access Person's
household (including children who are temporarily living outside
of the household for school, military service or other similar
situation);
(b) a relative of the person who lives in an Access Person's
household and over whose purchases, sales, or other trading
activities an Access Person directly or indirectly exercises
influence;
(c) a relative whose financial affairs an Access Person "controls,"
whether by contract, arrangement, understanding or by convention
(such as a relative he or she traditionally advises with regard
to investment choices, invests for or otherwise assists
financially);
(d) an investment account over which an Access Person has investment
control or discretion;
(e) a trust or other arrangement that names an Access Person as a
beneficiary; and
(f) a non-public entity (partnership, corporation or otherwise) of
which an Access Person is a director, officer, partner or
employee, or in which he owns 10% or more of any class of voting
securities, a "controlling" interest as generally defined by
securities laws, or over which he exercises effective control.
ADVISOR ACCESS PERSON means a person who meets the definition of Access
Person with respect to the Advisor.
AUTOMATIC INVESTMENT PLAN means a program in which regular periodic
purchases (or withdrawals) are made automatically in (or from) investment
accounts in accordance with a predetermined schedule and allocation. An
Automatic Investment Plan includes a dividend reinvestment plan. However, any
transaction that overrides the pre-set schedule or allocations of the automatic
investment plan is not under the Automatic Investment Plan.
BENEFICIAL OWNERSHIP or BENEFICIALLY OWNS means the same as it does under
Section 16 of the Securities Exchange Act of 1934 and Rule 16a-1(a)(2)
thereunder. A person is the "beneficial owner" of any securities in which he or
she has a direct or indirect pecuniary (monetary) interest.
CONTROL means the power to exercise a controlling influence over the
management or policies of a Fund, unless such power is solely the result of an
official position with such Fund. Any person who owns beneficially, either
directly or through one or more controlled companies, more than 25 per centum of
the voting securities of a Fund shall be presumed to control such Fund. Any
person who does not so own more than 25 per centum of the voting securities of
any Fund shall be presumed not to control such Fund. A natural person shall be
presumed not to be a controlled person within the meaning of this title. Any
such presumption may be rebutted by evidence, but except as otherwise provided
in accordance with applicable law, shall continue until a determination to the
contrary made by the SEC by order either on its own motion or on application by
an interested person.
DISTRIBUTOR ACCESS PERSON means a person who meets the definition of Access
Person with respect to the Distributor and is subject to the Distributor's Code
of Ethics. If such person is an Access Person but is not subject to the
Distributor's Code of Ethics, such person shall be considered an Adviser Access
Person for all purposes herein.
EXEMPT SECURITY means: (i) direct obligations of the U.S. Government (or
any other "government security" as that term is defined in the 1940 Act),
bankers' acceptances, bank certificates of deposit, commercial paper and
High-Quality Short-Term Debt Instruments, including repurchase agreements, and
shares of registered open-end investment companies, other than exchange traded
funds, (ii) securities purchased or sold in any account over which the Access
Person has no direct or indirect influence or control, (iii) securities
purchased or sold in a transaction that is non-volitional on the part of either
the Access Person or a Company, including mergers, recapitalizations or similar
transactions, and (iv) securities acquired as a part of an Automatic Investment
Plan.
FAMILY/HOUSEHOLD means a member of such person's immediate family (spouse,
domestic partner, child or parents) who lives in the person's household
(including children who are temporarily living outside of the household for
school, military service or other similar situation), and a relative of the
person who lives in such person's household.
HIGH QUALITY SHORT-TERM DEBT INSTRUMENT means any instrument that has a
maturity at issuance of less than 366 days and that is rated in one of the two
highest rating categories by a nationally recognized statistical rating
organization (E.G., Moody's Investors Service).
INDEPENDENT TRUSTEE means a Trustee of the Company who is not an
"interested person" of the Company within the meaning of Section 2(a)(19) of the
1940 Act.
IPO (I.E., initial public offering) means an offering of securities
registered under the Securities Act of 1933 the issuer of which, immediately
before the registration, was not subject to the reporting requirements of
Sections 13 or 15(d) of the Securities Exchange Act of 1934.
INTERESTED TRUSTEE means a Trustee of the Company who is an "interested
person" of the Company within the meaning of Section 2(a)(19) of the 1940 Act.
INVESTMENT PERSONNEL means (i) any employee of the Company or the Advisor
(or of any company in a control relationship to the Company or the Advisor) who,
in connection with his or her regular functions or duties, makes or participates
in making recommendations regarding the purchase or sale of Securities by the
Company, (ii) any natural person who controls the Company or the and who obtains
information concerning recommendations made to the Company regarding the
purchase or sale of Securities by that Company.
LIMITED OFFERING means an offering that is exempt from registration under
the Securities Act of 1933 pursuant to Section 4(2), Section 4(6), Rule 504,
Rule 505 or Rule 506 (E.G., private placements).
PURCHASE or SALE of a security includes, among other things, the writing of
an option to purchase or sell a security.
SECURITY or SECURITIES means any note, stock, treasury stock, security
future, bond, debenture, evidence of indebtedness, certificate of interest or
participation in any profit-sharing agreement, collateral-trust certificate,
preorganization certificate or subscription, transferable share, investment
contract, voting-trust certificate, certificate of deposit for a security,
fractional undivided interest in oil, gas, or other mineral rights, any put,
call, straddle, option, or privilege on any security (including a certificate of
deposit) or on any group or index of securities (including any interest therein
or based on the value thereof), or any put, call, straddle, option, or privilege
entered into on a national securities exchange relating to foreign currency, or,
in general, any interest or instrument commonly known as a "security," or any
certificate of interest or participation in, temporary or interim certificate
for, receipt for, guarantee of, or warrant or right to subscribe to or purchase
any of the foregoing.
A SECURITY HELD or TO BE ACQUIRED by a Fund means: (i) any security that
within the most recent 15 days is or has been held by the Fund or is being or
has been considered by the Advisor for purchase by the Fund and (ii) any option
to purchase or sell, and any security convertible into or exchangeable for, a
security.
APPENDIX B
PERSONAL TRADE REQUEST FORM (PTR)
The following form must be completed by you in order to request
pre-clearance of a personal securities transaction that requires pre-clearance
under the Code of Ethics of the Global X Funds. By signing below, you certify
that you are not aware of any trades for any Funds in this Security over the
past 15 days and that you are also not aware that the Advisor is planning on
engaging in a trade involving this Security over the next 15 days. You further
certify that you do not have any confidential or inside information relating to
the issuer of this Security. This Form must be submitted to the Company's Chief
Compliance Officer. You may not complete this trade until you receive approval
from the Chief Compliance Officer. If approved, the approval is good for the day
it is given and the following business day. If your trade is not completed
within that time, you must submit a new request.
Name:
Social Security Number:
INVESTMENT INFORMATION
Issuer and ticker symbol:
Nature of Equity Investments (please circle):
Common Stock Preferred Stock
Number of Shares:
Nature of Fixed Income Investments:
Describe instrument:
Principal amount of
trade:
TRANSACTION INFORMATION
Transaction Type (please circle):
Purchase Sale Short Sale
Estimated Trade Date:
Estimated Price:
Broker/Dealer:
Is the proposed investment an IPO? Y N
Is the proposed investment a Limited Offering? Y N
Signature:
---------------------
B-1
Date:
--------------------------
Chief Compliance Officer Action
Approved:
-------------------------
Not Approved:
-----------------------
APPENDIX C
INITIAL AND ANNUAL HOLDINGS REPORTS
To: The Chief Compliance Officer
Global X Funds
As of , a date within 45 calendar days of this submission,
I had direct or indirect beneficial ownership interest in the Securities listed
below which are required to be reported pursuant to the Code of Ethics of Global
X Funds.
Name of Reporting Person:
If Initial Report, Date Person Became Subject to the Code:
Information in Report Dated as of:
Date Report Submitted:
SECURITIES HOLDINGS :
Check here if, in lieu of completing the chart below, you have attached all of
your most recent investment account statements: [_] , Number of statements
attached:
PRINCIPAL AMOUNT,
TICKER SYMBOL MATURITY DATE AND INTEREST
TITLE OF SECURITY OR CUSIP NUMBER OF SHARES RATE (IF APPLICABLE)
- ----------------------------------------------------------------------------------------------------
The name of all brokers, dealers or banks with whom I maintain an account
in which my securities are held for my direct or indirect benefit are as follows
NAME OF BROKER, DEALER OR BANK NAME(S) ON AND TYPE OF ACCOUNT
- --------------------------------------------- ----------------------------------------------
I certify that I have included on this report all securities holdings
and accounts required to be reported pursuant to the Code of Ethics and that the
information contained herein is accurate an complete.
Signature: Date:
----------------------------- ------------------------------------
APPENDIX D
QUARTERLY REPORT
To: The Chief Compliance Officer
Global X Funds
I hereby certify that I have engaged in the following personal securities
transactions which are required to be reported under the Code of Ethics of
Global X Funds during the calendar quarter indicated below. I hereby submit this
report within 30 days after the end of that quarter. (Note: you do not need to
complete this report if all of your trading confirmations and account statements
are already being delivered to the Chief Compliance Officer)
Name of Reporting Person:
Calendar Quarter Ended:
Date Report Submitted:
Securities Transactions
Please provide the following information for any reportable transactions during the quarter:
PRINCIPAL NAME OF
AMOUNT, BROKER,
MATURITY DATE DEALER OR
TICKER AND INTEREST BANK
DATE OF TITLE OF SYMBOL OR NUMBER OF RATE (IF TYPE OF EFFECTING
TRANSACTION SECURITY CUSIP SHARES PRICE APPLICABLE) TRANSACTION TRANSACTION
- -------------------------------------------------------------------------------------------------------------------
I have established the following new accounts with brokers, dealers or
banks in which my securities are held for my direct or indirect benefit.
NAME OF BROKER, DEALER OR BANK DATE ACCOUNT WAS ESTABLISHED NAME(S) ON AND TYPE OF ACCOUNT
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I certify that I have included on this report all securities transactions
and accounts required to be reported pursuant to the Code of Ethics.
Signature: Date:
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APPENDIX E
ACKNOWLEDGMENT
To: Chief Compliance Officer
Global X Funds
Re: Acknowledgment of Code of Ethics
Initial Acknowledgment: Please check here if this is an initial
acknowledgment. ?
I certify that (1) I have received, read and understand this Code of
Ethics, (2) I am aware that I am subject to the provisions of this Code, (3) I
will comply with this Code, (4) I will report all holdings, transactions and
accounts that I am required to report pursuant to this Code.
Annual Acknowledgment: Please check here if this is an annual
acknowledgment. ?
I certify that (1) I have received, read and understand this Code of
Ethics, (2) I am aware that I am subject to the provisions of this Code, (3) I
have complied with this Code at all times during the previous calendar year, and
(4) I have, during the previous calendar year, reported all holdings,
transactions and accounts that I am required to report pursuant to this Code.
Name (print):
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Position:
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Signature:
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Date Submitted:
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