REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 | | [ X ] | ||
| Pre-Effective Amendment No. | ____ | [ ] | |
| Post-Effective Amendment No. | 91_ | [ X ] | |
and/or | ||||
REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940 | [ X ] | |||
Amendment No. | 91_ | [ X ] |
International Equity Portfolio—Class I Shares |
Fund Summary | |
|
2 |
|
9 |
|
9 |
|
14 |
|
15 |
|
15 |
|
17 |
Your Investment | |
|
18 |
|
19 |
|
20 |
|
20 |
|
21 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 1.15 |
Distribution and/or shareholder service (12b-1) fees | None |
Other expenses | 0.30 |
Total annual operating expenses | 1.45 |
Fee waiver and/or expense reimbursement | 0.43 |
Total annual operating expenses after fee waiver and/or expense reimbursement1 | 1.02 |
1 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class I so that total annual operating expenses (excluding interest, taxes, transaction costs, brokerage commissions, dividend and interest expenses relating to short sales, acquired fund fees and expenses and extraordinary expenses, if any) (“annual operating expenses”) are limited to 1.00% of average net assets. This undertaking lasts until 12/31/2025 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that Class I will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 1.00% of its average net assets. Any such repayment must be made within three years after the year in which the Manager incurred the expense. |
1 Year | 3 Years | 5 Years | 10 Years | |
Expenses | $104 | $325 | $662 | $1,617 |
International Equity Portfolio | 1 Year | 5 Years | 10 Years |
Class I | 14.03 | 11.84 | 8.94 |
MSCI EAFE® Index (Net) (reflects reinvested dividends net of withholding taxes, but reflects no deduction for fees, expenses or taxes) | 11.26 | 9.55 | 8.03 |
YEAR ENDED DECEMBER 31, | 2018(1) | 2019 | 2020 | 2021 |
PER-SHARE DATA ($) | ||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | ||||
Share price (NAV) at beginning of year | 14.42 | 11.30 | 13.77 | 14.65 |
Plus: | ||||
Income from investment operations | ||||
Net investment income (loss)(5) | 0.13 | 0.13 | 0.07 | 0.16 |
Net gains (losses)—realized and unrealized | (3.18) | 3.01 | 1.65 | 1.89 |
Subtotal: income (loss) from investment operations | (3.05) | 3.14 | 1.72 | 2.05 |
Minus: | ||||
Distributions to shareholders | ||||
Income dividends | 0.07 | 0.12 | 0.14 | 0.12 |
Capital gain distributions | — | 0.55 | 0.70 | 0.24 |
Subtotal: distributions to shareholders | 0.07 | 0.67 | 0.84 | 0.36 |
Plus: | ||||
Voluntary contribution from Management | — | — | 0.01 | — |
Equals: | ||||
Share price (NAV) at end of year | 11.30 | 13.77 | 14.65 | 16.34 |
RATIOS (% OF AVERAGE NET ASSETS) | ||||
The ratios show the Fund's expenses and net investment income (loss), as they actually are as well as how they would have been if certain expense reimbursement arrangements had not been in effect. | ||||
Net expenses—actual | 1.01(6) | 1.00 | 1.00 | 1.02 |
Gross expenses(2) | 1.49(6) | 1.47 | 1.45 | 1.45 |
Net investment income (loss)—actual | 1.12(6) | 1.00 | 0.56 | 0.99 |
OTHER DATA | ||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | ||||
Total return (%)(3)(4) | (21.20)(7) | 28.35 | 13.14 | 14.03 |
Net assets at end of year (in millions of dollars) | 53.6 | 65.9 | 71.2 | 23.2 |
Portfolio turnover rate (%) | 31(7) | 26 | 31 | 31 |
(1) | Period from 1/30/18 (beginning of operations) to 12/31/18. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement. |
(3) | Would have been lower if there had been no expense reimbursement. |
(4) | Does not reflect charges and other expenses that apply to the separate account or the related insurance policies. Qualified plans that are direct shareholders of the Fund are not affected by insurance related expenses. |
(5) | Calculated based on the average number of shares outstanding during each fiscal period. |
(6) | Annualized. |
(7) | Not Annualized. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
■ | a discussion by the Portfolio Manager(s) about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
International Equity Portfolio—Class S Shares |
Fund Summary | |
|
2 |
|
9 |
|
9 |
|
14 |
|
15 |
|
15 |
|
17 |
Your Investment | |
|
18 |
|
19 |
|
20 |
|
20 |
|
21 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 1.15 |
Distribution and/or shareholder service (12b-1) fees | 0.25 |
Other expenses | 0.38 |
Total annual operating expenses | 1.78 |
Fee waiver and/or expense reimbursement | 0.24 |
Total annual operating expenses after fee waiver and/or expense reimbursement1 | 1.54 |
1 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class S so that total annual operating expenses (excluding interest, taxes, transaction costs, brokerage commissions, dividend and interest expenses relating to short sales, acquired fund fees and expenses and extraordinary expenses, if any) (“annual operating expenses”) are limited to 1.50% of average net assets. This undertaking lasts until 12/31/2025 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that Class S will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 1.50% of its average net assets. Any such repayment must be made within three years after the year in which the Manager incurred the expense. |
1 Year | 3 Years | 5 Years | 10 Years | |
Expenses | $157 | $486 | $893 | $2,031 |
International Equity Portfolio | 1 Year | 5 Years | 10 Years |
Class S | 13.35 | 11.39 | 8.73 |
MSCI EAFE® Index (Net) (reflects reinvested dividends net of withholding taxes, but reflects no deduction for fees, expenses or taxes) | 11.26 | 9.55 | 8.03 |
YEAR ENDED DECEMBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 10.82 | 13.63 | 11.30 | 13.81 | 14.70 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(4) | 0.05 | 0.02 | 0.06 | 0.01 | 0.08 |
Net gains (losses)—realized and unrealized | 2.84 | (2.33) | 3.02 | 1.65 | 1.88 |
Subtotal: income (loss) from investment operations | 2.89 | (2.31) | 3.08 | 1.66 | 1.96 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.08 | 0.02 | 0.02 | 0.07 | 0.05 |
Capital gain distributions | — | — | 0.55 | 0.70 | 0.24 |
Subtotal: distributions to shareholders | 0.08 | 0.02 | 0.57 | 0.77 | 0.29 |
Plus: | |||||
Voluntary contribution from Management | — | — | — | 0.01 | — |
Equals: | |||||
Share price (NAV) at end of year | 13.63 | 11.30 | 13.81 | 14.70 | 16.37 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund's expenses and net investment income (loss), as they actually are as well as how they would have been if certain expense reimbursement arrangements had not been in effect. | |||||
Net expenses—actual | 1.50 | 1.51 | 1.50 | 1.50 | 1.54 |
Gross expenses(1) | 1.74 | 1.73 | 1.72 | 1.70 | 1.78 |
Net investment income (loss)—actual | 0.42 | 0.13 | 0.51 | 0.06 | 0.48 |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2)(3) | 26.76 | (16.95) | 27.69 | 12.57 | 13.35 |
Net assets at end of year (in millions of dollars) | 83.6 | 15.2 | 16.5 | 16.3 | 17.1 |
Portfolio turnover rate (%) | 23 | 31 | 26 | 31 | 31 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement. |
(2) | Would have been lower if there had been no expense reimbursement. |
(3) | Does not reflect charges and other expenses that apply to the separate account or the related insurance policies. Qualified plans that are direct shareholders of the Fund are not affected by insurance related expenses. |
(4) | Calculated based on the average number of shares outstanding during each fiscal period. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
■ | a discussion by the Portfolio Manager(s) about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
Mid Cap Growth Portfolio—Class I Shares |
Fund Summary | |
|
2 |
|
7 |
|
7 |
|
11 |
|
11 |
|
11 |
|
13 |
Your Investment | |
|
14 |
|
15 |
|
16 |
|
16 |
|
17 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 0.83 |
Distribution and/or shareholder service (12b-1) fees | None |
Other expenses | 0.06 |
Total annual operating expenses | 0.89 |
1 Year | 3 Years | 5 Years | 10 Years | |
Expenses | $91 | $284 | $493 | $1,096 |
Mid Cap Growth Portfolio | 1 Year | 5 Years | 10 Years |
Class I | 12.99 | 19.75 | 15.36 |
Russell Midcap® Growth Index (reflects no deduction for fees, expenses or taxes) | 12.73 | 19.83 | 16.63 |
Russell Midcap® Index (reflects no deduction for fees, expenses or taxes) | 22.58 | 15.10 | 14.91 |
YEAR ENDED DECEMBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 22.61 | 27.79 | 24.09 | 29.76 | 39.80 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | 0.01 | (0.07) | (0.09) | (0.17) | (0.24) |
Net gains (losses)—realized and unrealized | 5.68 | (1.48) | 7.86 | 11.89 | 5.48 |
Subtotal: income (loss) from investment operations | 5.69 | (1.55) | 7.77 | 11.72 | 5.24 |
Minus: | |||||
Distributions to shareholders | |||||
Capital gain distributions | 0.51 | 2.15 | 2.10 | 1.68 | 4.70 |
Subtotal: distributions to shareholders | 0.51 | 2.15 | 2.10 | 1.68 | 4.70 |
Equals: | |||||
Share price (NAV) at end of year | 27.79 | 24.09 | 29.76 | 39.80 | 40.34 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund's expenses and net investment income (loss), as they actually are as well as how they would have been if certain expense reimbursement arrangements had not been in effect. | |||||
Net expenses—actual | 0.65 | 0.93 | 0.92 | 0.91 | 0.89 |
Gross expenses | 0.94(1) | 0.93 | 0.92 | 0.91 | 0.89 |
Net investment income (loss)—actual | 0.04 | (0.25) | (0.32) | (0.54) | (0.56) |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return(%)(2) | 25.29(4) | (6.40) | 32.75 | 39.98 | 12.99 |
Net assets at end of year (in millions of dollars) | 106.4 | 93.2 | 114.4 | 139.4 | 165.7 |
Portfolio turnover rate (%) | 57 | 50 | 47 | 54 | 47 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement. |
(2) | Does not reflect charges and other expenses that apply to the separate account or the related insurance policies. Qualified plans that are direct shareholders of the Fund are not affected by insurance related expenses. |
(3) | Calculated based on the average number of shares outstanding during each fiscal period. |
(4) | Would have been lower if there had been no expense reimbursement. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
■ | a discussion by the Portfolio Manager(s) about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
Mid Cap Growth Portfolio—Class S Shares |
Fund Summary | |
|
2 |
|
8 |
|
8 |
|
12 |
|
12 |
|
12 |
|
14 |
Your Investment | |
|
15 |
|
16 |
|
17 |
|
17 |
|
18 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 0.83 |
Distribution and/or shareholder service (12b-1) fees | 0.25 |
Other expenses | 0.06 |
Total annual operating expenses | 1.14 |
Fee waiver and/or expense reimbursement | 0.04 |
Total annual operating expenses after fee waiver and/or expense reimbursement1 | 1.10 |
1 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class S so that the total annual operating expenses (excluding interest, taxes, transaction costs, brokerage commissions, dividend and interest expenses relating to short sales, acquired fund fees and expenses and extraordinary expenses, if any) (“annual operating expenses”) are limited to 1.10% of average net assets. This undertaking lasts until 12/31/2025 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that Class S will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 1.10% of its average net assets. Any such repayment must be made within three years after the year in which the Manager incurred the expense. |
1 Year | 3 Years | 5 Years | 10 Years | |
Expenses | $112 | $350 | $615 | $1,374 |
Mid Cap Growth Portfolio | 1 Year | 5 Years | 10 Years |
Class S | 12.72 | 19.42 | 15.06 |
Russell Midcap® Growth Index (reflects no deduction for fees, expenses or taxes) | 12.73 | 19.83 | 16.63 |
Russell Midcap® Index (reflects no deduction for fees, expenses or taxes) | 22.58 | 15.10 | 14.91 |
YEAR ENDED DECEMBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 21.12 | 25.77 | 22.16 | 27.14 | 36.06 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(4) | (0.12) | (0.11) | (0.13) | (0.22) | (0.30) |
Net gains (losses)—realized and unrealized | 5.28 | (1.35) | 7.21 | 10.82 | 4.96 |
Subtotal: income (loss) from investment operations | 5.16 | (1.46) | 7.08 | 10.60 | 4.66 |
Minus: | |||||
Distributions to shareholders | |||||
Capital gain distributions | 0.51 | 2.15 | 2.10 | 1.68 | 4.70 |
Subtotal: distributions to shareholders | 0.51 | 2.15 | 2.10 | 1.68 | 4.70 |
Equals: | |||||
Share price (NAV) at end of year | 25.77 | 22.16 | 27.14 | 36.06 | 36.02 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund's expenses and net investment income (loss), as they actually are as well as how they would have been if certain expense reimbursement/repayment arrangements had not been in effect. | |||||
Net expenses—actual | 1.18 | 1.10 | 1.10 | 1.10 | 1.10 |
Gross expenses(1) | 1.19 | 1.18 | 1.17 | 1.16 | 1.14 |
Net investment income (loss)—actual | (0.52) | (0.42) | (0.50) | (0.74) | (0.77) |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return(%)(2)(3) | 24.56 | (6.56) | 32.48 | 39.71 | 12.72 |
Net assets at end of year (in millions of dollars) | 317.7 | 299.4 | 381.1 | 459.2 | 497.6 |
Portfolio turnover rate (%) | 57 | 50 | 47 | 54 | 47 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement. |
(2) | Does not reflect charges and other expenses that apply to the separate account or the related insurance policies. Qualified plans that are direct shareholders of the Fund are not affected by insurance related expenses. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses. |
(4) | Calculated based on the average number of shares outstanding during each fiscal period. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
■ | a discussion by the Portfolio Manager(s) about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
Mid Cap Intrinsic Value Portfolio—Class I Shares |
Fund Summary | |
|
2 |
|
9 |
|
9 |
|
14 |
|
15 |
|
15 |
|
17 |
Your Investment | |
|
18 |
|
19 |
|
20 |
|
20 |
|
21 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 0.85 |
Distribution and/or shareholder service (12b-1) fees | None |
Other expenses | 0.15 |
Total annual operating expenses | 1.00 |
1 Year | 3 Years | 5 Years | 10 Years | |
Expenses | $102 | $318 | $552 | $1,225 |
■ | Complex Companies: These companies typically have multiple lines of business that are in different industries or sectors and/or that have different growth rates and profitability characteristics. |
■ | Cyclical Companies: These companies typically have ebbs and flows in their business depending on demand patterns for their products, the length of product cycles, or other transient factors. |
■ | Companies in a Period of Interrupted Growth: Typically, these are companies in attractive, high growth markets that have suffered what the Portfolio Managers believe is a temporary setback and/or are in transition to a more mature, lower growth business model that focuses more on current earnings than on rapid growth. |
Mid Cap Intrinsic Value Portfolio | 1 Year | 5 Years | 10 Years |
Class I | 32.80 | 8.35 | 11.10 |
Russell Midcap® Value Index (reflects no deduction for fees, expenses or taxes) | 28.34 | 11.22 | 13.44 |
Russell Midcap® Index (reflects no deduction for fees, expenses or taxes) | 22.58 | 15.10 | 14.91 |
YEAR ENDED DECEMBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
PER SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 16.91 | 19.58 | 15.69 | 16.01 | 15.40 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(4) | 0.14 | 0.15 | 0.21 | 0.14 | 0.14 |
Net gains (losses)—realized and unrealized | 2.69 | (3.00) | 2.31 | (0.59) | 4.91 |
Subtotal: income (loss) from investment operations | 2.83 | (2.85) | 2.52 | (0.45) | 5.05 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.16 | 0.13 | 0.13 | 0.16 | 0.12 |
Capital gain distributions | — | 0.91 | 2.07 | — | — |
Subtotal: distributions to shareholders | 0.16 | 1.04 | 2.20 | 0.16 | 0.12 |
Equals: | |||||
Share price (NAV) at end of year | 19.58 | 15.69 | 16.01 | 15.40 | 20.33 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund's expenses and net investment income (loss), as they actually are as well as how they would have been if certain expense reimbursement arrangements had not been in effect. | |||||
Net expenses—actual | 0.97 | 1.00 | 1.01 | 1.03 | 1.00 |
Gross expenses | 0.99(1) | 1.00 | 1.01 | 1.03 | 1.00 |
Net investment income (loss)—actual | 0.79 | 0.76 | 1.22 | 1.12 | 0.74 |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2) | 16.74(3) | (15.28) | 16.74 | (2.62) | 32.80 |
Net assets at end of year (in millions of dollars) | 119.1 | 93.8 | 94.0 | 92.0 | 109.8 |
Portfolio turnover rate (%) | 35 | 34 | 14 | 35 | 40 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement. |
(2) | Does not reflect charges and other expenses that apply to the separate account or the related insurance policies. Qualified plans that are direct shareholders of the Fund are not affected by insurance related expenses. |
(3) | Would have been lower if there had been no expense reimbursement. |
(4) | Calculated based on the average number of shares outstanding during each fiscal period. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
■ | a discussion by the Portfolio Manager(s) about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
Mid Cap Intrinsic Value Portfolio—Class S Shares |
Fund Summary | |
|
2 |
|
9 |
|
9 |
|
14 |
|
15 |
|
15 |
|
17 |
Your Investment | |
|
18 |
|
19 |
|
20 |
|
20 |
|
21 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 0.85 |
Distribution and/or shareholder service (12b-1) fees | 0.25 |
Other expenses | 0.16 |
Total annual operating expenses | 1.26 |
1 Year | 3 Years | 5 Years | 10 Years | |
Expenses | $128 | $400 | $692 | $1,523 |
■ | Complex Companies: These companies typically have multiple lines of business that are in different industries or sectors and/or that have different growth rates and profitability characteristics. |
■ | Cyclical Companies: These companies typically have ebbs and flows in their business depending on demand patterns for their products, the length of product cycles, or other transient factors. |
■ | Companies in a Period of Interrupted Growth: Typically, these are companies in attractive, high growth markets that have suffered what the Portfolio Managers believe is a temporary setback and/or are in transition to a more mature, lower growth business model that focuses more on current earnings than on rapid growth. |
Mid Cap Intrinsic Value Portfolio | 1 Year | 5 Years | 10 Years |
Class S | 32.52 | 8.07 | 10.85 |
Russell Midcap® Value Index (reflects no deduction for fees, expenses or taxes) | 28.34 | 11.22 | 13.44 |
Russell Midcap® Index (reflects no deduction for fees, expenses or taxes) | 22.58 | 15.10 | 14.91 |
YEAR ENDED DECEMBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 19.19 | 22.22 | 17.95 | 18.68 | 18.02 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(4) | 0.10 | 0.11 | 0.19 | 0.13 | 0.10 |
Net gains (losses)—realized and unrealized | 3.03 | (3.41) | 2.66 | (0.68) | 5.76 |
Subtotal: income (loss) from investment operations | 3.13 | (3.30) | 2.85 | (0.55) | 5.86 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.10 | 0.06 | 0.05 | 0.11 | 0.06 |
Capital gain distributions | — | 0.91 | 2.07 | — | — |
Subtotal: distributions to shareholders | 0.10 | 0.97 | 2.12 | 0.11 | 0.06 |
Equals: | |||||
Share price (NAV) at end of year | 22.22 | 17.95 | 18.68 | 18.02 | 23.82 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund's expenses and net investment income (loss), as they actually are as well as how they would have been if certain expense reimbursement/repayment arrangements had not been in effect. | |||||
Net expenses—actual | 1.25 | 1.25 | 1.25 | 1.25 | 1.25 |
Gross expenses(1) | 1.25 | 1.25 | 1.26 | 1.28 | 1.25 |
Net investment income (loss)—actual | 0.49 | 0.49 | 0.98 | 0.89 | 0.48 |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2)(3) | 16.35 | (15.48) | 16.43 | (2.83) | 32.52 |
Net assets at end of year (in millions of dollars) | 59.3 | 44.8 | 43.8 | 39.5 | 43.5 |
Portfolio turnover rate (%) | 35 | 34 | 14 | 35 | 40 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement/repayment. |
(2) | Would have been lower/higher if there had been no expense reimbursement/recoupment. |
(3) | Does not reflect charges and other expenses that apply to the separate account or the related insurance policies. Qualified plans that are direct shareholders of the Fund are not affected by insurance related expenses. |
(4) | Calculated based on the average number of shares outstanding during each fiscal period. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
■ | a discussion by the Portfolio Manager(s) about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
Real Estate Portfolio—Class S Shares |
Fund Summary | |
|
2 |
|
8 |
|
8 |
|
13 |
|
14 |
|
16 |
Your Investment | |
|
17 |
|
18 |
|
19 |
|
19 |
|
20 |
|
22 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 1.15 |
Distribution and/or shareholder service (12b-1) fees | 0.25 |
Other expenses1 | 0.78 |
Total annual operating expenses | 2.18 |
Fee waiver and/or expense reimbursement | 0.43 |
Total annual operating expenses after fee waiver and/or expense reimbursement2 | 1.75 |
1 | Since the Fund had not commenced investment operations as of December 31, 2021, “Other expenses” are based on estimated amounts for the current fiscal year. |
2 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class S so that total annual operating expenses (excluding interest, taxes, transaction costs, brokerage commissions, dividend and interest expenses relating to short sales, acquired fund fees and expenses and extraordinary expenses, if any) (“annual operating expenses”) are limited to 1.75% of average net assets. This undertaking lasts until 12/31/2025 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that Class S will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 1.75% of its average net assets. Any such repayment must be made within three years after the year in which the Manager incurred the expense. |
1 Year | 3 Years | |
Expenses | $178 | $551 |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
Neuberger Berman Real Estate Fund | 1 Year | 5 Years | 10 Years |
Trust Class | 41.68 | 14.26 | 11.79 |
FTSE® Nareit All Equity REITs Index (reflects no deduction for fees, expenses or taxes) | 41.30 | 12.46 | 12.22 |
Index Description: The FTSE® Nareit All Equity REITs Index is a free float-adjusted market capitalization-weighted index that tracks the performance of all tax-qualified equity real estate investment trusts (REITs) that are listed on the New York Stock Exchange or NASDAQ. Equity REITs include all tax-qualified REITs with more than 50 percent of total assets in qualifying real estate assets other than mortgages secured by real property. |
■ | a discussion by the Portfolio Manager(s) about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
Short Duration Bond Portfolio—Class I Shares |
Fund Summary | |
|
2 |
|
12 |
|
12 |
|
22 |
|
23 |
|
23 |
|
25 |
Your Investment | |
|
26 |
|
27 |
|
28 |
|
28 |
|
29 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 0.57 |
Distribution and/or shareholder service (12b-1) fees | None |
Other expenses | 0.23 |
Acquired fund fees and expenses | 0.03 |
Total annual operating expenses | 0.83 |
1 Year | 3 Years | 5 Years | 10 Years | |
Expenses | $85 | $265 | $460 | $1,025 |
Short Duration Bond Portfolio | 1 Year | 5 Years | 10 Years |
Class I | 0.74 | 1.95 | 1.69 |
Bloomberg 1-3 Year U.S. Government/Credit Bond Index (reflects no deduction for fees, expenses or taxes) | -0.47 | 1.85 | 1.39 |
YEAR ENDED DECEMBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 10.52 | 10.46 | 10.40 | 10.57 | 10.68 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(2) | 0.11 | 0.14 | 0.18 | 0.24 | 0.26 |
Net gains (losses)—realized and unrealized | (0.02) | (0.03) | 0.20 | 0.12 | (0.18) |
Subtotal: income (loss) from investment operations | 0.09 | 0.11 | 0.38 | 0.36 | 0.08 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.15 | 0.17 | 0.21 | 0.25 | 0.28 |
Subtotal: distributions to shareholders | 0.15 | 0.17 | 0.21 | 0.25 | 0.28 |
Equals: | |||||
Share price (NAV) at end of year | 10.46 | 10.40 | 10.57 | 10.68 | 10.48 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund's expenses and net investment income (loss), as they actually are as well as how they would have been if certain expense reimbursement arrangements had not been in effect. | |||||
Net expenses—actual | 0.75 | 0.87 | 0.88 | 0.86 | 0.80 |
Gross expenses | 0.85(1) | 0.87 | 0.88 | 0.86 | 0.80 |
Net investment income (loss)—actual | 1.03 | 1.34 | 1.69 | 2.26 | 2.47 |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(3) | 0.89(4) | 1.02 | 3.69 | 3.46 | 0.74 |
Net assets at end of year (in millions of dollars) | 131.6 | 117.6 | 107.0 | 103.1 | 111.5 |
Portfolio turnover rate (%) | 87 | 60 | 91 | 162 | 91 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement. |
(2) | Calculated based on the average number of shares outstanding during each fiscal period. |
(3) | Does not reflect charges and other expenses that apply to the separate account or the related insurance policies. Qualified plans that are direct shareholders of the Fund are not affected by insurance related expenses. |
(4) | Would have been lower if there had been no expense reimbursement. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange or the bond market is closed |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange, the Federal Reserve or the bond market closes early (e.g., on the eve of a major holiday or because of a local emergency, such as a blizzard) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
■ | a discussion by the Portfolio Manager(s) about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
Sustainable Equity Portfolio—Class I Shares |
Fund Summary | |
|
2 |
|
8 |
|
8 |
|
12 |
|
13 |
|
13 |
|
14 |
Your Investment | |
|
15 |
|
16 |
|
17 |
|
17 |
|
18 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 0.83 |
Distribution and/or shareholder service (12b-1) fees | None |
Other expenses | 0.06 |
Total annual operating expenses | 0.89 |
1 Year | 3 Years | 5 Years | 10 Years | |
Expenses | $91 | $285 | $494 | $1,099 |
Sustainable Equity Portfolio | 1 Year | 5 Years | 10 Years |
Class I | 23.48 | 15.72 | 14.36 |
S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 28.71 | 18.47 | 16.55 |
YEAR ENDED DECEMBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 22.57 | 25.61 | 22.70 | 26.89 | 30.69 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(2) | 0.12 | 0.14 | 0.17 | 0.13 | 0.14 |
Net gains (losses)—realized and unrealized | 3.99 | (1.48) | 5.59 | 4.98 | 7.01 |
Subtotal: income (loss) from investment operations | 4.11 | (1.34) | 5.76 | 5.11 | 7.15 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.13 | 0.13 | 0.11 | 0.17 | 0.13 |
Capital gain distributions | 0.94 | 1.44 | 1.46 | 1.14 | 0.68 |
Subtotal: distributions to shareholders | 1.07 | 1.57 | 1.57 | 1.31 | 0.81 |
Equals: | |||||
Share price (NAV) at end of year | 25.61 | 22.70 | 26.89 | 30.69 | 37.03 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund's expenses and net investment income (loss), as they actually are as well as how they would have been if certain expense reimbursement arrangements had not been in effect. | |||||
Net expenses—actual | 0.93(1) | 0.95 | 0.93 | 0.92 | 0.89 |
Gross expenses | 0.94 | 0.95 | 0.93 | 0.92 | 0.89 |
Net investment income (loss)—actual | |||||
OTHER DATA | 0.50 | 0.53 | 0.67 | 0.48 | 0.40 |
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(3) | 18.43(4) | (5.73) | 25.88 | 19.56 | 23.48 |
Net assets at end of year (in millions of dollars) | 379.6 | 339.0 | 491.3 | 544.0 | 639.6 |
Portfolio turnover rate (%) | 18 | 13 | 21 | 22 | 15 |
(1) | Shows what the ratio would have been if there had been no expense reimbursement. |
(2) | Calculated based on the average number of shares outstanding during each fiscal period. |
(3) | Does not reflect charges and other expenses that apply to the separate account or the related insurance policies. Qualified plans that are direct shareholders of the Fund are not affected by insurance related expenses. |
(4) | Would have been lower if there had been no expense reimbursement. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
■ | a discussion by the Portfolio Manager(s) about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
Sustainable Equity Portfolio —Class S Shares |
Fund Summary | |
|
2 |
|
8 |
|
8 |
|
12 |
|
13 |
|
13 |
|
14 |
Your Investment | |
|
15 |
|
16 |
|
17 |
|
17 |
|
18 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 0.83 |
Distribution and/or shareholder service (12b-1) fees | 0.25 |
Other expenses | 0.08 |
Total annual operating expenses | 1.16 |
1 Year | 3 Years | 5 Years | 10 Years | |
Expenses | $118 | $368 | $638 | $1,409 |
Sustainable Equity Portfolio | 1 Year | 5 Years | 10 Years |
Class S | 23.16 | 15.43 | 14.11 |
S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 28.71 | 18.47 | 16.55 |
YEAR ENDED DECEMBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 22.66 | 25.69 | 22.79 | 26.97 | 30.78 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(4) | 0.06 | 0.08 | 0.10 | 0.06 | 0.05 |
Net gains (losses)—realized and unrealized | 3.99 | (1.48) | 5.61 | 5.00 | 7.03 |
Subtotal: income (loss) from investment operations | 4.05 | (1.40) | 5.71 | 5.06 | 7.08 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.08 | 0.06 | 0.07 | 0.11 | 0.06 |
Capital gain distributions | 0.94 | 1.44 | 1.46 | 1.14 | 0.68 |
Subtotal: distributions to shareholders | 1.02 | 1.50 | 1.53 | 1.25 | 0.74 |
Equals: | |||||
Share price (NAV) at end of year | 25.69 | 22.79 | 26.97 | 30.78 | 37.12 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund's expenses and net investment income (loss), as they actually are as well as how they would have been if certain expense reimbursement arrangements had not been in effect. | |||||
Net expenses—actual | 1.17 | 1.17 | 1.17 | 1.17 | 1.16 |
Gross expenses(1) | 1.19 | 1.20 | 1.18 | 1.17 | 1.16 |
Net investment income (loss)—actual | 0.25 | 0.31 | 0.39 | 0.22 | 0.13 |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2)(3) | 18.11 | (5.94) | 25.58 | 19.28 | 23.16 |
Net assets at end of year (in millions of dollars) | 85.7 | 69.6 | 121.5 | 130.0 | 152.8 |
Portfolio turnover rate (%) | 18 | 13 | 21 | 22 | 15 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement/repayment. |
(2) | Does not reflect charges and other expenses that apply to the separate account or the related insurance policies. Qualified plans that are direct shareholders of the Fund are not affected by insurance related expenses. |
(3) | Would have been lower/higher if there had been no expense reimbursement/repayment. |
(4) | Calculated based on the average number of shares outstanding during each fiscal period. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
■ | a discussion by the Portfolio Manager(s) about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
U.S. Equity Index PutWrite Strategy Portfolio—Class I Shares |
Fund Summary | |
|
2 |
|
11 |
|
11 |
|
19 |
|
19 |
|
20 |
|
22 |
Your Investment | |
|
23 |
|
24 |
|
25 |
|
25 |
|
26 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 0.75 |
Distribution and/or shareholder service (12b-1) fees | None |
Other expenses1 | 0.49 |
Acquired fund fees and expenses | 0.01 |
Total annual operating expenses | 1.25 |
Fee waiver and/or expense reimbursement | 0.44 |
Total annual operating expenses after fee waiver and/or expense reimbursement2 | 0.81 |
1 | “Other expenses” are based on estimated amounts for the current fiscal year; actual expenses may vary. |
2 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class I so that the total annual operating expenses (excluding interest, taxes, transaction costs, brokerage commissions, dividend and interest expenses relating to short sales, acquired fund fees and expenses and extraordinary expenses, if any) (“annual operating expenses”) are limited to 0.80% of average net assets. This undertaking lasts until 12/31/2025 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that Class I will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 0.80% of its average net assets. Any such repayment must be made within three years after the year in which the Manager incurred the expense. |
1 Year | 3 Years | 5 Years | 10 Years | |
Expenses | $83 | $259 | $552 | $1,388 |
U.S. Equity Index PutWrite Strategy Portfolio | 1 Year | 5 Years | Since Inception (05/01/2014) |
Class S | 17.94 | 7.91 | 4.29 |
50% Cboe S&P 500 One-Week PutWrite Index/50% Cboe S&P 500 PutWrite Index (reflects no deduction for fees, expenses or taxes)* | 16.87 | 5.48 | 5.19 |
42.5% Cboe S&P 500 One-Week PutWrite Index/42.5% Cboe S&P 500 PutWrite Index/7.5% Cboe Russell 2000 One-Week PutWrite Index/7.5% Cboe Russell 2000 PutWrite Index (reflects no deduction for fees, expenses or taxes) | 15.69 | 4.53 | 4.53 |
S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 28.71 | 18.47 | 15.07 |
* | On February 28, 2022, the Fund began comparing its performance to the 50% Cboe S&P 500 One-Week PutWrite Index/50% Cboe S&P 500 PutWrite Index rather than the 42.5% Cboe S&P 500 One-Week PutWrite Index/42.5% Cboe S&P 500 PutWrite Index/7.5% Cboe Russell 2000 One-Week PutWrite Index/7.5% Cboe Russell 2000 PutWrite Index because the 50% Cboe S&P 500 One-Week PutWrite Index/50% Cboe S&P 500 PutWrite Index has characteristics that are more representative of the Fund’s investment strategy than its previous index. |
YEAR ENDED DECEMBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of period | 9.28 | 9.90 | 8.95 | 10.30 | 10.31 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(4) | (0.02) | 0.04 | 0.09 | 0.04 | (0.06) |
Net gains (losses)—realized and unrealized | 0.64 | (0.70) | 1.28 | 0.77 | 1.89 |
Subtotal: income (loss) from investment operations | 0.62 | (0.66) | 1.37 | 0.81 | 1.83 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | — | 0.02 | 0.09 | 0.03 |
Capital gain distributions | — | 0.29 | — | 0.71 | 0.72 |
Subtotal: distributions to shareholders | — | 0.29 | 0.02 | 0.80 | 0.75 |
Equals: | |||||
Share price (NAV) at end of period | 9.90 | 8.95 | 10.30 | 10.31 | 11.39 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement arrangements had not been in effect. | |||||
Net expenses—actual | 1.72 | 1.05 | 1.05 | 1.05 | 1.05 |
Net expenses (excluding expenses on securities sold short)—actual | 1.54 | — | — | — | — |
Gross expenses(1) | 3.68 | 2.59 | 1.72 | 1.61 | 1.52 |
Gross expenses (excluding expenses on securities sold short) | 3.50 | — | — | — | — |
Net investment income (loss)—actual | (0.24) | 0.46 | 0.97 | 0.36 | (0.53) |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2)(3) | 6.68 | (6.78) | 15.26 | 8.26 | 17.94 |
Net assets at end of year (in millions of dollars) | 12.2 | 12.0 | 34.6 | 36.0 | 41.3 |
Portfolio turnover rate (including securities sold short) (%) | 368 | — | — | — | — |
Portfolio turnover rate (excluding securities sold short) (%) | 342 | 23 | 26 | 48 | 44 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement. |
(2) | Would have been lower if the Manager had not reimbursed certain expenses. |
(3) | Does not reflect charges and other expenses that apply to the separate account or the related insurance policies. Qualified plans that are direct shareholders of the Fund are not affected by insurance related expenses. |
(4) | Calculated based on the average number of shares outstanding during the fiscal period. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange or the bond market is closed |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange, the Federal Reserve or the bond market closes early (e.g., on the eve of a major holiday or because of a local emergency, such as a blizzard) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
■ | a discussion by the Portfolio Manager(s) about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
U.S. Equity Index PutWrite Strategy Portfolio—Class S Shares |
Fund Summary | |
|
2 |
|
10 |
|
10 |
|
18 |
|
18 |
|
19 |
|
21 |
Your Investment | |
|
22 |
|
23 |
|
24 |
|
24 |
|
25 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 0.75 |
Distribution and/or shareholder service (12b-1) fees | 0.25 |
Other expenses | 0.52 |
Acquired fund fees and expenses | 0.01 |
Total annual operating expenses | 1.53 |
Fee waiver and/or expense reimbursement | 0.47 |
Total annual operating expenses after fee waiver and/or expense reimbursement1 | 1.06 |
1 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class S so that the total annual operating expenses (excluding interest, taxes, transaction costs, brokerage commissions, dividend and interest expenses relating to short sales, acquired fund fees and expenses and extraordinary expenses, if any) (“annual operating expenses”) are limited to 1.05% of average net assets. This undertaking lasts until 12/31/2025 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that Class S will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 1.05% of its average net assets. Any such repayment must be made within three years after the year in which the Manager incurred the expense. |
1 Year | 3 Years | 5 Years | 10 Years | |
Expenses | $108 | $337 | $693 | $1,696 |
U.S. Equity Index PutWrite Strategy Portfolio | 1 Year | 5 Years | Since Inception (05/01/2014) |
Class S | 17.94 | 7.91 | 4.29 |
50% Cboe S&P 500 One-Week PutWrite Index/50% Cboe S&P 500 PutWrite Index (reflects no deduction for fees, expenses or taxes)* | 16.87 | 5.48 | 5.19 |
42.5% Cboe S&P 500 One-Week PutWrite Index/42.5% Cboe S&P 500 PutWrite Index/7.5% Cboe Russell 2000 One-Week PutWrite Index/7.5% Cboe Russell 2000 PutWrite Index (reflects no deduction for fees, expenses or taxes) | 15.69 | 4.53 | 4.53 |
S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 28.71 | 18.47 | 15.07 |
* | On February 28, 2022, the Fund began comparing its performance to the 50% Cboe S&P 500 One-Week PutWrite Index/50% Cboe S&P 500 PutWrite Index rather than the 42.5% Cboe S&P 500 One-Week PutWrite Index/42.5% Cboe S&P 500 PutWrite Index/7.5% Cboe Russell 2000 One-Week PutWrite Index/7.5% Cboe Russell 2000 PutWrite Index because the 50% Cboe S&P 500 One-Week PutWrite Index/50% Cboe S&P 500 PutWrite Index has characteristics that are more representative of the Fund’s investment strategy than its previous index. |
YEAR ENDED DECEMBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of period | 9.28 | 9.90 | 8.95 | 10.30 | 10.31 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(4) | (0.02) | 0.04 | 0.09 | 0.04 | (0.06) |
Net gains (losses)—realized and unrealized | 0.64 | (0.70) | 1.28 | 0.77 | 1.89 |
Subtotal: income (loss) from investment operations | 0.62 | (0.66) | 1.37 | 0.81 | 1.83 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | — | 0.02 | 0.09 | 0.03 |
Capital gain distributions | — | 0.29 | — | 0.71 | 0.72 |
Subtotal: distributions to shareholders | — | 0.29 | 0.02 | 0.80 | 0.75 |
Equals: | |||||
Share price (NAV) at end of period | 9.90 | 8.95 | 10.30 | 10.31 | 11.39 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement arrangements had not been in effect. | |||||
Net expenses—actual | 1.72 | 1.05 | 1.05 | 1.05 | 1.05 |
Net expenses (excluding expenses on securities sold short)—actual | 1.54 | — | — | — | — |
Gross expenses(1) | 3.68 | 2.59 | 1.72 | 1.61 | 1.52 |
Gross expenses (excluding expenses on securities sold short) | 3.50 | — | — | — | — |
Net investment income (loss)—actual | (0.24) | 0.46 | 0.97 | 0.36 | (0.53) |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2)(3) | 6.68 | (6.78) | 15.26 | 8.26 | 17.94 |
Net assets at end of year (in millions of dollars) | 12.2 | 12.0 | 34.6 | 36.0 | 41.3 |
Portfolio turnover rate (including securities sold short) (%) | 368 | — | — | — | — |
Portfolio turnover rate (excluding securities sold short) (%) | 342 | 23 | 26 | 48 | 44 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement. |
(2) | Would have been lower if the Manager had not reimbursed certain expenses. |
(3) | Does not reflect charges and other expenses that apply to the separate account or the related insurance policies. Qualified plans that are direct shareholders of the Fund are not affected by insurance related expenses. |
(4) | Calculated based on the average number of shares outstanding during the fiscal period. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange or the bond market is closed |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange, the Federal Reserve or the bond market closes early (e.g., on the eve of a major holiday or because of a local emergency, such as a blizzard) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
■ | a discussion by the Portfolio Manager(s) about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
Fund
|
Class I
|
Class S
|
International Equity Portfolio
|
X
|
X
|
Mid Cap Growth Portfolio
|
X
|
X
|
Mid Cap Intrinsic Value Portfolio
|
X
|
X
|
Real Estate Portfolio
|
X
|
|
Short Duration Bond Portfolio
|
X
|
|
Sustainable Equity Portfolio
|
X
|
X
|
U.S. Equity Index PutWrite Strategy Portfolio
|
X
|
X
|
1290 Avenue of the Americas, New York, NY 10104-0002
800.877.9700
www.nb.com
|
FUND TRANSACTIONS
|
140
|
Portfolio Turnover
|
145
|
Proxy Voting
|
146
|
PORTFOLIO HOLDINGS DISCLOSURE
|
147
|
Portfolio Holdings Disclosure Policy
|
147
|
Public Disclosure
|
147
|
Selective Disclosure Procedures
|
148
|
Portfolio Holdings Approved Recipients
|
149
|
REPORTS TO SHAREHOLDERS
|
150
|
ORGANIZATION, CAPITALIZATION AND OTHER MATTERS
|
150
|
CUSTODIAN AND TRANSFER AGENT
|
151
|
INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
|
152
|
LEGAL COUNSEL
|
152
|
CONTROL PERSONS AND PRINCIPAL HOLDERS OF SECURITIES
|
152
|
REGISTRATION STATEMENT
|
153
|
FINANCIAL STATEMENTS
|
153
|
APPENDIX A - LONG-TERM AND SHORT-TERM DEBT SECURITIES RATING DESCRIPTIONS
|
A-1 |
APPENDIX B - PROXY VOTING POLICY FOR NEUBERGER BERMAN INVESTMENT ADVISERS LLC
|
B-1 |
|
(1)
|
67% of the units of beneficial interest (“shares”) of the Fund present at a meeting at which more than 50% of the outstanding shares of the Fund are present or represented, or
|
|
(2)
|
a majority of the outstanding shares of the Fund.
|
International
Equity Portfolio
|
|
Gross income from securities lending activities
|
$23,581
|
Fees and/or compensation paid by the Fund for securities lending activities and related services
|
|
Fees paid to securities lending agent from a revenue split
|
$2,307
|
Fees paid for any cash collateral management service (including fees deducted from a pooled cash collateral reinvestment vehicle) that are not included in the revenue split
|
$494
|
Administrative fees not included in revenue split
|
$0
|
Indemnification fees not included in revenue split
|
$0
|
Rebate (paid to borrower)
|
$11
|
Other fees relating to the securities lending program that are not included in the revenue split
|
$0
|
Aggregate fees/compensation for securities lending activities
|
$2,813
|
Net income from securities lending activities
|
$20,769
|
Short Duration
Bond Portfolio
|
|
Gross income from securities lending activities
|
$14,725
|
Fees and/or compensation paid by the Fund for securities lending activities and related services
|
|
Fees paid to securities lending agent from a revenue split
|
$1,424
|
Fees paid for any cash collateral management service (including fees deducted from a pooled cash collateral reinvestment vehicle) that are not included in the revenue split
|
$458
|
Administrative fees not included in revenue split
|
$0
|
Indemnification fees not included in revenue split
|
$0
|
Rebate (paid to borrower)
|
$0
|
Other fees relating to the securities lending program that are not included in the revenue split
|
$0
|
Aggregate fees/compensation for securities lending activities
|
$1,882
|
Net income from securities lending activities
|
$12,843
|
•
|
Environmental issues
|
•
|
Employment practices and diversity policies
|
•
|
Community relations
|
•
|
Supply chain issues
|
•
|
Product integrity (safety, quality)
|
•
|
Disclosure and sustainability reporting
|
•
|
tobacco,
|
•
|
alcohol,
|
•
|
weapons,
|
•
|
nuclear power, or
|
•
|
private prisons.
|
•
|
agricultural products companies that sell products to the alcohol industry for use in the production of alcoholic beverages (primarily grain alcohol producers);
|
•
|
companies that sell unprocessed agricultural goods, such as barley or grapes, to producers of alcoholic beverages; or
|
•
|
companies that produce products to be used in production of alcohol such as: enzymes, catalysts and fermentation agents.
|
•
|
provide specialized financial services to casinos; or
|
•
|
sell goods or services that are clearly nongaming-related to casinos or other gaming operations.
|
•
|
have some minor military business;
|
•
|
have some contracts with the DoD for goods and services that are clearly not weapons-related; or
|
•
|
manufacture computers, electric wiring, and semiconductors or that provide telecommunications systems (in the absence of information that these products and services are specifically and exclusively
weapons-related).
|
•
|
Biological and chemical weapons. Weapons outlawed by the Biological and Toxin Weapons Convention of 1972 and the Chemical Weapons Convention of 1993.
|
•
|
Anti-personnel mines. Weapons that signatories agreed to, prohibit the use, stockpiling, production or transfer of, under the 1997 Anti-personnel Landmines Convention. The Convention does not address
the issue of financial support for companies that manufacture such weapons.
|
•
|
Cluster munitions. Weapons that signatories agreed to restrict the manufacture, use and stockpiling of, as well as components of these weapons, under the 2008 Convention on Cluster Munitions. The
implications for financial support of companies that manufacture cluster munitions is left unclear in the Convention. As a result, signatory states and the institutions based on them have taken a range of approaches to the question of
prohibiting or allowing investments in cluster munitions producers: some prohibit all investments, some prohibit only direct investments and some have not yet banned investments.
|
•
|
Depleted uranium weapons. Companies involved in the production of depleted uranium (DU) weapons, ammunition and armor.
|
•
|
that have integrated environmental management systems;
|
•
|
have heightened awareness and are proactively addressing climate change related issues;
|
•
|
have measurably reduced their emissions to the air, land or water and/or are substantially lower than their peers;
|
•
|
continue to make progress in implementing environmental programs to increase efficiency, decrease energy and water consumption and reduce their overall impact on biodiversity;
|
•
|
have innovative processes or products that offer an environmental benefit including but not limited to clean technology, renewables, alternative energy and organic agriculture;
|
•
|
are committed to the public disclosure of environmental policies, goals, and progress toward those goals;
|
•
|
have minimized penalties, liabilities and contingencies and are operationally sustainable; and
|
•
|
participate in voluntary environmental multi-stakeholder initiatives led by government agencies such as the Environmental Protection Agency (EPA) and/or non-governmental organizations (NGOs).
|
• |
are major manufacturers of hydrochloroflurocarbons, bromines, or other ozone-depleting chemicals;
|
• |
are major manufacturers of pesticides or chemical fertilizers;
|
• |
operate in the gold mining industry; or
|
• |
design, market, own, or operate nuclear power plants (see Nuclear Power section).
|
•
|
engineering or construction companies that are involved in the construction of a nuclear power plant or provide maintenance services to such plants in operation; or
|
•
|
electric utility companies that are purchasers and distributors of electricity that may have been generated from nuclear power plants (but are not themselves majority owners/operators of such plants).
|
▪ |
Thermal Coal. The Fund is prohibited from purchasing the securities of issuers with expansion plans for coal extraction. Additionally, 5% of revenue is the
maximum acceptable percentage of revenue derived from thermal coal related activities unless the company has one of either: a Science Based Target (“SBTi”) set or in the process of being set, less than 10% of capital expenditures
(“capex”) is related to thermal coal activities or greater than 50% of capex is dedicated to contributing activities (as defined below).
|
▪ |
Unconventional oil and gas supply. The Fund is prohibited from purchasing the securities of issuers with expansion plans for unconventional oil and gas.
Additionally, 5% of revenue is the maximum acceptable percentage of revenue derived from unconventional oil and gas-related activities, unless the company has one of either: a SBTi set, a SBTi is in the process of being set or greater
than 50% of capex is dedicated to contributing activities.
|
▪ |
Conventional oil and gas supply. 5% of revenue is the maximum acceptable percentage of revenue derived from conventional oil and gas-related activities, unless
the company has one of either: a SBTi set or in the process of being set, less than 15% capex is related to oil and gas activities or greater than 15% of capex is dedicated to contributing activities.
|
▪ |
Electricity generation. The Fund is prohibited from investing in electricity utilities with a carbon intensity greater than 374 gCO2/kWH, and decreasing over
time consistent with a 2‐ degrees scenario. If this data is unavailable or cannot be accurately quantified then the following exclusions apply:
|
•
|
environmental fines or penalties issued by a state or federal agency or court over the most recent three calendar years; and/or
|
•
|
highly publicized community environmental lawsuits or controversies.
|
•
|
preparing for potential regulatory changes,
|
•
|
having demonstrated consistent and sustained implementation of practices that address and remedy prior fines, censures or judgments.
|
•
|
offer benefits such as maternity leave that exceeds the 12 unpaid weeks mandated by the federal government; paid maternity leave; paternity leave; subsidized child and elder care (particularly for
lower-paid staff); flexible spending accounts with dependent care options; flextime or job-sharing arrangements; phaseback for new mothers; adoption assistance; a full time work/family benefits manager; and/or health and other benefits
for same-sex domestic partners of its employees;
|
•
|
have taken extraordinary steps to treat their unionized workforces fairly; and
|
•
|
have exceptional workplace safety records, particularly Occupational Safety and Health Administration Star certification for a substantial number of its facilities and/or a marked decrease in their lost
time accidents and workers compensation insurance rates.
|
•
|
demonstrated a blatant disregard for worker safety; or
|
•
|
historically had poor relations with their unionized workforces, including involvement in unfair labor practices, union busting, and denying employees the right to organize.
|
•
|
have implemented innovative hiring, training, or other programs for women, people of color, and/or the disabled, or otherwise have a superior reputation in the area of diversity;
|
•
|
promote women and people of color into senior line positions;
|
•
|
appoint women and people of color to their boards of directors;
|
•
|
purchase goods and services from women- and minority-owned firms.
|
•
|
that are currently involved in unsettled major class action discrimination lawsuits;
|
•
|
that are currently involved in unsettled major discrimination lawsuits involving the U.S. Department of Justice or the EEOC (Equal Employment Opportunity Commission); or
|
•
|
that have exceptional historical patterns of discriminatory practices.
|
•
|
have open communications within the communities in which they operate;
|
•
|
actively support charitable organizations, particularly multi-year commitments to local community groups; and
|
•
|
offer incentives (such as paid time off) to employees to volunteer their time with charitable organizations; and
|
•
|
earn the ‘right to operate’ and minimize business interruption through active communications with the local community.
|
•
|
have taken steps to refine their disclosure methods so that they are complete, consistent and measurable;
|
•
|
have developed or are in the process of developing a vision and human rights strategy or to formalize an already existing standard and process;
|
•
|
have identified or are in the process of identifying opportunities that will enhance their overall business and/or where they can take a leadership and advocacy role and extend principles to their
suppliers, networks and stakeholders within their sphere of influence; or
|
•
|
strive to build partnerships with NGOs (non-governmental organizations), local communities, labor unions and other businesses in order to learn best practices.
|
•
|
the nature of a company’s products;
|
•
|
whether a company has significant (already accrued or settled lawsuits) or potentially significant (pending lawsuits or settlements) product liabilities;
|
•
|
if a company’s products are innovative and/or address unmet needs, with positive environmental and societal benefits;
|
•
|
whether a company is a leader in quality, ethics and integrity across the supply, production, distribution and post-consumption recycling phases; or
|
•
|
whether a company has high quality control standards in place with regards to animal welfare.
|
•
|
companies that have identified or are in the process of identifying the components of their supply chains; and
|
•
|
companies that engage suppliers to commit to an ESG standard code of conduct.
|
•
|
enhanced transparency and ESG/sustainability reporting, such as the Global Reporting Initiative (GRI); and
|
•
|
participation in voluntary multi-stakeholder initiatives relevant to their business and supply chain.
|
Name, (Year of
Birth),
and
Address (1)
|
Position(s)
and Length
of Time
Served (2)
|
Principal Occupation(s) (3) |
Number
of Funds
in Fund Complex Overseen
by Fund Trustee
|
Other Directorships Held Outside
Fund Complex by Fund Trustee (3)
|
Independent Fund Trustees
|
||||
Michael J. Cosgrove (1949)
|
Trustee since 2015
|
President, Carragh Consulting USA, since 2014; formerly, Executive, General Electric Company, 1970 to 2014, including President, Mutual Funds and Global Investment Programs, GE Asset Management, 2011 to
2014, President and Chief Executive Officer, Mutual Funds and Intermediary Business, GE Asset Management, 2007 to 2011, President, Institutional Sales and Marketing, GE Asset Management, 1998 to 2007, and Chief Financial Officer, GE Asset
Management, and Deputy Treasurer, GE Company, 1988 to 1993.
|
50
|
Director, America Press, Inc. (not-for-profit Jesuit publisher), since 2015; formerly, Director, Fordham University, 2001 to 2018; formerly, Director, The Gabelli Go Anywhere Trust, June 2015 to June 2016;
formerly, Director, Skin Cancer Foundation (not-for-profit), 2006 to 2015; formerly, Director, GE Investments Funds, Inc., 1997 to 2014; formerly, Trustee, GE Institutional Funds, 1997 to 2014; formerly, Director, GE Asset Management,
1988 to 2014; formerly, Director, Elfun Trusts, 1988 to 2014; formerly, Trustee, GE Pension & Benefit Plans, 1988 to 2014; formerly, Member of Board of Governors, Investment Company Institute.
|
Marc Gary (1952)
|
Trustee since 2015
|
Executive Vice Chancellor and Chief Operating Officer, Jewish Theological Seminary, since 2012; formerly, Executive Vice President and General Counsel, Fidelity Investments, 2007 to 2012; formerly,
Executive Vice President and General Counsel, BellSouth Corporation, 2004 to 2007; formerly, Vice President and Associate General Counsel, BellSouth Corporation, 2000 to 2004; formerly, Associate, Partner, and National Litigation Practice
Co-Chair, Mayer, Brown LLP, 1981 to 2000; formerly, Associate Independent Counsel, Office of Independent Counsel, 1990 to 1992.
|
50
|
Director, UJA Federation of Greater New York, since 2019; Trustee, Jewish Theological Seminary, since 2015; Director, Legility, Inc. (privately held for-profit company), since 2012; Director, Lawyers
Committee for Civil Rights Under Law (not-for-profit), since 2005; formerly, Director, Equal Justice Works (not-for-profit), 2005 to 2014; formerly, Director, Corporate Counsel Institute, Georgetown University Law Center, 2007 to 2012;
formerly, Director, Greater Boston Legal Services (not-for-profit), 2007 to 2012.
|
Martha C. Goss (1949)
|
Trustee since 2007
|
President, Woodhill Enterprises Inc./Chase Hollow Associates LLC (personal investment vehicle), since 2006; formerly, Consultant, Resources Global Professionals (temporary staffing), 2002 to 2006; formerly,
Chief Financial Officer, Booz-Allen & Hamilton, Inc., 1995 to 1999; formerly, Enterprise Risk Officer, Prudential Insurance, 1994 to1995; formerly, President, Prudential Asset Management Company, 1992 to 1994; formerly, President,
Prudential Power Funding (investments in electric and gas utilities and alternative energy projects), 1989 to 1992; formerly, Treasurer, Prudential Insurance Company, 1983 to 1989.
|
50
|
Director, American Water (water utility), since 2003; Director, Allianz Life of New York (insurance), since 2005; Director, Berger Group Holdings, Inc. (engineering consulting firm), since 2013; Director,
Financial Women’s Association of New York (not-for-profit association), since 2003; Trustee Emerita, Brown University, since 1998; Director, Museum of American Finance (not-for-profit), since 2013; formerly, Non-Executive Chair and
Director, Channel Reinsurance (financial guaranty reinsurance), 2006 to 2010; formerly, Director, Ocwen Financial Corporation (mortgage servicing), 2005 to 2010; formerly, Director, Claire’s Stores, Inc. (retailer), 2005 to 2007;
formerly, Director, Parsons Brinckerhoff Inc. (engineering consulting firm), 2007 to 2010; formerly, Director, Bank Leumi (commercial bank), 2005 to 2007; formerly, Advisory Board Member, Attensity (software developer), 2005 to 2007.
|
Michael M. Knetter (1960)
|
Trustee since 2007
|
President and Chief Executive Officer, University of Wisconsin Foundation, since 2010; formerly, Dean, School of Business, University of Wisconsin - Madison; formerly, Professor of International Economics
and Associate Dean, Amos Tuck School of Business - Dartmouth College, 1998 to 2002.
|
50
|
Director, 1 William Street Credit Income Fund, since 2018; Board Member, American Family Insurance (a mutual company, not publicly traded), since March 2009; formerly, Trustee, Northwestern Mutual Series
Fund, Inc., 2007 to 2011; formerly, Director, Wausau Paper, 2005 to 2011; formerly, Director, Great Wolf Resorts, 2004 to 2009.
|
Deborah C. McLean (1954)
|
Trustee since 2015
|
Member, Circle Financial Group (private wealth management membership practice), since 2011; Managing Director, Golden Seeds LLC (an angel investing group), since 2009; Adjunct Professor, Columbia University
School of International and Public Affairs, since 2008; formerly, Visiting Assistant Professor, Fairfield University, Dolan School of Business, Fall 2007; formerly, Adjunct Associate Professor of Finance, Richmond, The American
International University in London, 1999 to 2007.
|
50
|
Board member, Norwalk Community College Foundation, since 2014; Dean’s Advisory Council, Radcliffe Institute for Advanced Study, since 2014; formerly, Director and Treasurer, At Home in Darien
(not-for-profit), 2012 to 2014; formerly, Director, National Executive Service Corps (not-for-profit), 2012 to 2013; formerly, Trustee, Richmond, The American International University in London, 1999 to 2013.
|
George W. Morriss (1947)
|
Trustee since 2007
|
Adjunct Professor, Columbia University School of International and Public Affairs, since 2012; formerly, Executive Vice President and Chief Financial Officer, People’s United Bank, Connecticut (a financial
services company), 1991 to 2001.
|
50
|
Director, 1 William Street Credit Income Fund, since 2018; Director and Chair, Thrivent Church Loan and Income Fund, since 2018; formerly, Trustee, Steben Alternative Investment Funds, Steben Select
Multi-Strategy Fund, and Steben Select Multi-Strategy Master Fund, 2013 to 2017; formerly, Treasurer, National Association
of Corporate Directors, Connecticut Chapter, 2011 to 2015; formerly, Manager, Larch Lane Multi-Strategy Fund complex (which consisted of three funds), 2006 to 2011; formerly, Member, NASDAQ Issuers’ Affairs
Committee, 1995 to 2003.
|
Tom D. Seip (1950)
|
Trustee since 2000; Chairman of the Board since 2008; formerly Lead Independent Trustee from 2006 to 2008
|
Formerly, Managing Member, Ridgefield Farm LLC (a private investment vehicle), 2004 to 2016; formerly, President and CEO, Westaff, Inc. (temporary staffing), May 2001 to January 2002; formerly, Senior
Executive, The Charles Schwab Corporation, 1983 to 1998, including Chief Executive Officer, Charles Schwab Investment Management, Inc.; Trustee, Schwab Family of Funds and Schwab Investments, 1997 to 1998; and Executive Vice
President-Retail Brokerage, Charles Schwab & Co., Inc., 1994 to 1997.
|
50
|
Formerly, Director, H&R Block, Inc. (tax services company), 2001 to 2018; formerly, Director, Talbot Hospice Inc., 2013 to 2016; formerly, Chairman, Governance and Nominating Committee, H&R Block,
Inc., 2011 to 2015; formerly, Chairman, Compensation Committee, H&R Block, Inc., 2006 to 2010; formerly, Director, Forward Management, Inc. (asset management company), 1999 to 2006.
|
James G. Stavridis (1955)
|
Trustee since 2015
|
Operating Executive, The Carlyle Group, since 2018; Commentator, NBC News, since 2015; formerly, Dean, Fletcher School of Law and Diplomacy, Tufts University, 2013 to 2018; formerly, Admiral, United States
Navy, 1976 to 2013, including Supreme Allied Commander, NATO and Commander, European Command, 2009 to 2013, and Commander, United States Southern Command, 2006 to 2009.
|
50
|
Director, American Water (water utility), since 2018; Director, NFP Corp. (insurance broker and consultant), since 2017; Director, U.S. Naval Institute, since 2014; Director, Onassis Foundation, since 2014;
Director, BMC Software Federal, LLC, since 2014; Director, Vertical Knowledge, LLC, since 2013; formerly, Director, Navy Federal Credit Union, 2000-2002.
|
Fund Trustees who are “Interested Persons”
|
||||
Joseph V. Amato*
(1962)
|
Chief Executive Officer and President since 2018 and Trustee since 2009
|
President and Director, Neuberger Berman Group LLC, since 2009; President and Chief Executive Officer, Neuberger Berman BD LLC and Neuberger Berman Holdings LLC (including its predecessor, Neuberger
Berman Inc.), since 2007; Chief Investment Officer (Equities) and President (Equities), NBIA (formerly, Neuberger Berman Fixed Income LLC and including predecessor entities), since 2007, and Board Member of NBIA since 2006; formerly,
Global Head of Asset Management of Lehman Brothers Holdings Inc.’s (“LBHI”) Investment Management Division, 2006 to 2009; formerly, member of LBHI’s Investment Management Division’s Executive Management Committee, 2006 to 2009;
formerly, Managing Director, Lehman Brothers Inc. (“LBI”), 2006 to 2008; formerly, Chief Recruiting and Development Officer, LBI, 2005 to 2006; formerly, Global Head of LBI’s Equity Sales and a Member of its Equities Division Executive
Committee, 2003 to 2005; President and Chief Executive Officer, twelve registered investment companies for which NBIA acts as investment manager and/or administrator.
|
50
|
Member of Board of Advisors, McDonough School of Business, Georgetown University, since 2001; Member of New York City Board of Advisors, Teach for America, since 2005; Trustee, Montclair Kimberley Academy
(private school), since 2007; Member of Board of Regents, Georgetown University, since 2013.
|
(1)
|
The business address of each listed person is 1290 Avenue of the Americas, New York, New York 10104.
|
(2)
|
Pursuant to the Trust’s Amended and Restated Trust Instrument (“Trust Instrument”), subject to any limitations on the term of service imposed by the By-Laws or any retirement policy adopted by the Fund
Trustees, each Fund Trustee shall hold office for life or until his or her successor is elected or the Trust terminates; except that (a) any Fund Trustee may resign by delivering a written resignation; (b) any Fund Trustee may be removed
with or without cause at any time by a written instrument signed by at least two‑thirds of the other Fund Trustees; (c) any Fund Trustee who requests to be retired, or who has become unable to serve, may be retired by a written instrument
signed by a majority of the other Fund Trustees; and (d) any Fund Trustee may be removed at any shareholder meeting by a vote of at least two‑thirds of the outstanding shares.
|
(3)
|
Except as otherwise indicated, each individual has held the positions shown during at least the last five years.
|
*
|
Indicates a Fund Trustee who is an “interested person” within the meaning of the 1940 Act. Mr. Amato is an interested person of the Trust by virtue of the fact that he is an officer of NBIA and/or its
affiliates.
|
Name, (Year of Birth), and
Address (1)
|
Position(s) and Length of
Time Served (2) |
Principal Occupation(s) (3)
|
Claudia A. Brandon (1956)
|
Executive Vice President since 2008 and Secretary since 1985
|
Senior Vice President, Neuberger Berman, since 2007 and Employee since 1999; Senior Vice President, NBIA, since 2008 and Assistant Secretary since 2004; formerly, Vice President, Neuberger Berman, 2002
to 2006; formerly, Vice President – Mutual Fund Board Relations, NBIA, 2000 to 2008; formerly, Vice President, NBIA, 1986 to 1999 and Employee, 1984 to 1999; Executive Vice President and Secretary, thirty-three registered investment
companies for which NBIA acts as investment manager and/or administrator.
|
Name, (Year of Birth), and
Address (1)
|
Position(s) and Length of
Time Served (2) |
Principal Occupation(s) (3)
|
Agnes Diaz (1971)
|
Vice President since 2013
|
Senior Vice President, Neuberger Berman, since 2012; Senior Vice President, NBIA, since 2012 and Employee since 1996; formerly, Vice President, Neuberger Berman, 2007 to 2012; Vice President, twelve
registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Anthony DiBernardo (1979)
|
Assistant Treasurer since 2011
|
Senior Vice President, Neuberger Berman, since 2014; Senior Vice President, NBIA, since 2014, and Employee since 2003; formerly, Vice President, Neuberger Berman, 2009 to 2014; Assistant Treasurer,
twelve registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Savonne L. Ferguson (1973)
|
Chief Compliance Officer since 2018
|
Senior Vice President, Chief Compliance Officer (Mutual Funds) and Associate General Counsel, NBIA, since November 2018; formerly, Vice President T. Rowe Price Group, Inc. (2018), Vice President and
Senior Legal Counsel, T. Rowe Price Associates, Inc. (2014-2018), Vice President and Director of Regulatory Fund Administration, PNC Capital Advisors, LLC (2009-2014), Secretary, PNC Funds and PNC Advantage Funds (2010-2014); Chief
Compliance Officer, thirty-three registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Name, (Year of Birth), and
Address (1)
|
Position(s) and Length of
Time Served (2) |
Principal Occupation(s) (3)
|
Corey A. Issing (1978)
|
Chief Legal Officer since 2016 (only for purposes of sections 307 and 406 of the Sarbanes-Oxley Act of 2002)
|
General Counsel – Mutual Funds since 2016 and Managing Director, NBIA, since 2017; formerly, Associate General Counsel (2015 to 2016), Counsel (2007 to 2015), Senior Vice President (2013 – 2016), Vice
President (2009 – 2013); Chief Legal Officer (only for purposes of sections 307 and 406 of the Sarbanes-Oxley Act of 2002), thirty-three registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Sheila R. James (1965)
|
Assistant Secretary since 2002
|
Vice President, Neuberger Berman, since 2008 and Employee since 1999; Vice President, NBIA, since 2008; formerly, Assistant Vice President, Neuberger Berman, 2007; Employee, NBIA, 1991 to 1999; Assistant
Secretary, thirty-three registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Brian Kerrane (1969)
|
Chief Operating Officer since 2015 and Vice President since 2008
|
Managing Director, Neuberger Berman, since 2014; Chief Operating Officer – Mutual Funds and Managing Director, NBIA, since 2015; formerly, Senior Vice President, Neuberger Berman, 2006 to 2014; Vice
President, NBIA, 2008 to 2015 and Employee since 1991; Chief Operating Officer, twelve registered investment companies for which NBIA acts as investment manager and/or administrator; Vice President, thirty-three registered investment
companies for which NBIA acts as investment manager and/or administrator.
|
Name, (Year of Birth), and
Address (1)
|
Position(s) and Length of
Time Served (2) |
Principal Occupation(s) (3)
|
Anthony Maltese (1959)
|
Vice President since 2015
|
Senior Vice President, Neuberger Berman, since 2014 and Employee since 2000; Senior Vice President, NBIA, since 2014; Vice President, twelve registered investment companies for which NBIA acts as
investment manager and/or administrator.
|
Josephine Marone (1963)
|
Assistant Secretary since 2017
|
Senior Paralegal, Neuberger Berman, since 2007 and Employee since 2007; Assistant Secretary, thirty-three registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Owen F. McEntee, Jr. (1961)
|
Vice President since 2008
|
Vice President, Neuberger Berman, since 2006; Vice President, NBIA, since 2006 and Employee since 1992; Vice President, twelve registered investment companies for which NBIA acts as investment manager
and/or administrator.
|
John M. McGovern (1970)
|
Treasurer and Principal Financial and Accounting Officer since 2005
|
Senior Vice President, Neuberger Berman, since 2007; Senior Vice President, NBIA, since 2007 and Employee since 1993; formerly, Vice President, Neuberger Berman, 2004 to 2006; formerly, Assistant
Treasurer, 2002 to 2005; Treasurer and Principal Financial and Accounting Officer, twelve registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Frank Rosato (1971)
|
Assistant Treasurer since 2005
|
Vice President, Neuberger Berman, since 2006; Vice President, NBIA, since 2006 and Employee since 1995; Assistant Treasurer, twelve registered investment companies for which NBIA acts as investment
manager and/or administrator.
|
Name, (Year of Birth), and
Address (1)
|
Position(s) and Length of
Time Served (2) |
Principal Occupation(s) (3)
|
Niketh Velamoor (1979)
|
Anti-Money Laundering Compliance Officer since 2018
|
Senior Vice President and Associate General Counsel, Neuberger Berman, since July 2018; Assistant United States Attorney, Southern District of New York, 2009 to 2018; Anti-Money Laundering Compliance
Officer, five registered investment companies for which NBIA acts as investment manager and/or administrator.
|
(1)
|
The business address of each listed person is 1290 Avenue of the Americas, New York, New York 10104.
|
(2)
|
Pursuant to the By‑Laws of the Trust, each officer elected by the Fund Trustees shall hold office until his or her successor shall have been elected and qualified or until his or her earlier death, inability to serve, or resignation.
Officers serve at the pleasure of the Fund Trustees and may be removed at any time with or without cause.
|
(3)
|
Except as otherwise indicated, each individual has held the positions shown during at least the last five years.
|
Name and Position with the Trust
|
Aggregate
Compensation
from the Trust |
Total Compensation from Investment
Companies in the Neuberger Berman
Fund Complex Paid to Fund Trustees
|
Independent Fund Trustees
|
||
Michael J. Cosgrove
Trustee |
$30,805
|
$240,000
|
Marc Gary
Trustee |
$30,163
|
$235,000
|
Martha C. Goss
Trustee |
$30,163
|
$235,000
|
Michael M. Knetter
Trustee |
$30,163
|
$235,000
|
Deborah C. McLean
Trustee |
$30,805
|
$240,000
|
George W. Morriss
Trustee |
$30,805
|
$240,000
|
Tom D. Seip
Chairman of the Board and
Trustee
|
$34,055
|
$270,000
|
James G. Stavridis
Trustee |
$28,237
|
$220,000
|
Candace L. Straight
Trustee1 |
$12,280
|
$95,000
|
Peter P. Trapp
Trustee2 |
$28,237
|
$220,000
|
Fund Trustees who are “Interested Persons”
|
||
Joseph V. Amato
President, Chief Executive Officer and Trustee |
$0
|
$0
|
Fund |
Management and Administration Fees
Accrued for Fiscal Years Ended December 31 |
||
2021
|
2020
|
2019
|
|
International Equity Portfolio
|
$918,526
|
$864,770
|
$880,707
|
Mid Cap Growth Portfolio
|
$5,356,196
|
$4,216,535
|
$3,947,728
|
Mid Cap Intrinsic Value Portfolio
|
$1,262,184
|
$962,288
|
$1,239,579
|
Real Estate Portfolio
|
N/A^
|
N/A^
|
N/A^
|
Short Duration Bond Portfolio
|
$632,957
|
$596,594
|
$726,796
|
Sustainable Equity Portfolio
|
$6,098,336
|
$4,808,961
|
$4,474,912
|
U.S. Equity Index PutWrite Strategy Portfolio
|
$292,871
|
$245,391
|
$214,845
|
Fund
|
Class
|
Limitation Period
|
Expense Limitation
|
International Equity Portfolio
|
I
|
12/31/2025
|
1.00%^
|
S
|
12/31/2025
|
1.50%^
|
|
Mid Cap Growth Portfolio
|
I
|
12/31/2025
|
1.00%^
|
S
|
12/31/2025
|
1.10%^
|
|
Mid Cap Intrinsic Value Portfolio
|
I
|
12/31/2025
|
1.50%^
|
S
|
12/31/2025
|
1.25%^
|
|
Real Estate Portfolio
|
S
|
12/31/2025
|
1.75%^
|
Short Duration Bond Portfolio
|
I
|
12/31/2025
|
0.95%^!
|
Sustainable Equity Portfolio
|
I
|
12/31/2025
|
1.30%^
|
S
|
12/31/2025
|
1.17%^
|
|
U.S. Equity Index PutWrite Strategy Portfolio
|
I
|
12/31/2025
|
0.80%^
|
S
|
12/31/2025
|
1.05%^
|
Expenses Reimbursed for Fiscal Periods
Ended December 31,
|
||||
Fund
|
Class
|
2021
|
2020
|
2019
|
International Equity Portfolio
|
Class I
|
$272,896
|
$269,970
|
$281,611
|
Class S
|
$41,309
|
$28,846
|
$34,567
|
|
Mid Cap Growth Portfolio
|
Class I
|
$0
|
$0
|
$0
|
Class S
|
$167,018
|
$214,503
|
$240,462
|
|
Mid Cap Intrinsic Value Portfolio
|
Class I
|
$0
|
$0
|
$0
|
Class S
|
$0
|
$9,794
|
$202
|
|
Real Estate Portfolio
|
Class S
|
N/A*
|
N/A*
|
N/A*
|
Short Duration Bond Portfolio
|
Class I
|
$0
|
$0
|
$0
|
Expenses Reimbursed for Fiscal Periods
Ended December 31,
|
||||
Fund
|
Class
|
2021
|
2020
|
2019
|
Sustainable Equity Portfolio
|
Class I
|
$0
|
$0
|
$0
|
Class S
|
$0
|
$0
|
$0
|
|
U.S. Equity Index PutWrite Strategy Portfolio
|
Class I
|
N/A*
|
N/A*
|
N/A*
|
Class S
|
$184,142
|
$183,237
|
$192,742
|
Expenses Repaid for Fiscal Periods
Ended December 31,
|
||||
Fund
|
Class
|
2021
|
2020
|
2019
|
Mid Cap Intrinsic Value Portfolio
|
Class S
|
$3,510
|
$0
|
$0
|
Sustainable Equity Portfolio
|
Class S
|
$22,437
|
$9,196
|
$0
|
Portfolio Manager
|
Fund(s) Managed
|
Jennifer Blachford
|
Mid Cap Growth Portfolio
|
David M. Brown
|
Short Duration Bond Portfolio
|
Chad Bruso
|
Mid Cap Growth Portfolio
|
Elias Cohen
|
International Equity Portfolio
|
Derek Devens
|
U.S. Equity Index PutWrite Strategy Portfolio
|
Rory Ewing
|
U.S. Equity Index PutWrite Strategy Portfolio
|
Michael Foster
|
Short Duration Bond Portfolio
|
Rand W. Gesing
|
Mid Cap Intrinsic Value Portfolio
|
Michael C. Greene
|
Mid Cap Intrinsic Value Portfolio
|
Daniel P. Hanson
|
Sustainable Equity Portfolio
|
Thomas Hogan
|
International Equity Portfolio
|
Brian Jones
|
Real Estate Portfolio
|
James F. McAree
|
Mid Cap Intrinsic Value Portfolio
|
Portfolio Manager
|
Fund(s) Managed
|
Matthew McGinnis
|
Short Duration Bond Portfolio
|
Woolf Norman Milner
|
Short Duration Bond Portfolio
|
Trevor Moreno
|
Mid Cap Growth Portfolio
|
Benjamin H. Nahum
|
Mid Cap Intrinsic Value Portfolio
|
Steve Shigekawa
|
Real Estate Portfolio
|
Amit Solomon
|
Mid Cap Intrinsic Value Portfolio
|
Kenneth J. Turek
|
Mid Cap Growth Portfolio
|
Eric Zhou
|
U.S. Equity Index PutWrite Strategy Portfolio
|
Type of Account
|
Number of Accounts Managed
|
Total Assets Managed
($ millions)
|
Number of Accounts Managed for which Advisory Fee is Performance-Based
|
Assets Managed for which Advisory Fee is Performance-Based
($ millions)
|
Jennifer Blachford***
|
||||
Registered Investment Companies*
|
1
|
413
|
-
|
-
|
Other Pooled Investment Vehicles
|
-
|
-
|
-
|
-
|
Other Accounts**
|
-
|
-
|
-
|
-
|
David M. Brown***
|
||||
Registered Investment Companies*
|
2
|
1046
|
-
|
-
|
Other Pooled Investment Vehicles
|
86
|
33,865
|
2
|
2,221
|
Other Accounts**
|
270
|
38,155
|
2
|
152
|
Chad Bruso***
|
||||
Registered Investment Companies*
|
1
|
413
|
-
|
-
|
Other Pooled Investment Vehicles
|
-
|
-
|
-
|
-
|
Other Accounts**
|
-
|
-
|
-
|
-
|
Elias Cohen***
|
||||
Registered Investment Companies*
|
4
|
2358
|
-
|
-
|
Other Pooled Investment Vehicles
|
2
|
356
|
-
|
-
|
Other Accounts**
|
843
|
3,779
|
1
|
697
|
Type of Account
|
Number of Accounts Managed
|
Total Assets Managed
($ millions)
|
Number of Accounts Managed for which Advisory Fee is Performance-Based
|
Assets Managed for which Advisory Fee is Performance-Based
($ millions)
|
Type of Account
|
Number of Accounts Managed
|
Total Assets Managed
($ millions)
|
Number of Accounts Managed for which Advisory Fee is Performance-Based
|
Assets Managed for which Advisory Fee is Performance-Based
($ millions)
|
Other Pooled Investment Vehicles
|
2
|
356
|
-
|
-
|
Other Accounts**
|
15
|
3,069
|
1
|
697
|
Brian Jones***
|
||||
Registered Investment Companies*
|
3
|
1,680
|
-
|
-
|
Other Pooled Investment Vehicles
|
16
|
1,776
|
-
|
-
|
Other Accounts**
|
22
|
140
|
-
|
-
|
James F. McAree***
|
||||
Registered Investment Companies*
|
2
|
221
|
-
|
-
|
Other Pooled Investment Vehicles
|
1
|
154
|
-
|
-
|
Other Accounts**
|
-
|
-
|
-
|
-
|
Matthew McGinnis***
|
||||
Registered Investment Companies*
|
2
|
277
|
-
|
-
|
Other Pooled Investment Vehicles
|
1
|
179
|
-
|
-
|
Other Accounts**
|
167
|
8,702
|
-
|
-
|
Woolf Norman Milner***
|
||||
Registered Investment Companies*
|
-
|
-
|
-
|
-
|
Other Pooled Investment Vehicles
|
9
|
5,819
|
1
|
2,080
|
Other Accounts**
|
10
|
3,317
|
-
|
-
|
Trevor Moreno***
|
||||
Registered Investment Companies*
|
1
|
413
|
-
|
-
|
Other Pooled Investment Vehicles
|
-
|
-
|
-
|
-
|
Other Accounts**
|
-
|
-
|
-
|
-
|
Benjamin H. Nahum***
|
||||
Registered Investment Companies*
|
5
|
1,755
|
-
|
-
|
Other Pooled Investment Vehicles
|
1
|
154
|
-
|
-
|
Other Accounts**
|
1,393
|
2,345
|
2
|
349
|
Type of Account
|
Number of Accounts Managed
|
Total Assets Managed
($ millions)
|
Number of Accounts Managed for which Advisory Fee is Performance-Based
|
Assets Managed for which Advisory Fee is Performance-Based
($ millions)
|
Portfolio Manager
|
Fund Managed
|
Dollar Range of Equity
Securities Owned in the Fund
|
Jennifer Blachford
|
Mid Cap Growth Portfolio
|
A
|
David M. Brown
|
Short Duration Bond Portfolio
|
A
|
Chad Bruso
|
Mid Cap Growth Portfolio
|
A
|
Elias Cohen
|
International Equity Portfolio
|
A
|
Derek Devens
|
U.S. Equity Index PutWrite Strategy Portfolio
|
A
|
Rory Ewing
|
U.S. Equity Index PutWrite Strategy Portfolio
|
A
|
Michael Foster
|
Short Duration Bond Portfolio
|
A
|
Rand W. Gesing
|
Mid Cap Intrinsic Value Portfolio
|
A
|
Michael C. Greene
|
Mid Cap Intrinsic Value Portfolio
|
A
|
Daniel P. Hanson
|
Sustainable Equity Portfolio
|
A
|
Portfolio Manager
|
Fund Managed
|
Dollar Range of Equity
Securities Owned in the Fund
|
Thomas Hogan
|
International Equity Portfolio
|
A
|
Brian Jones
|
Real Estate Portfolio
|
A
|
James F. McAree
|
Mid Cap Intrinsic Value Portfolio
|
A
|
Matthew McGinnis
|
Short Duration Bond Portfolio
|
A
|
Trevor Moreno
|
Mid Cap Growth Portfolio
|
A
|
Woolf Norman Milner
|
Short Duration Bond Portfolio
|
A
|
Benjamin H. Nahum
|
Mid Cap Intrinsic Value Portfolio
|
A
|
Steve Shigekawa
|
Real Estate Portfolio
|
A
|
Amit Solomon
|
Mid Cap Intrinsic Value Portfolio
|
A
|
Kenneth J. Turek
|
Mid Cap Growth Portfolio
|
A
|
Eric Zhou
|
U.S. Equity Index PutWrite Strategy Portfolio
|
A
|
Fund and Class
|
2021
|
2020
|
2019
|
International Equity Portfolio - Class S
|
$42,781
|
$36,711
|
$40,034
|
Mid Cap Growth Portfolio - Class S
|
$1,232,968
|
$968,433
|
$903,048
|
Mid Cap Intrinsic Value Portfolio - Class S
|
$107,676
|
$92,130
|
$112,990
|
Sustainable Equity Portfolio - Class S
|
$357,716
|
$280,747
|
$257,551
|
U.S. Equity Index PutWrite Strategy Portfolio -Class S
|
$97,623
|
$81,797
|
$71,614
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held
|
International Equity Portfolio – Class I
|
PRUDENTIAL FINANCIAL
C/O PRUBENEFIT FUNDING - LAUREATE ATTN TERESITA BUSINELLI VP OPS 80 LIVINGSTON AVE BUILDING ROS 3 ROSELAND NJ 07068-1798 |
99.96%
|
International Equity Portfolio – Class S
|
RIVERSOURCE LIFE INSURANCE COMPANY
222 AXP FINANCIAL CENTER MINNEAPOLIS MN 55474-0001 |
63.61%
|
AXA EQUITABLE LIFE INSURANCE CO
1290 AVENUE OF THE AMERICAS 16TH FL NEW YORK NY 10104-1472 |
30.28%
|
|
Mid Cap Growth Portfolio – Class I
|
LINCOLN NATIONAL LIFE INS CO
WELLS FARGO B SHARE EGMDB ACCT W ATTN MARGARET WALLACE 6H-02 1300 SOUTH CLINTON ST FORT WAYNE IN 46802-3506 |
35.44%
|
NEW YORK LIFE INSURANCE AND ANNUITY
CORPORATION (NYLIAC) ATTN ASHESH UPADHYAY PO BOX 468 JERSEY CITY NJ 07303-0468 |
16.86%
|
|
PRUDENTIAL FINANCIAL
C/O PRUBENEFIT FUNDING - LAUREATE ATTN TERESITA BUSINELLI VP OPS 80 LIVINGSTON AVE BUILDING ROS 3 ROSELAND NJ 07068-1798 |
9.73%
|
|
AMERICAN GENERAL LIFE INSURANCE CO
AIG INCOME ADVANTAGE 2727 ALLEN PKWY STE A HOUSTON TX 77019-2116 |
5.73%
|
|
Mid Cap Growth Portfolio – Class S
|
NEW YORK LIFE INSURANCE AND ANNUITY
CORP (NYLIAC) ATTN ASHESH UPADHYAY PO BOX 468 JERSEY CITY NJ 07303-0468 |
95.44%
|
Mid Cap Intrinsic Value Portfolio – Class I
|
TIAA-CREF LIFE SEPARATE AC VA-1
OF TIAA-CREF LIFE INS CO 730 3RD AVE # 14/41 NEW YORK NY 10017-3206 |
45.54%
|
LINCOLN NATIONAL LIFE INS CO WELLS
FARGO B SHARE EGMDB ACCT W ATTN MARGARET WALLACE 6H-02 1300 SOUTH CLINTON ST FORT WAYNE IN 46802-3506 |
26.69%
|
JEFFERSON NATL LIFE INSURANCE
ATTN CARLA HIGGS - C1B SEPERATE ACCOUNTS 10350 ORMSBY PARK PLACE SUITE 600 LOUISVILLE KY 40223-6175 |
7.23%
|
|
GREAT WEST LIFE & ANNUITY COLI VUL
7 SERIES ACCOUNT 8515 E ORCHARD RD 2T2 GREENWOOD VILLAGE CO 80111-5002 |
7.04%
|
|
Mid Cap Intrinsic Value Portfolio – Class S
|
OHIO NATIONAL LIFE INSURANCE
COMPANY FOR THE BENEFIT OF ITS SEPARATE ACCOUNTS 1 FINANCIAL WAY CINCINNATI OH 45242-5800 |
94.96%
|
Short Duration Bond Portfolio – Class I
|
NATIONWIDE LIFE INSURANCE COMPANY
(NWVAII) C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 COLUMBUS OH 43218-2029 |
52.08%
|
JEFFERSON NATL LIFE INSURANCE
ATTN CARLA HIGGS - C1B SEPERATE ACCOUNTS ATTN CARLA HIGGS C1B SEPARATE ACCT 10350 ORMSBY PARK PL STE 600 LOUISVILLE KY 40223-6175 |
11.65%
|
|
NATIONWIDE LIFE INSURANCE COMPANY
(NWVA9) C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 COLUMBUS OH 43218-2029 |
9.57%
|
|
NATIONWIDE LIFE INSURANCE CO
PMLIC-VLI C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 ONE NATIONWIDE PLAZA COLUMBUS OH 43218-2029 |
5.16%
|
Sustainable Equity Portfolio – Class I
|
NORTHWESTERN MUTUAL LIFE
VARIABLE ANNUITY ACCOUNT B ATTN MUTUAL FUND ACCOUNTING 720 E WISCONSIN AVE MILWAUKEE WI 53202-4703 |
68.00%
|
Sustainable Equity Portfolio – Class S
|
SECURITY BENEFIT LIFE
VARIFLEX Q NAVISYS 1 SW SECURITY BENEFIT PL TOPEKA KS 66636-1000 |
31.80%
|
PHOENIX LIFE INSURANCE CO
15 TECH VALLEY DR STE 2 E GREENBUSH NY 12061-4137 |
24.43%
|
|
RIVERSOURCE LIFE INSURANCE COMPANY
222 AXP FINANCIAL CENTER MINNEAPOLIS MN 55474-0001 |
11.65%
|
|
PRUCO LIFE INSURANCE COMPANY
213 WASHINGTON ST FL 7 NEWARK NJ 07102-2917 |
7.31%
|
|
U.S. Equity Index PutWrite Strategy
Portfolio - Class S
|
NATIONWIDE LIFE INSURANCE COMPANY
(NWPP) C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 COLUMBUS OH 43218-2029 |
53.44%
|
RIVERSOURCE LIFE INSURANCE COMPANY
222 AXP FINANCIAL CENTER MINNEAPOLIS MN 55474-0001 |
20.53%
|
|
AXA EQUITABLE LIFE INSURANCE CO
1290 AVENUE OF THE AMERICAS 16TH FL NEW YORK NY 10104-1472 |
9.17%
|
SEPARATE ACCOUNT A OF PACIFIC LIFE
INSURANCE COMPANY 700 NEWPORT CENTER DR NEWPORT BEACH CA 92660-6307 |
8.74%
|
Fund
|
Name and Address
|
Percent Owned
|
International Equity Portfolio
|
PRUDENTIAL FINANCIAL
C/O PRUBENEFIT FUNDING - LAUREATE ATTN TERESITA BUSINELLI VP OPS 80 LIVINGSTON AVE BUILDING ROS 3 ROSELAND NJ 07068-1798 |
62.16%
|
Mid Cap Growth Portfolio
|
NEW YORK LIFE INSURANCE AND ANNUITY
CORPORATION (NYLIAC) ATTN ASHESH UPADHYAY PO BOX 468 JERSEY CITY NJ 07303-0468 |
76.09%
|
Mid Cap Intrinsic Value Portfolio
|
JPMORGAN CHASE BANK CUST FBO
M INTELLIGENT VARIABLE UNULIFE TIAA CREF LIFE SEP A/C VLI2 OF TIAA CREF LIFE INSURANCE CO 8625 ANDREW CARNEGIE BLVD CHARLOTTE NC 28262-8551 |
35.11%
|
OHIO NATIONAL LIFE INSURANCE
COMPANY FOR THE BENEFIT OF ITS SEPARATE ACCOUNTS 1 FINANCIAL WAY CINCINNATI OH 45242-5800 |
27.29%
|
|
Short Duration Bond Portfolio
|
NATIONWIDE LIFE INSURANCE COMPANY
(NWVLI7) C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 COLUMBUS OH 43218-2029 |
72.53%
|
Sustainable Equity Portfolio
|
NORTHWESTERN MUTUAL LIFE
VARIABLE ANNUITY ACCOUNT A ATTN MUTUAL FUND ACCOUNTING 720 E WISCONSIN AVE MILWAUKEE WI 53202-4703 |
61.60%
|
U.S. Equity Index PutWrite Strategy
Portfolio
|
NATIONWIDE LIFE INSURANCE COMPANY
(NWPP) C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 COLUMBUS OH 43218-2029 |
56.28%
|
APRIL 2019 |
|
I.
|
INTRODUCTION AND GENERAL PRINCIPLES
|
A.
|
Certain subsidiaries of Neuberger Berman Group LLC (“NB”) have been delegated the authority and responsibility to vote the proxies of their respective investment advisory clients.
|
B.
|
NB understands that proxy voting is an integral aspect of investment management. Accordingly, proxy voting must be conducted with the same degree of prudence and loyalty accorded any
fiduciary or other obligation of an investment manager.
|
C.
|
NB believes that the following policies and procedures are reasonably expected to ensure that proxy matters are conducted in the best interest of clients, in accordance with NB’s
fiduciary duties, applicable rules under the Investment Advisers Act of 1940, fiduciary standards and responsibilities for ERISA clients set out in Department of Labor interpretations, the UK Stewardship Code, the Japan
Stewardship Code and other applicable laws and regulations.
|
D.
|
In instances where NB does not have authority to vote client proxies, it is the responsibility of the client to instruct the relevant custody bank or banks to mail proxy material
directly to such client.
|
E.
|
In all circumstances, NB will comply with specific client directions to vote proxies, whether or not such client directions specify voting proxies in a manner that is different from
NB’s policies and procedures.
|
F.
|
NB will seek to vote all shares under its authority so long as that action is not in conflict with client instructions. There may be circumstances under which NB may abstain from voting a
client proxy, such as when NB believes voting would not be in clients’ best interests (e.g., not voting in countries with share blocking or meetings in which voting would entail additional costs). NB understands that it must
weigh the costs and benefits of voting proxy proposals relating to foreign securities and make an informed decision with respect to whether voting a given proxy proposal is prudent
and solely in the interests of the clients and, in the case of an ERISA client and other accounts and clients subject to similar local laws, a plan’s participants and beneficiaries. NB’s decision in such circumstances will take
into account the effect that the proxy vote, either by itself or together with other votes, is expected to have on the value of the client’s investment and whether this expected effect would outweigh the cost of voting.
|
II.
|
RESPONSIBILITY AND OVERSIGHT
|
A.
|
NB has designated a Governance & Proxy Committee (“Proxy Committee”) with the responsibility for: (1) developing, authorizing, implementing and updating NB’s policies and procedures; (2)
administering and overseeing the governance and proxy voting processes; and (3) engaging and overseeing any third-party vendors as voting delegates to review, monitor and/or vote proxies. NB, at the recommendation of the Proxy
Committee, has retained Glass, Lewis & Co., LLC (“Glass Lewis”) as its voting delegate.
|
B.
|
The Proxy Committee will meet as frequently and in such manner as necessary or appropriate to fulfill its responsibilities.
|
C.
|
The members of the Proxy Committee will be appointed from time to time and will include the Chief Investment Officer (Equities), the Head of Global Equity Research, the Head of ESG Investing, and
senior portfolio managers. A senior member of the Legal and Compliance Department will advise the Proxy Committee and may be included for purposes of ensuring a quorum.
|
D.
|
In the event that one or more members of the Proxy Committee are not independent with respect to a particular matter, the remaining members of the Proxy Committee shall constitute an ad hoc
independent subcommittee of the Proxy Committee, which will have full authority to act upon such matter.
|
III.
|
PROXY VOTING GUIDELINES
|
A.
|
The Proxy Committee developed the Governance and Proxy Voting Guidelines (“Voting Guidelines”) based on our Governance and Engagement Principles. These Guidelines are updated as
appropriate and generally on an annual basis. With input from certain of our investment professionals, the modifications are intended to reflect emerging corporate governance issues and themes. The Proxy Committee recognizes that
in certain circumstances it may be in the interests of our clients to deviate from our Voting Guidelines.
|
B.
|
Our views regarding corporate governance and engagement, and the related stewardship actions, are led by our ESG Investing group, in consultation with professionals in the Legal
& Compliance and Global Equity Research groups, among others. These insightful, experienced and dedicated groups enable us to think strategically about engagement and stewardship priorities.
|
C.
|
We believe NB’s Voting Guidelines generally represent the voting positions most likely to support our clients’ best economic interests across a range of sectors and contexts. These guidelines are
not intended to constrain our consideration of the specific issues facing a particular company on a particular vote, and so there will be times when we deviate from the Voting Guidelines.
|
D.
|
In the event that a senior investment professional at Neuberger Berman believes that it is in the best interest of a client or clients to vote proxies in a manner inconsistent with NB’s
Voting Guidelines, the investment professional will submit in writing the basis for his or her recommendation. The Proxy Committee will review this recommendation in the context of
the specific circumstances of the situation and with the intention of remaining consistent with our Engagement Principles.
|
IV.
|
PROXY VOTING PROCEDURES
|
A.
|
NB will vote client proxies in accordance with a client’s specific request even if it is in a manner inconsistent with NB’s policies and procedures. Such specific requests should
be made in writing by the individual client or by an authorized officer, representative or named fiduciary of a client.
|
B.
|
NB has engaged Glass Lewis as its advisor and voting agent to: (1) provide research on proxy matters; (2) vote proxies in accordance with NB’s Voting
Guidelines or as otherwise instructed and submit such proxies in a timely manner; (3) handle other administrative functions of proxy voting; (4) maintain records of proxy statements received in connection with proxy votes and provide copies of such proxy statements promptly upon request; and (5) maintain records of votes cast.
|
C.
|
Except in instances where clients have retained voting authority, NB will instruct custodians of client accounts to forward all proxy statements and materials received in respect
of client accounts to Glass Lewis.
|
D.
|
Notwithstanding the foregoing, NB retains final authority and fiduciary responsibility for proxy voting.
|
V.
|
CONFLICTS OF INTEREST
|
A.
|
Glass Lewis will vote proxies in accordance with the Voting Guidelines described in Section III or, in instances where a material conflict has been determined to exist, as Glass Lewis
recommends. NB believes that this process is reasonably designed to address material conflicts of interest that may arise in conjunction with proxy voting decisions. Potential conflicts considered by the Proxy Committee when
it is determining whether to deviate from NB’s Voting Guidelines include, among others: a material client relationship with the corporate issuer being considered; personal or
business relationships between the portfolio managers and an executive officer; director, or director nominee of the issuer; joint business ventures; or a direct transactional relationship between the issuer and senior
executives of NB.
|
B.
|
In the event that an NB Investment Professional believes that it is in the best interest of a client or clients to vote proxies in a manner inconsistent with
the Voting Guidelines described in Section III, such NB Investment Professional will contact a member of the Legal & Compliance Department advising the Proxy Committee and complete and sign a questionnaire in the form adopted from time to time. Such questionnaires will require specific information, including the reasons the NB Investment Professional believes a proxy vote in this manner is in the
best interest of a client or clients and disclosure of specific ownership, business or personal relationship, or other matters that may raise a potential material conflict of interest with respect to the voting of the proxy.
The Proxy Committee will meet with the NB Investment Professional to review the completed questionnaire and consider such other matters as it deems appropriate to determine that
there is no material conflict of interest with respect to the voting of the proxy in the requested manner. The Proxy Committee shall document its consideration of such other matters. In the event that the Proxy Committee
determines that such vote will not present a material conflict, the Proxy Committee will make a determination whether to vote such proxy as recommended by the NB Investment Professional. In the event of a determination to vote
the proxy as recommended by the NB Investment Professional, an authorized member of the Legal & Compliance Department advising the Proxy Committee will instruct Glass Lewis to vote in such manner with respect to the client
or clients. In the event that the Proxy Committee determines that the voting of a proxy as recommended by the NB Investment Professional would not be appropriate, the Proxy Committee will:
|
(i)
|
take no further action, in which case Glass Lewis shall vote such proxy in accordance with the Voting Guidelines;
|
(ii)
|
disclose such conflict to the client or clients and obtain written direction from the client with respect to voting the proxy;
|
(iii)
|
suggest that the client or clients engage another party to determine how to vote the proxy; or
|
(iv)
|
engage another independent third party to determine how to vote the proxy. A record of the Proxy Committee’s determinations shall be prepared and maintained in accordance with
applicable policies.
|
C.
|
In the event that the Voting Guidelines described in Section III do not address how a proxy should be voted and Glass Lewis refrains from making a recommendation as to how such
proxy should be voted, the Proxy Committee will make a determination as to how the proxy should be voted. The Proxy Committee will consider such matters as it deems appropriate to determine how such proxy should be voted
including whether there is a material conflict of interest with respect to the voting of the proxy in accordance with its decision. The Proxy Committee shall document its consideration of such matters, and an authorized member
of the Legal & Compliance Department advising the Proxy Committee will instruct Glass Lewis to vote in such manner with respect to such client or clients.
|
D.
|
Material conflicts cannot be resolved by simply abstaining from voting.
|
Exhibit
Number
|
Description
|
|||
(a)
|
(1)
|
Restated Certificate of Trust. Incorporated by Reference to Post-Effective Amendment No. 79 to Registrant's Registration Statement on Form N-1A, File Nos. 2-88566 and 811-4255. (Filed April 21, 2017). | ||
(2)
|
||||
(3)
|
||||
(b)
|
||||
(c)
|
(1)
|
|||
(2)
|
||||
(d)
|
(1)
|
(i)
|
||
(ii)
|
||||
(2)
|
(i)
|
|||
(ii)
|
||||
(3)
|
||||
(e)
|
(1)
|
(i)
|
||
(ii)
|
||||
(2)
|
(i)
|
Exhibit
Number
|
Description | ||
(ii)
|
|||
(3)
|
(i)
|
||
(ii)
|
|||
(f)
|
Bonus or Profit Sharing Contracts – None.
|
||
(g)
|
(1)
|
||
(2)
|
|||
(3)
|
|||
(4)
|
|||
(h)
|
(1)
|
||
(2)
|
(i)
|
||
(ii)
|
|||
(3)
|
(i)
|
||
(ii)
|
|||
(4)
|
Exhibit
Number
|
Description | ||
(2)
|
(i)
|
||
(ii)
|
|||
(n)
|
(1)
|
(i)
|
|
(ii)
|
|||
(iii)
|
|||
(o)
|
|||
(p)
|
NAME
|
BUSINESS AND OTHER CONNECTIONS
|
Joseph V. Amato
President – Equities and Chief
Investment Officer – Equities, NBIA
|
Chief Executive Officer and President, Neuberger Berman Holdings LLC (including its predecessor, Neuberger Berman Inc.); President and Director of Neuberger Berman Group LLC; Chief Executive Officer and President, NB BD LLC; Trustee,
twelve registered investment companies for which NBIA acts as investment manager and/or administrator; Chief Executive Officer and President, twelve registered investment companies for which NBIA acts as investment manager and/or
administrator.
|
Thanos Bardas
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Ashok Bhatia
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Jennifer Blachford
Senior Vice President, NBIA
|
Senior Vice President, NB BD LLC; Portfolio Manager.
|
James Bowden
Managing Director, NBIA
|
Managing Director, NB BD LLC; Managing Director, NB Alternatives Advisers LLC (“NBAA”).
|
Claudia A. Brandon
Senior Vice President, NBIA |
Senior Vice President, NB BD LLC; Executive Vice President and Secretary, twenty-nine registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Richard N. Bradt
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
David M. Brown
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Chad Bruso
Senior Vice President, NBIA |
Senior Vice President, NB BD LLC; Portfolio Manager.
|
John Buser
Managing Director, NBIA
|
Managing Director, NB BD LLC; President and Managing Director, NBAA.
|
Stephen J. Casey
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Brad E. Cetron
Chief Compliance Officer, Head of
Compliance and Managing Director of
Compliance, NBIA
|
Chief Compliance Officer and Managing Director, NB BD LLC.
|
Elias Cohen
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
William R. Covode
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Timothy Creedon
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
NAME | BUSINESS AND OTHER CONNECTIONS |
Brian C. Jones
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Charles Kantor
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Tokufumi Kato
Managing Director, NBIA
|
Portfolio Manager.
|
Hakan Kaya
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Brian Kerrane
Chief Operating Officer – Mutual
Funds and Managing Director, NBIA
|
Managing Director, NB BD LLC; Chief Operating Officer, and Vice President, twenty-nine registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Erik Knutzen
Managing Director, NBIA
|
Managing Director, NB BD LLC; Multi-Asset Class Chief Investment Officer, Neuberger Berman Group LLC.
|
Christopher Kocinski
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
David Kupperman
Managing Director, NBIA |
Managing Director, NB BD LLC; Managing Director, NBAIM; Portfolio Manager.
|
Nathan Kush
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Sajjad S. Ladiwala
Managing Director, NBIA |
Managing Director, NB BD LLC.
|
David Levine
Senior Vice President, NBIA |
Senior Vice President, NB BD LLC; Portfolio Manager.
|
Richard S. Levine
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Joseph Lind
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Brian Lord
Chief Compliance Officer – Fixed
Income and Senior Vice President,
NBIA
|
Senior Vice President, NB BD LLC.
|
James Lyman
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Joseph P. Lynch
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Jeffrey Majit
Managing Director, NBIA |
Managing Director, NB BD LLC; Managing Director, NBAIM; Portfolio Manager.
|
Jared Mann,
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
NAME | BUSINESS AND OTHER CONNECTIONS |
James F. McAree
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Kevin McCarthy
Senior Vice President, NBIA
|
Senior Vice President, NB BD LLC; Portfolio Manager.
|
Matthew McGinnis
Senior Vice President, NBIA
|
Senior Vice President, NB BD LLC; Portfolio Manager.
|
S. Blake Miller
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Norman Milner
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Trevor Moreno
Vice President, NBIA |
Senior Vice President, NB BD LLC; Portfolio Manager.
|
Richard S. Nackenson
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Benjamin H. Nahum
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Eric J. Pelio
Senior Vice President, NBIA
|
Senior Vice President, NB BD LLC; Portfolio Manager.
|
Alexandra Pomeroy
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Douglas A. Rachlin
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Hari Ramanan
Managing Director, NBIA
|
Portfolio Manager.
|
Marc Regenbaum
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Brett S. Reiner
Managing Director, NBIA |
Managing Director, NB BD LLC; Associate Portfolio Manager.
|
Joana Rocha Schaff
Managing Director, NBIA
|
Managing Director, NB BD LLC; Managing Director, NBAA.
|
Conrad A. Saldanha
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Eli M. Salzmann
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
John San Marco
Senior Vice President, NBIA
|
Senior Vice President, NB BD LLC; Portfolio Manager.
|
NAME | BUSINESS AND OTHER CONNECTIONS |
Linda Sharaby
Secretary and Managing Director,
NBIA
|
Managing Director and Secretary, NB BD LLC; Managing Director and Secretary, Neuberger Berman Holdings LLC.
|
Steve Shigekawa
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Ronald B. Silvestri
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Jonathan Shofet
Managing Director, NBIA
|
Managing Director, NB BD LLC; Managing Director, NBAA.
|
Brien Smith
Managing Director, NBIA
|
Managing Director, NB BD LLC; Chief Operating Officer and Managing Director, NBAA.
|
Amit Solomon
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Gregory G. Spiegel
Managing Director, NBIA |
Managing Director, NB BD LLC; Associate Portfolio Manager.
|
David Stonberg
Managing Director, NBIA
|
Managing Director, NB BD LLC; Managing Director, NBAA.
|
Robert Surgent
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Brad Tank
President - Fixed Income and Chief
Investment Officer - Fixed Income,
NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Jason Tauber
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Shawn Trudeau
Managing Director, NBIA
|
Senior Vice President, NB BD LLC; Portfolio Manager.
|
Kenneth J. Turek
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Anthony Tutrone
Managing Director, NBIA
|
Managing Director, NB BD LLC; Chief Executive Officer and Managing Director, NBAA.
|
James Tyre
Senior Vice President, NBIA
|
Senior Vice President, NB BD LLC; Portfolio Manager.
|
Gorky Urquieta
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Judith M. Vale
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Niketh Velamoor
Senior Vice President, and Associate
General Counsel, NBIA
|
Senior Anti-Corruption and Anti-Money Laundering Officer and Senior Vice President, NB BD LLC; Anti-Money Laundering Compliance Officer, five registered investment companies for which NBIA acts as investment manager and/or administrator.
|
NAME | BUSINESS AND OTHER CONNECTIONS |
Leo Anthony Viola
Treasurer and Senior Vice President,
NBIA
|
Treasurer and Senior Vice President, NB BD LLC; Treasurer, NBAA.
|
Peter Von Lehe
Managing Director, NBIA
|
Managing Director, NB BD LLC; Managing Director, NBAA.
|
David Yi Wan
Senior Vice President, NBIA
|
Senior Vice President, NB BD LLC; Portfolio Manager.
|
Eric Zhou
Senior Vice President, NBIA |
Vice President, NB BD LLC; Portfolio Manager.
|
NAME
|
POSITIONS AND OFFICES
WITH UNDERWRITER |
POSITIONS AND OFFICES
WITH REGISTRANT |
Joseph V. Amato
|
Chief Executive Officer and President
|
President, Chief Executive Officer and Trustee
|
Thanos Bardas
|
Managing Director
|
None
|
Ashok Bhatia
|
Managing Director
|
None
|
Jennifer Blachford
|
Senior Vice President
|
None
|
James Bowden
|
Managing Director
|
None
|
Richard N. Bradt
|
Managing Director
|
None
|
Claudia A. Brandon
|
Senior Vice President
|
Executive Vice President and Secretary
|
David M. Brown
|
Managing Director
|
None
|
Chad Bruso
|
Senior Vice President
|
None
|
John Buser
|
Managing Director
|
None
|
Stephen J. Casey
|
Managing Director
|
None
|
Brad E. Cetron
|
Chief Compliance Officer and Managing Director
|
None
|
Elias Cohen
|
Managing Director
|
None
|
William R. Covode
|
Managing Director
|
None
|
Timothy Creedon
|
Managing Director
|
None
|
Robert W. D’Alelio
|
Managing Director
|
None
|
Derek Devens
|
Managing Director
|
None
|
Daniel Doyle
|
Managing Director
|
None
|
Ingrid Dyott
|
Managing Director
|
None
|
Steven Eisman
|
Managing Director
|
None
|
Michael Foster
|
Managing Director
|
None
|
Jacob Gamerman
|
Managing Director
|
None
|
Rand W. Gesing
|
Senior Vice President
|
None
|
Jennifer Gorgoll
|
Managing Director
|
None
|
Michael C. Greene
|
Managing Director
|
None
|
Jeffrey Hunn
|
Senior Vice President
|
None
|
William Hunter
|
Managing Director
|
None
|
James L. Iselin
|
Managing Director
|
None
|
Brian C. Jones
|
Managing Director
|
None
|
Charles Kantor
|
Managing Director
|
None
|
Hakan Kaya
|
Managing Director
|
None
|
Brian Kerrane
|
Managing Director
|
Chief Operating Officer and Vice President
|
Erik Knutzen
|
Managing Director
|
None
|
Christopher Kocinski
|
Managing Director
|
None
|
David Kupperman
|
Managing Director
|
None
|
Nathan Kush
|
Managing Director
|
None
|
Sajjad S. Ladiwala
|
Managing Director
|
None
|
David Levine
|
Senior Vice President
|
None
|
Richard S. Levine
|
Managing Director
|
None
|
Joseph Lind
|
Managing Director
|
None
|
Brian Lord
|
Senior Vice President
|
None
|
James Lyman
|
Managing Director
|
None
|
Joseph P. Lynch
|
Managing Director
|
None
|
Jeffrey Majit
|
Managing Director
|
None
|
Jared Mann
|
Managing Director
|
None
|
James F. McAree
|
Managing Director
|
None
|
Kevin McCarthy
|
Senior Vice President
|
None
|
Matthew McGinnis
|
Senior Vice President
|
None
|
S. Blake Miller
|
Managing Director
|
None
|
Norman Milner
|
Managing Director
|
None
|
Trevor Moreno
|
Senior Vice President
|
None
|
Richard S. Nackenson
|
Managing Director
|
None
|
Benjamin H. Nahum
|
Managing Director
|
None
|
Eric J. Pelio
|
Senior Vice President
|
None
|
Alexandra Pomeroy
|
Managing Director
|
None
|
Douglas A. Rachlin
|
Managing Director
|
None
|
Marc Regenbaum
|
Managing Director
|
None
|
Brett S. Reiner
|
Managing Director
|
None
|
Henry Rosenberg
|
Senior Vice President
|
None
|
Conrad A. Saldanha
|
Managing Director
|
None
|
Eli M. Salzmann
|
Managing Director
|
None
|
Ronald B. Silvestri
|
Managing Director
|
None
|
Linda Sharaby
|
Secretary and Managing Director
|
None
|
Steve Shigekawa
|
Managing Director
|
None
|
Jonathan Shofet
|
Managing Director
|
None
|
Brien Smith
|
Managing Director
|
None
|
Amit Solomon
|
Managing Director
|
None
|
Gregory G. Spiegel
|
Managing Director
|
None
|
David Stonberg
|
Managing Director
|
None
|
Robert Surgent
|
Managing Director
|
None
|
Brad Tank
|
Managing Director
|
None
|
Jason Tauber
|
Managing Director
|
None
|
Shawn Trudeau
|
Senior Vice President
|
None
|
Kenneth J. Turek
|
Managing Director
|
None
|
Anthony Tutrone
|
Managing Director
|
None
|
James Tyre
|
Senior Vice President
|
None
|
Gorky Urquieta
|
Managing Director
|
None
|
Judith M. Vale
|
Managing Director
|
None
|
Niketh Velamoor
|
Senior Anti-Corruption and Anti-Money Laundering Officer and Senior Vice President
|
Anti-Money Laundering Compliance Officer
|
Leo Anthony Viola
|
Treasurer and Senior Vice President
|
None
|
Peter Von Lehe
|
Managing Director
|
None
|
David Yi Wan
|
Senior Vice President
|
None
|
Richard Werman
|
Managing Director
|
None
|
Eric Zhou
|
Senior Vice President
|
None
|
|
NEUBERGER BERMAN ADVISERS MANAGEMENT TRUST
|
|
|
|
|
|
By:
|
/s/ Joseph V. Amato
|
Name: |
Joseph V. Amato | |
Title: |
President and Chief Executive Officer |
Signature
|
Title
|
Date
|
/s/ Joseph V. Amato
|
President, Chief Executive Officer
and Trustee
|
April 20, 2022
|
Joseph V. Amato
|
||
John M. McGovern
|
Treasurer and Principal Financial and
Accounting Officer
|
April 20, 2022
|
John M. McGovern
|
||
/s/ Michael J. Cosgrove
|
Trustee
|
April 20, 2022
|
Michael J. Cosgrove*
/s/ Marc Gary
|
Trustee
|
April 20, 2022
|
Marc Gary*
|
||
/s/ Martha C. Goss
|
Trustee
|
April 20, 2022
|
Martha C. Goss*
|
||
/s/ Michael M. Knetter
|
Trustee
|
April 20, 2022
|
Michael M. Knetter*
|
||
/s/ Deborah C. McLean
|
Trustee
|
April 20, 2022
|
Deborah C. McLean*
|
||
/s/ George W. Morriss
|
Trustee
|
April 20, 2022
|
George W. Morriss*
|
||
/s/ Tom D. Seip
|
Chairman of the Board and Trustee
|
April 20, 2022
|
Tom D. Seip*
|
||
/s/ James G. Stavridis
|
Trustee
|
April 20, 2022
|
James G. Stavridis*
|
Exhibit Number
|
Description
|
(h)(6)
|
|
(h)(10)
|
|
(i)
|
|
(j)
|
|
(p)
|
|
Very truly yours, | |
|
|
|
|
NEUBERGER BERMAN ADVISERS MANAGEMENT TRUST,
on behalf of
INTERNATIONAL EQUITY PORTFOLIO
MID CAP GROWTH PORTFOLIO
MID CAP INTRINSIC VALUE PORTFOLIO
REAL ESTATE PORTFOLIO
SHORT DURATION BOND PORTFOLIO
SUSTAINABLE EQUITY PORTFOLIO
U.S. EQUITY INDEX PUTWRITE STRATEGY PORTFOLIO
|
|
By: | /s/ Joseph V. Amato | |
Name: |
Joseph V. Amato | |
Title: | President and Chief Executive Officer |
By: | /s/ Joseph V. Amato |
|
|
Name: | Joseph V. Amato |
Title: | President and Chief Investment Officer-- Equities |
Fund
|
Class
|
Limitation Period
|
Expense Limitation^
|
International Equity Portfolio
|
I
|
12/31/2025
|
1.00%
|
S
|
12/31/2025
|
1.50%
|
|
Mid Cap Growth Portfolio
|
I
|
12/31/2025
|
1.00%
|
S
|
12/31/2025
|
1.10%
|
|
Mid Cap Intrinsic Value Portfolio
|
I
|
12/31/2025
|
1.50%
|
S
|
12/31/2025
|
1.25%
|
|
Real Estate Portfolio
|
S
|
12/31/2025
|
1.75%
|
Short Duration Bond Portfolio
|
I
|
12/31/2025
|
0.95%
|
Sustainable Equity Portfolio
|
I
|
12/31/2025
|
1.30%
|
S
|
12/31/2025
|
1.17%
|
|
U.S. Equity Index PutWrite Strategy Portfolio
|
I
|
12/31/2025
|
0.80%
|
S
|
12/31/2025
|
1.05%
|
1.
|
Terms of Investment
|
2.
|
Representations of the Acquired Funds.
|
3.
|
Representations of the Acquiring Funds.
|
i.
|
of any purchase or acquisition of shares in an Acquired Fund that causes such Acquiring Fund to hold 3% or more of such Acquired Fund’s total outstanding voting securities;
|
|
ii. |
of any purchase or acquisition of shares in an Acquired Fund that causes such Acquiring Fund to hold 5% or more of such Acquired Fund’s total outstanding voting securities; |
iii. |
where an Acquiring Fund and its Advisory Group (as defined in the Rule), individually or in the aggregate, hold more than 25% of such Acquired Fund’s total outstanding voting securities; and | |
iv. |
if at any time an Acquiring Fund no longer holds voting securities of an Acquired Fund in excess of an amount noted in (i), (ii), or (iii) above. |
4.
|
Indemnification.
|
5.
|
Notices. |
6.
|
Term and Termination; Assignment; Amendment |
7.
|
Additional Provisions |
Acquiring Funds | |||
|
|
||
By: |
Legg Mason Partners Fund Advisor, LLC, | ||
On behalf of each of the Acquiring Funds | |||
By: |
/s/ Jane E. Trust |
||
Name: |
Jane E. Trust | ||
Title: |
President |
Acquired Funds | |||
|
|
||
By: |
Neuberger Berman Advisers Management Trust | ||
By: |
/s/ Brian Kerrane |
||
Name: |
Brian Kerrane | ||
Title: |
Managing Director |
K&L GATES LLP
1601 K STREET, N.W.
WASHINGTON, DC 20006-1600 T 202.778.9000 F 202.778.9100 klgates.com
|
|
Very truly yours,
/s/ K&L Gates LLP
|
SERIES
|
CLASSES
|
International Equity Portfolio
|
Class I, Class S
|
Mid Cap Growth Portfolio
|
Class I, Class S
|
Mid Cap Intrinsic Value Portfolio
|
Class I, Class S
|
Real Estate Portfolio
|
Class S
|
Short Duration Bond Portfolio
|
Class I
|
Sustainable Equity Portfolio
|
Class I, Class S
|
U.S. Equity Index PutWrite Strategy Portfolio
|
Class I, Class S
|
Statement of General Principles
|
4
|
A. General Prohibitions
|
5
|
B. Definitions
|
5
|
C. Code Policies
|
11
|
1. Covered Accounts
|
11
|
2. Initial Public Offerings
|
11
|
3. Information Barrier
|
11
|
4. Transactions in Restricted List Securities
|
11
|
5. Private Placements
|
12
|
6. Digital Assets
|
12
|
7. Dissemination of Client Information
|
13
|
8. Gifts
|
13
|
9. Related Issuer
|
13
|
10. Trading Opposite Clients
|
13
|
11. Service on a Board of Directors
|
14
|
12. Limitations on Short and Long Positions
|
14
|
13. Transactions in Shares of Funds
|
14
|
14. Transactions in Futures, Swaps, Forwards and Commodities
|
15
|
15. Sanctions
|
15
|
16. Violations
|
15
|
D. Reporting Requirements
|
15
|
1. Reports by Access Persons
|
15
|
2. Reports by Disinterested Directors/Trustees
|
17
|
3. Exceptions to Reporting Requirements
|
17
|
4. Notification of Reporting Obligations
|
17
|
E. Code Procedures
|
18
|
1. Maintenance of Covered Accounts
|
18
|
2. Pre-Clearance of Securities Transactions
|
18
|
3. Blackout Period
|
19
|
4. Price Restitution
|
20
|
5. Holding Period
|
21
|
6. Code Procedures Monitoring
|
22
|
F. NB Funds’ Ethics and Compliance Committee
|
22
|
G. Annual Report to the NB Funds’ Board
|
23
|
H. Administration
|
23
|
I. Recordkeeping
|
24
|
EXHIBIT A - Compliance Contacts
|
25
|
EXHIBIT B - Applicability of Code Procedures to Temporary Access Persons
|
26
|
•
|
Employees must at all times place the interests of Clients ahead of their personal interests - Client trades have priority over personal securities trades.
|
•
|
Personal securities transactions must be conducted in accordance with this Code and in such a manner as to avoid any actual, perceived or potential conflict of
interest or abuse of an employee’s position of trust and responsibility.
|
•
|
Employees should not take advantage of their position to benefit themselves at the expense of any Client.
|
•
|
In personal securities investing, employees should follow a philosophy of investment rather than trading.
|
•
|
Employees must comply with applicable Federal Securities Laws.
|
•
|
Employ any device, scheme or artifice to defraud any Client;
|
•
|
Make any untrue statement of a material fact to any Client or omit to state to such Client a material fact necessary in order to make the
statements made, in light of the circumstances under which they are made, not misleading;
|
•
|
Engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any Client;
|
•
|
Engage in any manipulative practice with respect to any Client;
|
•
|
Engage in any transaction in a security while in possession of material nonpublic information regarding the security or the issuer of the
security; or
|
•
|
Engage in any transaction intended to raise, lower, or maintain the price of any security or to create a false appearance of active trading.
|
a.
|
Any employee, officer, director of any NB Adviser or NB Fund (or any company controlled by the NB Advisers) and their Immediate Family Members; and
|
b.
|
Any director, officer or general partner of a principal underwriter who, in the ordinary course of business, makes, participates in or obtains information regarding the purchase
or sale of Covered Securities by any NB Fund for which the principal underwriter acts, or whose functions or duties in the ordinary course of business relate to the making of any recommendation to the NB Fund regarding the
purchase or sale of Covered Securities.
|
c.
|
Any temporary employee, consultant, contractor, intern or other person who will be on the Firm’s premises for a period of ninety (90) days or more. See Exhibit B for applicability of
Code Procedures to Temporary Access Persons.
|
•
|
in the name of an Immediate Family Member;
|
•
|
in his or her name as trustee for himself or herself or for his or her Immediate Family Member;
|
•
|
in a trust in which he or she has a Beneficial Interest or is the settlor with a power to revoke;
|
•
|
by another person and he or she has a contract or an understanding with such person that the securities held in that person's name are for his or her benefit;
|
•
|
in the form of acquisition rights of such security through the exercise of warrants, options, rights, or conversion rights;
|
•
|
by a partnership of which he or she is a member;
|
•
|
by a corporation which he or she uses as a personal trading medium;
|
•
|
by a holding company which he or she controls; or
|
•
|
any other relationship in which a person would have beneficial ownership under Rule 16a-1(a)(2) of the Securities Exchange Act of 1934 and the rules and regulations thereunder, except
that the determination of direct or indirect Beneficial Interest shall apply to all securities which an Access Person has or acquires.
|
a.
|
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;
|
b.
|
Shares of any Fund; and
|
c.
|
Exchange Traded Funds and closed-end funds registered under the Company Act.
|
a.
|
Direct obligations of the Government of the United States, its territories or States or Related Securities thereof, (including short term debt securities that are government securities
within the meaning of the law);
|
b.
|
Bankers' acceptances, bank certificates of deposit, commercial paper and high quality short- term debt instruments including repurchase agreements; and
|
c.
|
Shares issued by registered open-end investment companies for which any NB Adviser does not act as investment adviser, sub-adviser or distributor provided such shares are held directly
with the fund company in a mutual fund account and not in a third party brokerage account unless the Access Person has obtained prior written approval from the Legal and Compliance Department to maintain such account.
|
a.
|
Transactions in Managed Accounts.
|
b.
|
Transactions made automatically in accordance with a predetermined schedule and allocation, such as part of a dividend reinvestment plan (“DRIP”).
|
c.
|
An involuntary purchase effected upon the exercise of rights issued by an issuer pro rata to all holders of a class of its securities, to the extent such rights were acquired from such
issuer, and sales of rights so acquired.
|
d.
|
The acquisition or disposition of securities through stock dividends, stock splits, reverse stock splits, mergers, margin calls, consolidations, spin-offs, or other similar corporate
reorganizations or distributions generally applicable to all holders of the same class of securities.
|
e.
|
Securities transactions effected in Blind Trusts.
|
f.
|
A transaction by an NB Fund Disinterested Director/Trustee unless at the time of such transaction, the Disinterested Fund Director/Trustee, knew or should have known that, during
|
|
the fifteen calendar day period immediately preceding or, after the date of the transaction by the Disinterested Director/Trustee, such security was purchased or sold by the NB Fund
or was being considered for purchase or sale for Clients of the NB Adviser, provided that the foregoing does not apply if the Disinterested Fund Director/Trustee gains knowledge that such security was held by the NB Fund due to public
disclosure on the NB Fund’s website of such holding.
|
g.
|
Transactions in the following broad-based security indices: S&P 500, NASDAQ, 7-10 Year Treasury Bond Index, 20+ Year Treasury Bond Index, Russell 2000 and Dow Jones Industrial
Average. 3
|
h.
|
Other transactions designated in writing by the Legal and Compliance Department.
|
a.
|
An Access Person’s child, stepchild, grandchild, parent, stepparent, grandparent, spouse, Domestic Partner, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law,
brother-in-law, sister-in- law, including adoptive relationships who share the same household as the Access Person or to whom the employee provides material financial support; and
|
b.
|
Any other relative or person who shares the same household as the Access Person or to whom the employee provides material financial support and is deemed to be an Immediate Family
Member by the Legal and Compliance Department.
|
•
|
is or has been held by a Client, or
|
•
|
is being or has been considered by a NB Adviser for purchase by such Client.
|
1.
|
Covered Accounts
|
2.
|
Initial Public Offerings
|
3.
|
Information Barrier
|
4.
|
Transactions in Restricted List Securities
|
5.
|
Private Placements
|
6.
|
Digital Assets
|
i.
|
all Digital Assets Accounts have been disclosed;
|
ii.
|
Any Digital Assets transactions executed during the reporting quarter were pre-cleared; and
|
iii.
|
Digital Assets transactions have complied with the required 60 calendar day holding period.
|
7.
|
Dissemination of Client Information
|
8.
|
Gifts
|
9.
|
Related Issuer
|
10.
|
Trading Opposite Clients
|
•
|
to capture a gain or loss for tax purposes;
|
•
|
the Advisory Person or Advisory Person of a Fund sold the security for the Related Client account in order to raise cash;
|
•
|
securities transactions effected in Blind Trusts;
|
•
|
securities transactions that are non-volitional on the part of the Advisory Person or Advisory Person of a Fund. Non-volitional transactions include shares obtained or redeemed through
a corporate action (e.g. stock dividend) or the exercise of rights issued by an issuer pro rata to all holders of a class of securities; or
|
•
|
other such exceptions as may be granted by the Legal and Compliance Department.
|
11.
|
Service on a Board of Directors
|
12.
|
Limitations on Short and Long Positions
|
i.
|
A purchase to cover an existing short position, except that if an Advisory Person intends to create a long position for a Related Client in the same security, all Related Client
transactions must be completed before the Advisory Person can cover their short position.
|
ii.
|
A short sale against a broad-based index. Approved broad-based indices include the S&P 500, NASDAQ, 7-10 Year Treasury Bond Index, 20+ Year Treasury Bond Index, Russell 2000 and Dow
Jones Industrial Average. Any other index must be approved by the Legal and Compliance Department before engaging in any short sales against such index.
|
iii.
|
A short sale to hedge an existing security position provided the hedging activity is proportionate to the account.
|
iv.
|
Any approvals granted under this section will not relieve the Advisory Person from being subject to Price Restitution.
|
13.
|
Transactions in Shares of Funds
|
a.
|
All trading in shares of a Fund is subject to the terms of the prospectus and the Statement of Additional Information of the Fund.
|
b.
|
No Access Person may engage in excessive trading or market timing in any shares of any Fund.
|
14.
|
Transactions in Futures, Swaps, Forwards and Commodities
|
15.
|
Sanctions
|
16.
|
Violations
|
•
|
Non-compliance with applicable laws, rules, and regulations;
|
•
|
Fraud or illegal acts involving any aspect of the Firm’s business;
|
•
|
Material misstatements in regulatory filings, internal books and records, client records or reports;
|
•
|
Activity that is harmful to clients, including fund investors; and
|
•
|
Deviations from required controls and procedures that safeguard clients and the Firm.
|
1.
|
Reports by Access Persons
|
a.
|
Initial Disclosure
|
i.
|
All Access Persons must disclose their Covered Accounts within 10 calendar days of becoming an Access Person. The initial holdings disclosure must include all Covered Accounts in which the Access Person has a direct or indirect
Beneficial Interest. Access Persons may satisfy this requirement by providing copies of their account statements for all Covered Accounts to the Legal and Compliance Department (as applicable).
|
ii.
|
The information provided must be current as of a date no more than 45 days prior to the date the person became an Access Person.
|
iii.
|
Access Persons will be provided with a copy of the Code of Ethics and be required to acknowledge receipt of the Code.
|
i.
|
Within 30 days of the end of each calendar quarter, Access Persons must disclose securities transactions in any Covered Security in which such Access Person has, or by reason of such
transaction acquires, any direct or indirect Beneficial Interest that occurred during the previous quarter. For each transaction executed during the quarter, the following information must be provided:
|
•
|
the date of the transaction;
|
•
|
type of transaction (buy, sell, short, cover, etc.);
|
•
|
name of security, exchange ticker, symbol or CUSIP number;
|
•
|
the number of shares, price and principal amount;
|
•
|
the broker, dealer or bank with, or through which, the transaction was effected; and
|
•
|
the interest rate and maturity date (as applicable).
|
ii.
|
The above requirement may be satisfied if information is being received by Neuberger Berman as stated in Section D(3).
|
i.
|
On an annual basis, Access Persons must affirm that all Covered Accounts have been reported and are reflected in iCompliance.
|
ii.
|
Access Persons are required to certify that they have read, understand, and complied with the Code of Ethics and the Information Barrier Policies and
|
|
Procedures, and have disclosed or reported all personal securities transactions, holdings and accounts required to be disclosed or reported pursuant to the requirements of the Code.
|
iii.
|
The information provided must be current as of a date no more than 45 days of the date the report is submitted.
|
iv.
|
With respect to any Blind Trust in which an Access Person has a Beneficial Interest,such Access Person must certify that they do not exert any direct or indirect influence or control
over the trustee by: a) suggesting or directing any particular transactions in the account, or b) consulting with the trustee regarding the allocation of investments in the account. .
|
v.
|
With respect to any Managed Account managed by a third-party, Access Persons must certify that they do not exert any direct or indirect influence or control over the third-party manager
by: a) suggesting or directing any particular transactions in the account, or b) consulting with the third-party manager regarding the allocation of investments in the account.
|
a.
|
An initial holdings disclosure and annual holdings disclosure under Section D(1)(a) and (c) above; and
|
b.
|
A quarterly transactions disclosure under Section D(1)(b) above, unless the director/trustee knew or, in the ordinary course of fulfilling their official duties as a NB Fund
director/trustee, should have known that during the 15-day period immediately before or after the director/trustee’s transaction in a Covered Security, the NB Fund purchased or sold the Covered Security, or the NB Fund or its investment
adviser considered purchasing or selling the Covered Security, provided that the foregoing does not apply if the Disinterested Fund Director/Trustee gains knowledge that such security was held by the NB Fund due to public disclosure on the
NB Fund’s website of such holding.
|
a.
|
General Rules
|
i.
|
Access Persons who are not Advisory Persons may maintain their Covered Accounts at Neuberger Berman or Fidelity. Prior written approval from the Legal and Compliance Department is
required for Fidelity accounts.
|
ii.
|
Advisory Persons are required to maintain their Covered Accounts at Neuberger Berman.9
|
iii.
|
Limited Access Persons are not required to keep their securities accounts at Neuberger Berman or Fidelity.
|
b.
|
Exceptions to Maintenance of Covered Accounts at Neuberger Berman or Fidelity:
|
i.
|
Managed Accounts. Any Access Person granted approval to maintain an external Managed Account is required to direct their broker, adviser or trustee to provide duplicate copies of all
trade confirmations, as well as copies of account statements to the Legal and Compliance Department.
|
ii.
|
DRIPs established directly with the issuer that have been approved by the Legal and Compliance Department and for which duplicate copies of confirmations and periodic statements are
provided.
|
iii.
|
Other accounts as may be permitted by the Legal and Compliance Department.
|
a.
|
Access Persons
|
i.
|
Access Persons are required to obtain prior approval for transactions in Covered Accounts not maintained at Neuberger Berman by submitting a pre-clearance request in iCompliance that is
compared with the Firm’s Restricted List.
|
ii.
|
Access Persons are required to obtain prior approval from the Trading Desk before executing any transactions in Covered Accounts held at Neuberger Berman. Before granting approval, the
Trading Desk, subject to oversight by the Legal and Compliance Department, will determine whether:
|
•
|
the employee is an Advisory Person of a Fund that is a Related Client with a pending "buy" or "sell" order in the same (or Related Security);
|
•
|
the security is on the Firm’s Restricted List(s); or
|
•
|
the transaction is de minimis
|
iii.
|
The Legal and Compliance Department reviews transactions for required trade pre-clearance and all transactions are subject to the Price Restitution review, subject to certain exceptions
(see section E(4)).
|
b.
|
Advisory Persons
|
c.
|
NB CEF Insiders
|
d.
|
Exceptions from Pre-clearance Requirement
|
i.
|
Exempt Transactions
|
ii.
|
Other securities designated in writing by the Legal and Compliance Department
|
a.
|
Same Day – Advisory Persons of a Fund
|
i.
|
An Advisory Person of a Fund may not buy or sell a Covered Security (or a Related Security) on a day during which any Related Client executes either a “buy” or “sell” order in the
same security (“Same Day Blackout Period”).
|
ii.
|
Purchases that occur within the Same Day Blackout Period will be required to be “broken.” Any losses will be incurred by the Covered Account and any gains (including gains disgorged
from a sale within the Same Day Blackout Period) may be donated to a charitable organization designated by the Firm.
|
iii.
|
Certain Limited Access Person Accounts may be subject to the Same Day Blackout Period.
|
b.
|
Research Personnel
|
a.
|
Same Day Price Restitution
|
•
|
If an Access Person purchases or sells a Covered Security in a Covered Account and a Client purchases or sells the same security during the same day, the Access Person may not receive a
more favorable price than that received by the Client.
|
•
|
If an Advisory Person related to a Limited Access Person purchases or sells a Covered Security in the Limited Access Person Account and such Advisory Person purchases or sells the same
security during the same day for a Related Client, the Limited Access Person Account may not receive a more favorable price than that received by the Related Client.
|
iii.
|
For the avoidance of doubt, a “purchase” includes a long buy, as well as a cover short, and a “sell” includes a long sell, as well as a short sale.
|
b.
|
Five(5)/One(1) Day Price Restitution – Advisory Persons
|
i.
|
If an Advisory Person purchases or sells a Covered Security within five (5) business days prior, or one (1) business day subsequent to a Related Client (“5/1
Price Restitution”), the Advisory Person may not receive a more favorable price than that received by the Related Client.
|
ii.
|
Certain Limited Access Person Accounts may be subject to the 5/1 Price Restitution.
|
iii.
|
For the avoidance of doubt, a “purchase” includes a long buy, as well as a cover short, and a “sell” includes a long sell, as well as a short sale.
|
c.
|
Price Restitution Execution
|
i.
|
Price restitution will generally be executed when there is a total gain of at least $1000 from the difference in price received by the Access Person vs. the
Related Client(s), and a gain of at least $100 to each underlying Client Account.
|
ii.
|
With respect to the Funds, the Legal and Compliance Department reserves the right to review the individual restitutions below $1000 and may require payment of
these amounts if facts and circumstances warrant.
|
iii.
|
Where restitution is required, preference shall be to provide the economic benefit to Clients where operationally, contractually or legally permitted. Where otherwise not feasible or
permitted, restitution may be made by transfer, wire or check and shall be remitted to the Firm for donation to a charitable organization designated by the Firm.
|
d.
|
Exceptions to Price Restitution
|
i.
|
Exempt Transactions.
|
ii.
|
De minimis Restitution.
|
iii.
|
Transactions in non-Covered Securities.
|
iv.
|
Transactions arising through hedged options trading.
|
v.
|
Transactions in the Firm’s retirement contribution program.
|
vi.
|
Certain transactions related to the initial investment of a Related Client account or investments made as a result of additional funds contributed to an existing
Related Client account communicated to the Legal and Compliance Department.
|
vii.
|
Other exceptions designated in writing by the Legal and Compliance Department.
|
a.
|
Sixty (60) Day Holding Period
|
i.
|
All securities positions, including both long and short positions, established in any Covered Account must be held for at least 60 calendar days.10
|
ii.
|
Access Persons are required to hold shares of any Fund for at least 60 calendar days. After the holding period has lapsed, Fund shares may be redeemed or exchanged; however, the
redemption or exchange of such shares will result in a new 60-day holding period.
|
iii.
|
The holding period begins on the day of the transaction and is measured on a last-in, first-out (“LIFO”) basis.
|
b.
|
Exceptions to the Holding Period
|
i.
|
Transactions in Managed Accounts
|
ii.
|
U.S. Treasury obligations
|
iii.
|
Bona fide hedging transactions, identified as such to the Legal and Compliance Department prior to execution, on the following broad-based indices: S&P 500,
NASDAQ, 7-10 Year Treasury Bond Index, 20+ Year Treasury Bond Index, Russell 2000 and Dow Jones Industrial Average.
|
iv.
|
Positions where at time of order entry, there is an expected loss of at least 10%. This exclusion does not apply to losses in options on equities.
|
v.
|
Notwithstanding the foregoing, on a limited basis and with the prior approval of the Legal and Compliance Department and CIO (or designee), shares that have been
held for at least one year may be sold even if additional shares of the same security were purchased in the last 60 calendar days.
|
vi.
|
The 60-day holding period for Funds shall not apply to:
|
•
|
Taxable and tax-exempt money market funds;
|
•
|
Variable annuity contracts for which a Fund does not serve as the underlying investment vehicle; and
|
•
|
Shares of an investment company that are purchased through an automatic investment program or payroll deduction.
|
vii.
|
The above exclusions shall not apply if, in the opinion of the Legal and Compliance Department, a pattern of excessive trading exists.
|
1.
|
The Ethics and Compliance Committee shall be composed of at least two members who shall be Disinterested Director/Trustees selected by the Board of Directors/Trustees of the
Company/Trust (the “Board”).
|
2.
|
The Ethics and Compliance Committee shall consult regularly with the Legal and Compliance Department and/or the NB Funds Chief Compliance Officer and either the Committee or the Board
shall meet no less frequently than annually with the Legal and Compliance Department and/or the NB Funds Chief Compliance Officer regarding the implementation of this Code. The Legal and Compliance Department shall provide the Ethics and
Compliance Committee with such reports as are required herein or as are requested by the Ethics and Compliance Committee.
|
3.
|
On a quarterly basis, i) the NB Funds’ Chief Compliance Officer reviews with the Ethics and Compliance Committee violations of the Code, if any, and ii) the Chief Compliance Officers of
NBIA and NBBD provide certifications to the NB Funds’ Board with respect to whether there were any material violations of the Code.
|
G.
|
Annual Report to the NB Funds’ Board
|
•
|
describes any issues arising under this Code or procedures concerning personal investing since the last such report, including, but not limited to, information about material violations
of the Code or procedures and sanctions imposed in response to the material violations;
|
•
|
certifies that NBIA, the NB Funds or any NB Adviser, as applicable, have adopted procedures reasonably necessary to prevent Access Persons from violating the Code; and
|
•
|
identifies any recommended changes in existing restrictions or procedures based upon the fund's experience under the Code, evolving industry practices, or developments in applicable
laws or regulations.
|
1.
|
All Access Persons must be presented with a copy of this Code of Ethics upon commencement of employment and any amendments thereafter.
|
2.
|
All Access Persons are required to read this Code of Ethics and to acknowledge in writing that they have read, understood and agreed to abide by this Code of
Ethics, upon
|
|
commencement of employment and on an annual basis thereafter. In addition, Access Persons are required to read and understand any amendments thereto.
|
3.
|
All Access Persons are required to provide a list of their Covered Accounts.
|
4.
|
Access Persons who violate the rules of this Code of Ethics are subject to sanctions, which may include censure, suspension or termination of employment.
|
5.
|
Nothing contained in this Code of Ethics shall be interpreted as relieving any Covered Account from acting in accordance with the provisions of any applicable law,
rule or regulation or any other statement of policy or procedure governing the conduct of Access Persons.
|
6.
|
If any Access Person has any question with regard to the applicability of the provisions of this Code of Ethics generally or with regard to any securities
transaction, he or she should consult with Legal and Compliance.
|
7.
|
The Legal and Compliance Department may grant exceptions to the requirements of this Code based upon individual facts and circumstances. Exceptions granted will be
documented and retained in accordance with record-keeping requirements. Exceptions will not serve as precedent for additional exceptions, even under similar circumstances.
|
1.
|
A copy of this Code of Ethics and any Code of Ethics that has been in effect within the previous five years.
|
2.
|
Any record of any violation of this Code of Ethics and any action taken as a result of the violation. These records shall be maintained in an easily accessible place for at least five
years after the end of the fiscal year in which the violation occurs.
|
3.
|
A copy of each report made by an Access Person as required by this Code of Ethics, including any information provided in lieu of the monthly reports. These records shall be maintained
for at least five years after the end of the fiscal year in which the report is made or the information provided, the first two years in an easily accessible place.
|
4.
|
A record of all persons, currently or within the past five years, who are or were required to make reports under this Code of Ethics, or who are or were responsible for reviewing these
reports. These records shall be maintained in an easily accessible place.
|
5.
|
A copy of each decision to approve an acquisition by an Access Person of any Private Placement. These records must be maintained for at least five years after the end of the fiscal
year in which the approval is granted.
|
NB Adviser
|
Compliance Contact
|
Contact Information
|
NB Alternatives Advisers LLC and Neuberger Berman Investment Advisers LLC - Alternatives
|
Mark Salzberg, CCO
|
(212) 476-5781
|
David Leimgruber
Christina Korzeniowski
|
(212) 476-8992
(212) 476-9151
|
|
Neuberger Berman Canada ULC
|
Viviana Beltrametti Walker, CCO
|
(646) 497-4354
|
Neuberger Berman Investment Advisers LLC - Fixed Income
|
Brian Lord, CCO
|
(312) 325-7707
|
Paul Carter
|
(312) 325-7765
|
|
Neuberger Berman Investment Advisers LLC - Equity
Neuberger Berman BD LLC
|
Brad Cetron, CCO
|
(646) 497-4654
|
Henry Rosenberg
|
(646) 497-4668
|
|
Joshua Blackman
|
(646) 497-4791
|
|
Jason Hauptman
|
(646) 497-4681
|
|
Stacy Miller
|
(646) 497-4663
|
|
Cathy Collier
|
(212) 476-8120
|
|
Paula Roman
|
(646) 497-4667
|
|
Neuberger Berman Investment Advisers LLC - Mutual Funds
|
Savonne Ferguson, CCO
|
(646) 497-4934
|
Chris Connor
|
(212) 476-5430
|
|
Brandi Sinkovich
|
(646) 497-4665
|
|
Noel Daugherty
|
(646) 497-4653
|
|
Janelle White
|
(646) 497-4938
|
|
Neuberger Berman Trust Company N.A. Neuberger Berman Trust Company of Delaware N.A
|
Benedykt Szwalbenest, CCO
|
(212) 476-9869
|
Robert Ciraola
|
(646) 497-4656
|
Tara Rodrigues
|
(646) 497-4694
|
a.
|
All Temporary Access Persons must disclose their Covered Accounts within 10 calendar days of becoming a Temporary Access Person. The initial holdings disclosure must include all Covered
Accounts in which the Temporary Access Person has a direct or indirect Beneficial Interest. Temporary Access Persons may satisfy this requirement by providing copies of their account statements for all Covered Accounts to the Legal and
Compliance Department (as applicable).
|
b.
|
The information provided must be current as of a date no more than 45 days prior to the date the person became an Access Person.
|
c.
|
Temporary Access Persons will be provided with a copy of the Code of Ethics and be required to acknowledge receipt of the Code.
|
a.
|
Temporary Access Persons must provide the Legal and Compliance Department with duplicate statements of all Covered Accounts disclosed, on a monthly basis (or quarterly, as may be
applicable) for their duration at the Firm.
|
1.
|
Temporary Access Persons are not required to hold their Covered Accounts at Neuberger Berman, but must either 1) direct their broker, adviser or trustee, as applicable, to provide
duplicate copies of all trade confirmations, as well as copies of account statements to the Legal and Compliance Department for their duration at the Firm, or 2) provide copies of their trade confirmations and account statements to the
Legal and Compliance Department.
|
1.
|
Temporary Access Persons are required to obtain prior approval for transactions in Covered Accounts by submitting a pre-clearance request in iCompliance.
|
1.
|
A Temporary Access Person of a Fund may not buy or sell a Covered Security (or Related Security) on a day during which any Related Client executes either a “buy” or “sell” order in the
same security (“Same Day Blackout Period”).
|
2.
|
Purchases that occur within the Same Day Blackout Period will be required to be “broken.” Any losses will be incurred by the Covered Account and any gains (including gains disgorged
from a sale within the Same Day Blackout Period) may be donated to a charitable organization designated by the Firm.
|
1.
|
Same Day Price Restitution
|
a.
|
If a Temporary Access Person purchases or sells a Covered Security in a Covered Account and a Client purchases or sells the same security during the same day, the Temporary Access
Person may not receive a more favorable price than that received by the Client.
|
2.
|
Five(5)/One(1) Day Price Restitution
|
a.
|
If a Temporary Access Person purchases or sells a Covered Security within five (5) business days prior, or one (1) business day subsequent to a Related Client (“5/1 Price Restitution”),
the Temporary Advisory Person may not receive a more favorable price than that received by the Related Client.
|
1.
|
Sixty (60) Day Holding Period
|
a.
|
All securities positions, including both long and short positions, established in any Covered Account must be held for at least 60 calendar days.
|
b.
|
Temporary Access Persons are required to hold shares of any Fund for at least 60 calendar days. After the holding period has lapsed, Fund shares may be redeemed or exchanged; however,
the redemption or exchange of such shares will result in a new 60-day holding period.
|
c.
|
The holding period begins on the day of the transaction and is measured on a last-in, first-out (“LIFO”) basis.
|
i.
|
all Digital Assets Accounts have been disclosed;
|
ii.
|
Any Digital Assets transactions executed during the reporting quarter were pre-cleared; and
|
iii.
|
Digital Assets transactions have complied with the required 60 calendar day holding period.
|